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Ethics & Compliance

Ethics & Compliance = Good for business

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Ethics & Compliance

Introduction

Every day, in many ways, Mammoet pays attention to the importance of conducting business in an ethical way, in line with the culture of Mammoet. This is a culture based on shared values, where unethical behavior is not tolerated.

Mammoet is committed to conducting business on the basis of honesty, integrity, loyalty and openness. To Mammoet, a good reputation is just as valuable as our employees and our brand.

Mammoet has globally implemented an ethics and compliance program with a strong focus on anti-bribery and corruption, and trade compliance. This program introduced an extensive set of measures to enhance internal control and to ensure compliance with laws and regulations.

The ethics and compliance program has a solid foundation built on Mammoet’s philosophy, shared values and code of conduct. These give clear guidance to everyone on how Mammoet expects  professionals to behave. Advice and training are provided to help employees understand their responsibilities, such as the Anti-Bribery and Corruption Policy and e-learning modules on conducting business with integrity. Colleagues and business partners with concerns related to the code of conduct can always speak up to management, or use the Speak Up line without fear of negative impacts. As a global company, Mammoet adheres to the laws and regulations of the countries in which it operates. Mammoet is committed to compliance with all anti-bribery and corruption laws.

Code of Conduct

WHY A CODE OF CONDUCT?

At Mammoet, we want to conduct successful business, always in the right way. We call this “doing good business." We believe that our company can only remain successful if we all conduct our business in line with our company principles: integrity and loyalty. Because we want to safeguard and build on our excellent reputation.

CODE OF CONDUCT

1. Safety 

Our customers and families depend on us to operate safely. At all times, safety comes first, for all involved. We believe in zero accidents at all times. Employees have the right and obligation to stop work that is unsafe or being done incorrectly. Therefore employees follow all methods of working, rules and precautions everywhere they work and wear the required Personal Protective Equipment. Loyalty means being ‘fit to work’ and ensuring your team members are as well, by avoiding substances or situations which might negatively influence performance. In order to keep our excellent reputation we act on any unsafe situation, behavior or circumstance which can endanger the health or safety of any person.

2. Respect in all relationships

We all believe that respect is the key to successful and safe (work) relationships. We actively contribute to respectful environments where all cooperate as one team. Therefore each employee is expected to treat all others equally. We will recruit, hire and promote employees solely on the basis of their skills and capabilities which are relevant to the job. Employees avoid all forms of discrimination, such as discrimination based on gender, race, age, disability, sexual orientation, religion, belief, political opinion or social origin. They also refrain from behavior that may harm others, such as verbal or physical violence, harassment and intimidation. Employees should be free to express differing opinions and concerns without having to fear repercussions. Mammoet strictly prohibits any form of retaliation. A special policy on anti-retaliation has been developed in this respect to encourage all employees of Mammoet to feel comfortable speaking up without fear of retaliation.  

3. Gifts, entertainment and our anti-bribery approach

Gifts and entertainment should be modest and appropriate at all times, and used to strengthen business relationships, build goodwill and express gratitude. 'Appropriate' means that they are well-timed, moderate, infrequent and not in excess of your local generally accepted business practices.

Gifts may never put pressure on the recipient to return a favor or influence the integrity of business decisions. The same applies to relations with government officials. This is particularly important as most government officials are not allowed to accept any gift or entertainment at all. In all cases, employees may only offer or accept gifts or entertainment in line with the law and policy of the recipient’s organization as well as our own policy. All forms of improper payment must be avoided.

Charity, sponsorships or commission payments may never be used for the wrong purpose. Further details are described in our gifts and improper payments manual, which provides employees with practical advice on handling situations where something unusual or possibly improper. We do not tolerate any form of bribery.

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4. Conflicts of interests 

Working at a professional organization means that we work and act with objectivity, only in the best interests of Mammoet. We believe that business is business, and there is no place for secret, personal benefits or commercial side activities. Employees are not allowed to use company information, resources or their business position for personal gain. Sometimes your duty towards your employer may conflict with a more personal interest you might have towards family, friends or even yourself. In these situations, employees should communicate in a transparent manner with there colleagues and manager. You are expected to be open and honest and avoid even the appearance of a possible conflict of interest and in such cases, withdraw from the business issue.  

5. Protecting company resources

Each employee is provided with a variety of company resources and is responsible for protecting these against loss, damage, misuse and theft. Resources include vehicles, tools and machines, but also our brands, innovations, intellectual property rights and know how. We use resources in a careful and professional manner. Only for their intended business purpose. In exceptional cases, an authorized manager is the only person allowed to give you permission to use company resources for other purposes.

6. Protecting confidential information 

Employees make sure that all confidential information is preserved and protected in a professional manner. This applies to confidential information of others as well as our own. Confidential information is information that can give a competitive advantage and/or is privacy related. You only reveal our company’s confidential information to anyone outside the company with proper protection. You respect and use confidential information of others (like our competitors) only in so far as you have a legal right to do so.

7. Protecting our ICT 

We can only continue our success when our ICT is correctly used and properly protected by all users. Incorrect use costs not only time and money, but it also creates various risks to employees and our company. To avoid these risks, we have created regulations governing the use of ICT resources and established control measures to ensure that our regulations are observed.

8. Correct information 

We conduct our business in a fair and honest way. We want to make business decisions based on all relevant facts. Therefore we need reliable data. Each employee has a duty to ensure that his/her financial and non-financial documents, records and reports are accurate, complete, consistent and up-to-date. The financial administration and supporting documents must accurately describe and reflect the nature of the underlying transactions. No secret or unregistered accounts, sums of money or assets will be established or held. We do not accept any form of fraudulent behavior like falsifying invoices or other documents, deceiving or misleading people, or helping illegal trade of any kind. Each employee is expected to prevent fraud within our company and is obliged to promptly report any suspicion of fraud or other violation of a criminal law (like theft, fraud, bribery, competition laws and similar offenses).  

 9. Fair competition

We believe in competition based on fair play and a level playing field. The objective of competition law is to ensure fair and active competition between companies. We fully endorse this objective. You conduct all of your activities in a fair and competitive manner, thereby carefully complying with competition laws. Competitors must actively compete and take their own business decisions, not divide up markets, share prices or similar sensitive business information like costs, bids, promotions, allowances, sales, suppliers, and terms and conditions of work. Employees must only use legally allowed sources of competitive information. To give employees a good idea of the rules that are relevant in certain situations, a special competition compliance manual has been issued, which is mandatory for employees in marketing, sales and management positions.

10. Environment

Each employee commits to personally contributing to running our business in an environmentally sound and sustainable manner. We strive to minimize the adverse environmental impact of our processes and services. Together we contribute in this way to sustainable development without reducing the ability of future generations to meet their own needs. These policies and programs are an integrated part of our business. We monitor and report about our sustainability performance annually in a transparent and consistent manner.  

11. Communications with third parties

Our employees ensure that their communication with outside parties is appropriate and accurate and in a manner that avoids damaging the reputation of our company. Employees are particularly careful not to speak to third parties such as the media about projects or work without prior approval. You are careful about writing and posting on any social media and internet site, platform, application, etc. which can be used to share with others such items as information, messages, opinions, photographs and movies. Employees do not speak on behalf of Mammoet with the press or through social media unless they are explicitly authorized to do so. When approached by media, employees refer them to their regional Marketing Communication Advisor. They do not speak with the media, unless they have been designated as a spokesperson.  

12. Trusted business partners 

We want to establish and maintain fair and jointly challenging relationships with reliable business partners who apply business conduct standards consistent with our own. Who contribute to our goals and integrity commitments. Business partner relationships are evaluated consistently, with the objective of continuing improvements in all areas.  

13. Compliance - Laws & regulations and trade restrictions & customs

International trade restrictions prohibit us from engaging in certain business activities in certain countries and with certain persons, organizations and companies. These trade restrictions include prohibitions on interaction with identified terrorist organizations and boycotted persons and companies. International trade controls are designed to protect national and international security. We must also abide by certain special rules for transactions with governments. At Mammoet we all stick to the letter and spirit of the law at all times. We respect the immigration rules, import, export, customs and license restrictions and requirements everywhere we work. We conduct our activities in a fair manner. Before trading with potentially sensitive countries or companies, we double-check to make sure our plan is in compliance with all applicable (inter)national laws and regulations in this regard.  

14. Government investigations & proceedings 

Employees of Mammoet must cooperate with investigations, proceedings or raids from any legitimate local Government. A dawn raid is a surprise visit in which the visitors are legally authorized to enter premises, search for, copy and/or remove documents or other evidence and ask questions. Such raids may be organized by the national competition authorities, the European Commission, or various other governmental bodies. In order to help you in these cases we have drafted a dawn raid manual. This manual provides instructions for different groups of employees who have different tasks in the event of a dawn raid.

15. Following the Mammoet code of conduct 

Managers have additional responsibilities

Of course the Mammoet Code of Conduct also applies to all managers (including our Executive Board). Employees in management positions have increased responsibilities. Managers must implement the Mammoet Code of Conduct and its underlying policies and lead by example. A key responsibility is also creating an open environment so their employees can raise concerns or suspicions without fear of a negative reaction.

How to deal with dilemmas: the mirror test

If you are unsure about whether a course of action is acceptable according to our Code of Conduct and underlying policies you can do the mirror test. Look in the mirror and ask yourself these questions. It will help you to critically evaluate the action that you intend to take: with my family and manager? Do I want to read about it in the newspaper? Do I accept full personal responsibility for this decision?

Raising questions or concerns

We expect each employee to support a culture of openness in which we all feel comfortable raising questions, dilemmas and concerns related in any way to our Code of Conduct. We encourage you to discuss these with your colleagues or manager. If you are aware of a violation of the Mammoet Code of Conduct, you are encouraged to come forward. Also if you only suspect a violation or you only have a worry. If you feel that speaking up and discussing a suspicion with your manager is not reasonably possible, you can choose to report to: your local Legal Advisor; the Human Capital department; or, if these are not easily reachable for you, as a last resort, see the Speak Up procedure for contacting the Alertline, available 24/7/365; if you just want to discuss a topic out of the Mammoet Code of Conduct, please send an email to codeofconduct@Mammoet.com.

No negative effects

Demonstrating our company values, following our Code of Conduct and speaking up, all help to sustain our reputation and success. No employee will suffer if business is turned down in order to follow our Code of Conduct. No employee will suffer if he or she has reported in good faith a suspicion of a violation of our Code of Conduct.

Sanctions

Disregarding or violating the law, our Code of Conduct or any of the underlying policies can have serious consequences for our company and the individuals involved. For example imprisonment, personal liability and/or fines as well as reputational damage. Ignoring a violation can also have serious consequences. Using a third party or other method to bypass the Mammoet Code of Conduct is prohibited. A violation may lead to disciplinary measures, including dismissal.

Paul van Gelder

Working by our values

“Mammoet is a company built on strong values and we have high ethical standards. Yes, our primary focus is creating ongoing value for our customers and growing the business. However, we believe our responsibilities are wider than that. It’s not just about what we do, but how we do it. We have a responsibility to carry out our daily work with integrity, respect, and in full accordance with the law. We pride ourselves on building strong relationships with everyone we work with. These relationships are built on the trust that we will always do the right thing. The code of conduct sets these standards and guides the way we work.” 

Paul van Gelder: Chief Executive Officer

Paul van Gelder

Privacy Statement

Keep it safe. Keep it private!

Do you work with personal information such as names, addresses, photos, bank account numbers or copies of passports? This sort of information is called personal data. And it is very important to keep it private.

Protecting personal data

Mammoet, together with the other SHV Groups, has two key messages about working with personal data:

  • Personal data needs to be well protected. Keep it safe.
  • Personal data can only be shared on a need-to-know basis. Keep it private.

These messages are strongly supported by the Executive Board of Management.

New law 

Why are we providing this information now? Keeping personal data safe and private is becoming more and more important. An increasing number of countries are adopting strict laws on privacy. For example, in Europe a new law will take effect in May 2018: the General Data Protection Regulation (GDPR). 

Transparency 

It is not only new laws that make data protection important. We also take into account that people are more and more aware that companies are processing large quantities of their personal data. They expect transparency. Furthermore, data protection has become more and more complex due to increased cybercrime threats.

Privacy codes 

To ensure we keep personal data safe and private, Mammoet and the other SHV Groups are jointly issuing ‘privacy codes’. They contain guiding principles for everyone who works with personal data. One code refers to the personal data of clients, suppliers and business partners and the other one to employee data.

For more information, please contact the Group Privacy: privacy@mammoet.com 

You can download the privacy statement here

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Mammoet Privacy Statement - Customer data

Updated 22 May 2018

1. Introduction

This is the Mammoet Privacy Statement for customer, supplier and business partner data.  This Privacy Statement provides information on the processing of personal data by Mammoet B.V. and its group companies, hereafter: Mammoet, we or us.

The primary purpose of this Privacy Statement is to be a dynamic resource and business tool so that we can offer our services to you in the best possible way.  We want you to feel secure when visiting our site and are committed to maintaining your privacy when doing so.

This Privacy Statement may be changed over time. The most up-to-date Privacy Statement is published on our website. This Privacy Statement was last changed on 22 May 2018.

2. When does this privacy statement apply?

This Privacy Statement is applicable to the processing by Mammoet of all personal data of its customers, suppliers and business partners and other individuals. This Privacy Statement does not address the processing of personal data of employees in the context of their employment relationship with Mammoet.

3. Who is responsible for your personal data?

Mammoet and/or its group companies are the controllers of the processing of all personal data that fall within the scope of this Privacy Statement. This Privacy Statement indicates what personal data are processed by Mammoet and for what purpose, and to which persons or entities the data will or may be provided. Mammoet may share your personal data with third parties.

4. For which purposes do we process your personal data?

4.1 When you interact with Mammoet (online or offline)

(a)               For answering your questions

(i)                 What does this purpose entail?

If you get in touch with us at info@mammoet.com or via the contact form on one of the Mammoet group websites, we will use your personal data in order to reply to and answer your question.

(ii)               On what legal ground do we process personal data for this purpose?

We process your information for this purpose based on our legitimate interest to adequately answer your questions.

(iii)             Which personal data do we process for this purpose?

For this purpose, we process your name, contact details, your correspondence with Mammoet about your question and all other personal data which are necessary to answer your question.

(iv)             For what period do we retain your personal data for this purpose?

If you have contacted us via the contact form on Mammoet support page or via info@mammoet.com, then your data will be deleted from our systems after the legal retention period.  

(b)               For the development and improvement of products and/or services

(i)                 What does this purpose entail?

We process your personal data in order to assess, analyse and improve our products and (customer) services.  We use aggregated personal data to analyse customer behaviour and to adjust our products and services accordingly.  When you use a Website, enter or search data through this Website; we also process your personal data to compile analytics reports.  We use aggregated personal data to analyse customer behaviour and to adjust our products and services accordingly, to ensure that it is relevant to our customers.  This means that we analyse how often you read our newsletters, how often you visit our Website, which pages you click on and what goods you purchase through our Website.  

Based on the information above, we can make adjustments to our offering, our newsletters or our Website.  We may also adapt our promotions on the basis of our analysis.  We may also perform research into market trends through statistical analysis to evaluate and adapt our products and marketing to new developments, but research results are only reported on an aggregated basis.

(ii)               On what legal ground do we process personal data for this purpose?

We process your information based on our legitimate interest to develop and improve our products and services.

(iii)             Which personal data do we process for this purpose?

For this purpose, we process your contact details such as your address and email address, personal details such as your name and date of birth, payment and credit information, and correspondence with us.  In addition, we process the personal data you entered into a Website or that were generated by the functionalities you used in a Website and the technical data from your device such as its IP-address, the pages you visited on our Websites, your click- and surf behaviour and the length of your session.

(iv)             For what period do we retain your personal data for this purpose?

For this purpose, your personal data will be retained for the legal retention period. After this term, your personal data will be deleted from our systems.

4.2 When you use our Websites

(a)               To deliver you our Website's functionalities and for their technical and functional management

(i)                 What does this purpose entail?

If you use our Website, we process technical data to offer you our Website’s functionalities and to allow our Website's administrators to manage and improve our Website's performance. If you enter data in our Websites, such as a product preference or your location to receive relevant information or functionalities, Mammoet processes this data to provide you with the requested information or functionalities. Further, we process your personal data to allow you to save your data (such as preferences and products) to your saved items and to allow you to share these with others using the sharing options you have configured on your device.

(ii)               On what legal ground do we process personal data for this purpose?

We process personal data for this purpose based on our legitimate interest to offer technically adequately working Websites and to improve our Websites’ performance.

(iii)             Which personal data do we process for this purpose?

For this purpose, we process the personal data you have entered into our Websites or that is generated by the functionalities you have used in our Websites and the technical data from your device such as its IP address, the internet browser you use, the pages you have visited on our Websites, your click- and surf behaviour and the length of your session.

(iv)             How long do we retain your personal data for this purpose?

For this purpose, your personal data will be retained for the legal retention period. After this term, your personal data will be deleted from our systems.

(b)               To allow you to connect with us (eg via social media)

(i)                 What does this purpose entail?

Mammoet is active on social media platforms like Facebook, Twitter, LinkedIn and YouTube. When you contact Mammoet via social media, we process your personal data in order to answer your questions and to respond to your messages.

In addition, when you visit a 'Connect with us' screen on one of our Websites or Apps, you can contact us through a variety of communication channels.  We provide you with our email address, for you to send us your feedback and suggested improvements, as well as our Website, trade website, Twitter, Facebook and YouTube details.  When you click one of the corresponding icons we will refer you to the website or app of the applicable third party, whether this is your email provider or a social media platform.

(ii)               On what legal ground do we process personal data for this purpose?

We process personal data for this purpose based on our legitimate interest to adequately respond to your questions and correctly refer you to our social media pages.

(iii)             Which personal data do we process for this purpose?

For this, we process the communication channel you have chosen to use to connect with us and the personal data you supply to Mammoet.  This includes your (user) name, address, email address and the personal data you have included in your message.  In addition, when you click one of the buttons displayed, the relevant third party might place cookies on your device.

(iv)             How long do we retain your personal data for this purpose?

For this purpose, your personal data will be retained for the legal retention period. After this term, your personal data will be deleted from our systems.

4.3  When you do business with us

(a)               For the assessment and acceptance of a customer, supplier or business partner

(i)                 What does this purpose entail?

When you get in contact with Mammoet, we will process your personal data for assessment and acceptance purposes, for example in order to confirm and verify your identity. Mammoet will further process your personal data for other administrative purposes such as due diligence and screening against publicly available government and/or law enforcement agency sanctions lists.

(ii)               On what legal ground do we process personal data for this purpose?

We process personal data for this purpose because this is necessary for the conclusion of a contract between you and us. Mammoet cannot enter into contracts without obtaining the required information.

(iii)             Which personal data do we process for this purpose?

For this purpose, we process your contact details such as your address and email address, personal details such as your name and date of birth, payment and credit information and details of your correspondence with us.

(iv)             For what period do we retain your personal data for this purpose?

For this purpose, your personal data will be retained for the legal retention period. After this term, your personal data will be deleted from our systems.

(b)               For the conclusion and execution of agreements

(i)                 What does this purpose entail?

When you have purchased a product or service from us as a customer, or when you work together with us as a supplier or business partner, we process your personal data for administrative purposes such as sending invoices and making payments.  We also use your personal data in order to deliver or receive and administer our or your products or services. Mammoet will process your personal data in order to further execute our agreement, including for the delivery of customer services. When you require access to Mammoet's premises, we process your personal data for screening purposes.

(ii)               On what legal ground do we process personal data for this purpose?

We process personal data for this purpose because this is necessary for the conclusion of a contract between you and us. Mammoet cannot enter into contracts without obtaining the required information.

(iii)             Which personal data do we process for this purpose?

For this purpose, we process your contact details such as your address and email address, personal details such as your name and date of birth, payment and credit information, order history and other data stored in our customer, supplier and business partner database.

(iv)             For what period do we retain your personal data for this purpose?

For this purpose, your personal data will be retained for the legal retention period. After this term, your personal data will be deleted from our systems.

(c)                For relationship management and marketing

(i)                 What does this purpose entail?

Mammoet uses the information stored in its customer database to send you suitable offers and newsletters, as well as to provide customer services, perform account management and communicate recalls.  We also use your personal data for the development, execution and analysis of market surveys and marketing strategies.

(ii)               On what legal basis do we process personal data for this purpose?

When sending you newsletters and/or other relationship management and marketing communications, we process personal data based on your consent. In addition, we process personal data for this purpose based on our legitimate interest to improve our marketing strategies.

(iii)             Which personal data do we process for this purpose?

For this purpose, we process your contact details such as your address and email address, personal details such as your name, contact preferences, payment information, order history and correspondence with us.

(iv)             For what period do we retain your personal data for this purpose?

For this purpose, your personal data will be retained for the legal retention period. After this term, your personal data will be deleted from our systems.

(d)               For business process execution and internal management

(i)                 What does this purpose entail?

We process your personal data in the performance and organisation of our business. This includes general management, order management and management of Mammoet assets. Mammoet also processes your personal data for its internal management. We provide central processing facilities in order to work more efficiently. We conduct audits and investigations, implement business controls, and manage and use customer, supplier and business partner directories. Also, we process your personal data for finance and accounting, archiving and insurance purposes, legal and business consulting and in the context of dispute resolution.

(ii)               On what legal ground do we process personal data for this purpose?

We process personal data for this purpose based on our legitimate interest to maintain and improve sound business operations.

(iii)             Which personal data do we process for this purpose?

For this purpose, we process your contact details such as your address and email address, personal details such as your name, payment and credit information, payment and order history, correspondence with Mammoet and data generated during the performance of the agreement between you and Mammoet.

(iv)             For what period do we retain your personal data for this purpose?

For this purpose, your personal data will be retained for the legal retention period. After this term, your personal data will be deleted from our systems.

4.4 Your choices

(a)               If you participate in events or promotions

(i)                 What does this purpose entail?

With your consent, we can send you emails with promotions and invitations to participate in events.  If you choose to participate in one of these activities, we need your personal data to be able to announce and organise these.  In addition, if you participate in any of these activities, we need your personal data to measure the response to events and/or promotions.

(ii)               On what legal ground do we process personal data for this purpose?

We process personal data for this purpose based on your consent. You can withdraw your consent at any time, without this affecting the lawfulness of processing based on consent before withdrawal.

(iii)             Which personal data do we process for this purpose?

For this purpose, we process your name, address, email address and your entries in the relevant event.

(iv)             How long do we retain your personal data for this purpose?

For this purpose, your personal data will be retained for the duration event you participate in.  After this term, the personal data processed for this purpose will be deleted from our systems.

(b)               Only if you have consented to this during your account registration, for sending you relevant information about Mammoet

(i)                 What does this purpose entail?

When you register for an account on our Website, we ask you for your consent to receive personalised newsletters, information about products, services, events and promotions from Mammoet or other Mammoet group companies.  If you consent thereto, we process your personal data to provide you with information you may be interested in based on your account details, our Websites pages you have visited and the data you have entered into our Websites (including your preferences), your online and offline shopping history and your registered use of Mammoet or other Mammoet websites.  We will contact you through email, mail, SMS, social media and any other communication channels you have provided to us.

In this way we learn about your interests and can ensure that we provide you with the information and promotions that are of most interest to you.  We may also ask you for your opinion about our products and services.  If you do not want to receive any more messages or if you want to opt out of receiving or seeing a particular form of communication with us (for example SMS, social media, email or regular mail), just follow the steps in that particular communication or opt out on your account page.

(ii)               On what legal ground do we process personal data for this purpose?

We process personal data for this purpose based on your consent.  You can withdraw your consent at any time, without this affecting the lawfulness of processing based on consent before withdrawal.

(iii)             Which personal data do we process for this purpose?

For this purpose, we process:

  • your name, email address, and physical address;
  • your preferences and interests, such as those that you have actively shared with us, but also those inferred through your registered interactions with Mammoet websites and apps (for which we may use cookies);
  • the links you click on in our emails.

(iv)             How long do we retain your personal data for this purpose?

For this purpose, your personal data will be retained for the legal retention period. After this term, your personal data will be deleted from our systems

5. Cookies

We also collect information through the use of cookies.  Cookies are small files of information which save and retrieve information about your visit to this website – for example, how you entered our site, how you navigated through the site, and what information was of interest to you.

6. Who has access to your personal data?

6.1 Access to your personal data within Mammoet

As a global organisation, data we collect may be transferred internationally throughout Mammoet's worldwide organisation.  Your personal data may be exchanged with the Mammoet group, shareholders and associated companies.  We exchange your data for administrative purposes and so that we can have a complete overview of your contacts and contracts with the Mammoet group.  We may also exchange your data in order to offer you a complete package of services and products.

Mammoet employees are authorised to access personal data only to the extent necessary to serve the applicable purpose and to perform their jobs.

6.2 Access to your personal data by third parties

The following third parties have access to your personal data, where relevant, for the provisioning of their products or services to Mammoet: banks, insurance companies, IT suppliers, accountants, forensic specialists, consultants.

When third parties are given access to your personal data, Mammoet will take the required contractual, technical and organisational measures to ensure that your personal data are only processed to the extent that such processing is necessary. The third parties will only process your personal data in accordance with applicable law.

If your personal data are transferred to a recipient in a country that does not provide an adequate level of protection for personal data Mammoet will take measures to ensure that your personal data are adequately protected, such as entering into EU Standard Contractual Clauses with these third parties.

In other cases, your personal data will not be supplied to third parties, except where required by law.

6.3 The use of your personal data by data processors

When a third party processes your personal data solely following Mammoet instructions, it acts as a data processor.  We enter into an agreement with such a data processor for the processing of personal data.  In this agreement we include obligations to ensure that your personal data are processed by the data processor solely to provide services to us.

7. How are your personal data secured?

Mammoet has taken adequate safeguards to ensure the confidentiality and security of your personal data. Mammoet has implemented appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing.  Examples are IT security policies, staff training and secure servers.

8. Questions or requests for access, correction and removal

You can request access, correction, restriction, portability or removal of the data that Mammoet processes about you at any time by sending a request to: privacy@mammoet.com.

Should you have any questions regarding the processing of your personal data, please contact privacy@mammoet.com.

If you feel that we do not comply with applicable privacy rules you have the right to lodge a complaint with a competent data protection authority.

Should you have any questions regarding the processing of your personal data, please contact privacy@mammoet.com.

 

Anti slavery

Mammoet UK Ltd acknowledges the provisions of the Modern Slavery Act 2015. We do not tolerate modern slavery or human trafficking in our organisation or in our supply chain, and are satisfied from our own due diligence that there is no evidence of any act of this within our organisation.

Our policies on modern slavery and human trafficking 

Our opposition to modern slavery and human trafficking is confirmed in our Anti-Slavery Policy and reflects our commitment to acting ethically and with integrity in all our business relationships. We are committed to implementing and enforcing effective systems and controls to eliminate, as far as possible, the risk of modern slavery and human trafficking taking place anywhere in our business or supply chains.

Due diligence processes

As part of our initiative to identify and mitigate risk:-

  • Undertake a regular review of controls of all our suppliers and an established process of supplier approval.
  • Our supply chain is predominantly UK and EU based and we would expect these entities to have applicable anti-slavery and human trafficking policies and procedures. Where products and services are supplied from outside of these geographical areas, the management and control will be continually monitored.
  • Where possible, we build long standing relationships with our suppliers and customers and make clear our expectations of business behaviour.
  • The business will not forge commercial relationships with any business knowingly involved with slavery or human trafficking.
  • We have systems in place to encourage the reporting of concerns and the protection of whistle blowers.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and in our supply chains we provide information to our employees and training to relevant members of staff. All Directors have been briefed on the subject.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our company’s slavery and human trafficking statement for the current financial year.

Matthew Gent Managing Director Mammoet UK Ltd

 

Matthew Gent

“Mammoet UK supports the government’s efforts in raising awareness about this worldwide issue within the business community. At Mammoet, we believe in transparency and accountability. We have been and remain committed to ensuring modern slavery and human trafficking does not take place anywhere in our business. We also expect the same from our business partners. We are proactively taking steps to prevent this from happening and we will continue to strengthen our ability to identify and mitigate modern slavery risk.”

-  Matthew Gent

Matthew Gent

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