This policy explains how we collect and process your personal data in different contexts.
The purpose of this policy is to communicate to people and organizations about the different ways Infrateq Group processes personal data.
We will always process personal data in compliance with the General Data Protection Regulation (referred to below as GDPR).
Personal data is any information relating to an identified or identifiable person, for example names, contact details, IP addresses and identification numbers. Processing of personal data means any action taken on personal data such as, for example, collection, storage, use and transfer.
The policy also explains what legal rights you have related to our processing of your personal data.
We collect and process your personal data in the different contexts described below:
End users of our services
How much personal data we may collect and process differs based on your relationship to Infrateq Group and which products you are using, whether you are seeking a job with Infrateq Group, and whether you have a business relationship with us.
Our CEO has the overall responsibility for the content and implementation of this policy, for reviewing and updating the Policy as a consequence of new statutory requirements, practice and changes to the activities.
We take our legal obligations very seriously and we will always process your data with the protection of your privacy as our main priority. This means that we endeavor only to store the data necessary to carry out the required task, and to store the data for only as long as is needed.
To us it is important that you, as the data subject, may exercise your rights:
The right to be informed
The right of access
The right to rectification
The right to erasure
The right to restrict processing
Notification obligation regarding rectification or erasure of personal data or restriction of processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling
Data subjects have the right to make a Subject Data Access Request (SAR) and we will ensure that it is responded to in compliance with the requirements of the GDPR.
Code of Conduct
This document is the basis for our business ethics and a guide for all Infrateq Groups companies, the code of conduct that all employees are expected to follow. The rules apply to all members of staff, both permanent and temporary, as well as suppliers, partners and subcontractors.
The code of conduct covers basic requirements for human rights, workers rights, and the environment, and is based upon internationally recognised UN and ILO conventions.
It is important that the services and goods that we provide are produced in an ethical way. This involves respecting the provisions of this Code of Conduct even before the products and services reach our clients. The Code of Conduct therefore also applies to suppliers, sub-contractors and producers of goods and services for Infrateq Group.
All managers within Infrateq Group are responsible for ensuring that both the content and the spirit of this Code of Conduct are communicated, understood and acted upon in their teams. It is the manager’s responsibility to keep up to date with and distribute other relevant documented procedures for daily business. They are also expected to encourage team members to report incidents that may violate the Code of Conduct. Explicit or implicit approval of questionable actions will not be tolerated.
The ultimate responsibility for ensuring that the Code of Conduct is implemented and respected lies with the CEO of Infrateq Group.
Infrateq Group will act according to national law in all countries in which we operate. We will take every reasonable precaution to ensure we do not directly or indirectly violate human rights, labor rights, environmental laws, competition law or anti-corruption regulations.
The provisions in this Code of Conduct are minimum requirements. If provisions in local, national or international legislation, regulations, standards or rules set out a more stringent position regarding the matters dealt within this Code of Conduct, these shall be complied with.
Team members shall have the information, skills and tools necessary to run daily operations in accordance with this Code of Conduct. They must have the basic knowledge about sustainability issues needed to understand how to make decisions and what impact those decisions have. We will always encourage employees and owners to come up with new ideas on how we can reduce Infrateq Group´s environmental impact and create social sustainability.
Infrateq Group does not accept discrimination, active or by means of passive support, based on ethnicity, background, disability, gender, sexual orientation, political affiliation, parenthood or age. Every employee with Infrateq Group will be treated with respect. No one will be subject to or threatened with any physical, religious, sexual, psychological, verbal harassment or abuse.
Working conditions and development potential do not depend on gender or background. Upper management, managers and employees are all to contribute to creating a workplace and work environment that promotes equal treatment of employees, regardless of ethnic origin, nationality, religion or belief, sexual orientation, gender identity, gender expression, age, disability, expressions of rights, obligations and opportunities.
It is in our interest to promote diversity and benefit from employees different experiences, qualities and expertise. Through this we create a creative and stimulating work environment that increases the chances of achieving optimal results.
Fundamental human rights are to be known, respected and applied equally whether you are employed by Infrateq Group or by any of our sub-contractors.
We strongly oppose child labor, forced labor or other non-voluntary labor. The term child refers to any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace learning programs, which comply with all laws and regulations, is supported.
In conformance with local law, we shall respect the right of all employees to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.
Infrateq Group protects the individual's right to privacy and integrity when working within the company. We comply with applicable laws and regulations on the storage of personal data and we strive to prevent unauthorized access to such personal data. Infrateq Group does not handle personal data beyond what is permitted by applicable law.
Every person working at Infrateq must have a written contract specifying their terms of employment including their wage conditions and method of payment before entering employment. The contract shall becom prehensible for the employee.
No one will be forced to work more than the upper limits on regular and overtime hours allowed by the law of the country in which they are employed.
Wages and benefits shall as a minimum meet national legal standards or industry benchmark standards, whichever is higher. Deductions from wages as a disciplinary measure is not be permitted.
Infrateq Group will provide a healthy and safe working environment for all employees. We will always strive to prevent accidents and injuries occurring at work and we will take adequate steps to prevent accidents, injuries or attacks on our employees. We will achieve this by applying appropriate safety precautions.
We will provide regular and documented health and safety training. This training will be repeated on a regular basis.
Infrateq Group complies with environmental legislation that prevails in the countries we operate and in the relevant business sectors. We will continuously work to reduce our negative environmental impact.
At present, we can make a big impact by selecting partners and suppliers who have a clear vision of how to achieve their sustainability goals. Our business is dependent on functioning transport, and that the manufacturers of produce use sustainable products and packaging, and that they reduce the use of raw materials through recycling.
We will make conscious choices in our energy procurement, prioritizing energy from renewable sources and constantly work on reducing our energy consumption.
When ordering services that involve transportation, we will consider all aspects of the environmental impact. When choosing means of transportation and travel, we will always try to use the one with the least environmental impact.
We need to travel to meet our customers, for business but above all to install, consult and perform trainings. To the extent that we can, we will choose trains over flights.
Internal meetings such as management meetings, internal training and internal support shall be conducted exclusively online in accordance with Infrateqs policy.
We see it as a matter of duty to recycle and reuse materials. In collaboration with our suppliers, in several countries where we operate, we offer our customers alternative packaging and end-of-life products in connection with those installations.
Infrateq Group is dedicated to ensuring the security of all information that it holds and implements the highest standards of information security in order to achieve this.
The General Data Protection Regulation and the corporate Data Protection policy apply to all of Infrateq Groups personal data processing functions, including those performed on customers, employees, suppliers and partners personal data, and any other personal data the organisation processes from any source.
Infrateq Group aims for, and works toward, full and fair compliance with all data protection legislation.
Standards of fair business, advertising and competition are to be upheld. We are firm believers that free and fair competition works in our favour, allowing us to conduct good and sound business.
Our strength lies in our own competence. All Infrateq Groups employees are to ensure that the company competes as forcefully and constructively as possible, while at all times complying with international and national competition law and Infrateq Groups internal guidelines on competition compliance.
We believe in transparent and consistent corporate governance practices. We abide by all applicable rules and regulations in each of the geographical markets in which we operate. This protects the legitimate interests of our shareholders.
Infrateq Group has a commitment to follow strict accounting principles and standards. We must report financial information correctly and in full. We see it as essential to meet our obligations regarding internal controls and processes to ensure that accounting complies with legislation.
The integrity of Infrateq Group s financial records is critical to the companys business. It is also a key factor in maintaining the trust of our stakeholders. We must ensure that all transactions are properly recorded, classified and summarised in accordance with the group accounting policies. No employee may enter or remove information in the companys accounts that intentionally hides or misrepresents the true nature of any financial or non-financial transaction or result.
No employee may demand or receive from any third party, or offer or give to a third party, any undue advantage for personal gain, unless it can be accepted within the boundaries of international and national legislation and currently accepted business practices.
Infrateq Group abides by all national and international regulations aimed at preventing, detecting and tackling financial crime. This applies in particular to fraud, extortion, money laundering and other related crimes.
Infrateq Group employees must refrain from any act or omission in connection with this type of criminal activity.
Business decisions must always be made in the best interests of the company. Employees must never use their position or influence for any purpose other than to further Infrateq Group interests. Personal relationships or considerations may never influence our decision-making. This includes potential gains not only for employees, but also for their relatives and friends.
To avoid any conflict of interest, permanent employees with full time contracts may not work outside Infrateq Group in any capacity (e. g. employment, consultancy, Board membership) without informing the company of such engagement. If there is even the slightest risk of a conflict of interest, employees must immediately inform their managers.
Infrateq Group observes neutrality with regard to all political parties and political representatives. We abide by international treaties and national legislation concerning lobbying activities.
Infrateq Group complies with the OECD Transfer Pricing Guidelines and all national legal and administrative requirements in relation to tax rules, including intra-group deals and transfers.
Infrateq Group have an obligation and a commitment to ensure that we have proper, full insurance cover for its operations, employees and assets.
Infrateq Group aims to deliver consistent quality in its services and products. The guidelines for quality assurance are based on our principles and standards.
Compliance, Dialogue and Consequences