Staff Privacy

Kpler Holding SA and its affiliates (collectively Kpler Group, we or our) take data privacy very seriously and this privacy notice is designed to help you understand how we use your personal information in your capacity as a Kpler Group staff member.

For the purposes of this notice, Kpler Group staff members include: prospective, current or past employees (whether permanent or fixed term); contractors; consultants; workers; officers; volunteers; interns; agency workers; and apprentices employed or engaged by any member of the Kpler Group. We encourage you to read the whole notice.

1 The purpose of this Privacy Notice

2 Your personal information

2.2 What personal information do we collect about you?

In addition to the personal information we collect about you as part of considering you for a Kpler Group staff member role (which will, where appropriate, continue to be processed by us whilst you are a Kpler Group staff member), we may process further personal information about you in order to meet our responsibilities as an employer (where relevant) and to manage our relationship with you as a Kpler Group staff member. This may include, but not limited to, the following information:

• date of birth;

• marital status;

• health and absence related information that we become aware of during the course of your employment. We will not ask you for health related information unless we are required to under applicable law;

• where we are permitted to process such information under applicable law, information relating to: any disabilities you may have; your gender;

• bank account details;

• photographs of you;

• electronic signatures;

• driving licence and/or passport details;

• work eligibility status and arrangements, including visa, work permit and/or residence permit status and information such as whether you require a work visa sponsorship (where applicable);

• location of employment/workplace;

• leave entitlement (including holidays, parental leave, maternity leave, paternity leave, adoption leave);

• pensions data;

• remuneration and benefits, including any remuneration that you may be entitled to when you are unwell or on leave (such as parental pay, including statutory maternity and paternity pay);

• emergency contacts;

• trade union membership (where relevant) so we can process your subscription fee, if you have asked us to;

• occupational health data;

• information related to your salary and pay, pension, share plans and employee benefit options (including, any company car);

• information about your shift pattern, if needed for your role, notably as part of planning and paying you for overtime due;

• information in relation to any complaints that you make;

• data relating to any disciplinary or grievance proceedings in which you are involved;

• data relating to your criminal convictions and offences, where appropriate;

• leaving date and your reason for leaving (where applicable);

• location of employment or workplace;

• data on whistle blowing activities, where applicable;

• other information relating specifically to your status as a Kpler Group staff member; and

• where we utilise an employer of record or similar arrangement in respect of you, details of your employer of record or similar.

Where we operate CCTV, we may also capture your image on CCTV whilst you are on our premises.

We may also create personal information as part of your employment or engagement, such as records of your performance and career development.

We do not sell your information nor make it generally available to others. But we may share your information for a variety of reasons within the Kpler Group and/or with external third parties – as we explain in more detail below.

• The Kpler Group is made up of a number of different entities around the world. Where it is necessary or appropriate for the purposes for which we hold your information, we share your relevant information across our affiliated companies and shall be processed by appropriate Kpler Group personnel. All of our affiliated companies covered by this notice manage your personal information in the manner and to the standards set out in this notice, subject to any local jurisdictional compliance requirements. Details of the affiliated companies to which this notice applies are set out in paragraph 1.1 above. All internal processing activities within the Kpler Group with respect to your personal information is subject to security measures and internal controls and is restricted to what is legally permissible, relevant and proportionate for the relevant legitimate purpose of the processing.

• Your personal information may be disclosed to other organisations as required by law – for example, the provision of salary and tax data to governmental authorities such as tax authorities, for crime prevention, investigation or detection purposes or in order to protect your vital interests.

• Where necessary we may also share your information with:

o family, associates and representatives of the person whose personal information we are processing;

o current, past or prospective employers;

o external companies which provide benefits, such as health cover and life assurance, where applicable. These external companies will sometimes need information about your health in order to provide these benefits, and the only basis for this processing might be consent. You are not obliged to give consent, but without access to your health information these external companies might be unable to provide the benefit to you. Please be assured that we will not provide health-related information about you to these external companies;

o customers, who need your personal information (such as contact details) where this is necessary to deliver the services to them;

o suppliers and service providers;

o financial organisations;

o certification bodies, industry bodies or associations, or government bodies which have dealings with us in connection with our business operations;

o auditors;

o police forces and security organisations;

o courts and tribunals;

o legal representatives;

o local and central government and their agencies – particularly those involved with tax and the right to work;

o consultants and professional advisers – for example, external companies which provide us with professional HR services, such as lawyers and employment advisers;

o trade union and staff associations, where applicable;

o survey and research organisations;

o press and the media;

o landlords;

o shareholders;

o we use the services of various external organisations to help us run our business operations efficiently, particularly in relation to our HR and IT systems. Some of these services, such as email hosting, data backups and payroll service providers, involve the service provider holding and using your personal information. In each case where we share your information with one of our service providers, the service provider is required to keep it safe and secure. They are also not permitted to use your information for their own purposes;

o where we utilise an employer of record or similar arrangement in respect of you, your employer of record or similar; and

o if we sell all or any part of our business, then your information will also be transferred to the new owner to enable the continuation of the business.

In all cases we only share your personal information in accordance with applicable law. Where we share your personal information with a third party, we have controls in place to ensure your personal information is properly protected and we only provide the minimal information necessary for that purpose.

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4 Other important things you should know

5 Your rights and contacting us

Kpler Holding SA and its affiliates (collectively Kpler Group, we or our) take data privacy very seriously and this privacy notice is designed to help you understand how we use your personal information in your capacity as a Kpler Group staff member.

For the purposes of this notice, Kpler Group staff members include: prospective, current or past employees; contractors; consultants; workers; officers; volunteers; interns; agency workers; and apprentices employed or engaged by any member of the Kpler Group. We encourage you to read the whole notice.

1. The purpose of this privacy notice

1.1 Identity

We are the Kpler Group. We are a group of organisations that, together, form a leading provider of data, analytics and other products, services and solutions for commodity markets across the globe, including an online suite of intelligence and transparency tools that allow users to monitor the energy market value chain.

This privacy notice applies to each of the organisations that form part of the Kpler Group. Click here to find an up-to-date list of the organisations that make up the Kpler Group.

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1.2 This privacy notice

This is our staff privacy notice that applies across our business. It is designed to help you understand how we
use your personal information in your capacity as a Kpler Group staff member.

In addition to the information in this privacy notice, from time to time you may be given further information about the uses of your personal information as a Kpler Group staff member.

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1.3 Updating this privacy notice

This notice will be made available on our intranet, which is known as Kpler Hub, and may be updated from
time to time at Kpler Group’s discretion. This version is dated July 2022.

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1.4 What is personal information?

Personal information is information that relates to you or allows us to identify you. It may include your name but it may also be other information such as your date of birth, nationality and gender which when combined identify you. This information may be collected in a variety of ways, including electronically, in paper form, by telephone or in person.

There are different types of personal information. The most important types for you to know about are:

Special categories of personal information – these categories of personal information often have additional protection under data protection laws around the world. These categories include information about your health, racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership, your genetic data and biometric data, and information concerning your sex life or sexual orientation.
Criminal convictions information – this is information relating to your criminal convictions and offences. Local data protection laws may restrict the way in which we can use this information when compared to, for example, your name and address.

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1.5 Our responsibility to you

We process your personal information in our capacity as a controller. This means that (i) we decide the purposes for which, and the manner in which, your personal information is used by us; and (ii) we are responsible for ensuring that we comply with relevant data protection laws when processing your personal information.

2. Your personal information

2.1 Why are we collecting personal information about you?

We only collect personal information about you in connection with your (actual or prospective) employment or engagement as a Kpler Group staff member and the running of our business more generally.

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2.2 What personal information do we collect about you?

The types of information we process about you may include:

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2.2.1 Prospective staff members

The types of information we process about you may include:

name, including your first, middle and last names and any preferred or other names;
title;
address;
telephone, including home, mobile and/or work contact numbers;
email address(es);
details of your secondary and/or tertiary education;
professional qualifications and other information about your background experience and skillset;
statement in support of your application;
details within your submitted Curriculum Vitae (CV);
details of your right to work in a country or territory where we are located and your immigration status (where applicable) – for example, whether you hold a work permit;
for some positions, data relating to your criminal convictions and offences; and
information about your current employment and your prior employment history, including:

name and address of employer(s);
address;
job title;
start and end dates for your employment;
salary; and
your availability to start work, including your notice period (for your current position, if any).

In addition, we may contact your referees as provided in your application to confirm the employment
information that you provide.

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2.2.2 Actual staff members

date of birth;
marital status;
health and absence related information that we become aware of during the course of your employment.
We will not ask you for health related information unless we are required to under applicable law;
bank account details;
driving licence and/or passport details;
work eligibility status and arrangements, including visa, work permit and/or residence permit status and information such as whether you require a work visa sponsorship (where applicable);
location of employment/workplace;
leave entitlement (including holidays, parental leave, maternity leave, paternity leave, adoption
leave);
pensions data;
remuneration and benefits, including any remuneration that you may be entitled to when you are unwell or on leave (such as parental pay, including statutory maternity and paternity pay);
emergency contacts;
trade union membership (where relevant);
occupational health data;
information in relation to any complaints that you make;
data relating to performance and reviews;
data relating to any disciplinary or grievance proceedings in which you are involved;
data relating to your criminal convictions and offences, where appropriate;
leaving date and your reason for leaving (where applicable);
location of employment or workplace;
other information relating specifically to your status as a Kpler Group staff member;
where we are permitted to process such information under applicable law, information relating to: any disabilities you may have; your gender; and your religious beliefs; and
where we utilise an employer of record or similar arrangement in respect of you, details of your employer of record or similar.

Where we operate CCTV, we may also capture your image on CCTV whilst you are on our premises.

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2.3 Where do we collect your personal information from?

We collect your personal information from various sources, including:

you;
where you are a prospective Kpler Group staff member, your current or any previous employer;
recruitment agencies and head-hunters;
business and professional social media networking platforms such as LinkedIn;
other members of staff – for example, where a candidate for a position is referred to us by one of our existing staff members;
business partners;
where we utilise an employer of record or similar arrangement in respect of you, your employer of
record or similar; and
government agencies, regulators, compliance services, credit reference agencies and background check providers – for example, to validate or obtain information with respect to your immigration or right to work status or to confirm whether or not you hold any criminal convictions.

Examples of the types of personal information we may receive from third parties include: CVs; details of your right to work in a country or territory and your immigration status (where applicable); and other information in connection with your activities as a Kpler Group staff member. In certain circumstances, we may receive special category personal information or criminal convictions data from third parties.

Throughout the period of your employment or engagement, we will collect additional personal information in the course of your work-related activities.

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3. Our use of your personal information

3.1 How do we use your personal information?

In this section we set out in more detail:

the main purposes for which we use your personal information; and
the legal bases upon which we are using your personal information

Purpose

Legal basis

To consider you for a Kpler Group staff member role

We will use your personal information to:

process your application for a position within our business;
assess your suitability for a particular role or task and to decide whether to engage you; and
communicate with you about your application and the application process.

In addition, for certain positions, the information processed may also include criminal convictions data and we may require criminal records check to be carried out as part of the assessment of suitability, which will provide us with details of both unspent convictions and relevant spent convictions. You will be notified prior to the processing if this is a requirement of the role for which you have applied.

For all personal information – performance of a contract.

The processing of your personal information may be necessary in relation to the contract we will enter into with you, where we choose to employ or engage you as a Kpler Group staff member.

For all information – legitimate interests.

We have a legitimate interest in using your personal information to decide whether or not we wish to employ or engage you as a Kpler Group staff member– for example, we have a legitimate interest in using your personal information to evaluate whether you have the necessary skills, qualifications and experience to carry out a role we are recruiting for.

For special category personal information – equality of opportunity or treatment.

We process special category personal information in order to monitor equality of opportunity/treatment.

For special category personal information –employment law obligations.

We process special category personal information where this is necessary so that we can meet our obligations in the field of employment law.

For criminal convictions data – employment law obligations.

We will only process criminal convictions information where this is necessary so that we can meet our obligations in the field of employment law.

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To manage our relationship with you as a Kpler Group staff member

We will use your personal information to:

fulfil our obligations under our contract with you;
carry out our obligations in relation to pay and salary review and other remuneration and benefits;
provide and administer benefits (including pension, voluntary healthcare schemes, salary sacrifice schemes and others) that we offer and that apply to you;
support your training, health, safety and welfare requirements, including to make any necessary arrangements or adjustments to the workplace in the case of disability;
undertake performance appraisals and reviews;
undertake talent, performance and succession planning activities;

carry out any necessary investigations in respect of, disciplinary matters or grievances in relation to you or another person;
provide you with access to relevant systems to undertake your role and manage your use of facilities;
communicate with you – for example, in the form of e-mails – in order to keep you informed about important developments within our businesses and seminars and events relevant to your role with us;
maintain sickness and other absence records;

monitor compliance by you with our policies and your other contractual and legal obligations;

monitor your use of our networks to protect the security and integrity of our IT network and information and electronic communications systems; and

provide references and information to futureemployers.

We may process special category personal information – for example, data relating to health in order to make reasonable adjustments for disabilities and to provide relevant support to staff members with ill health.

For all personal information – performance of a contract.

The processing of your personal information may be necessary in relation to the contract we have entered into with you as a Kpler Group staff member.

For all personal information – compliance with a legal obligation.

In this context we will often process personal information in order to comply with our legalobligations – for example, in respect of tax, sick pay orparental leave.

For all personal information – vital interests.

In certain circumstances, your personal informationmay be processed by us and transferred to theemergency services where this is required to protectyour vital interests.

For all personal information – legitimate interests.

There are circumstances in which we may rely on our legitimate interests or the legitimate interests of a third party when processing your personal in formation. In particular, if we provide a reference to a future employer on your behalf, we will generally rely on the legitimate interests of that employer.

For special category personal information –employment law obligations.

We may process certain special category personal information where this is necessary so that we can meet our obligations in the field of employment law.

For special category personal information –occupational health purposes.

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We may process special category personal information, in particular health information, in an occupational health context.

For special category personal information – vital interests.

We may process your special category personal information transfer it to the emergency services where this is required to protect your vital interests.

For special category personal information – legal claims.

We may also process your special category personal information where this is necessary for the establishment, exercise or defence of legal claims.

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Internal and statutory reporting, audit and other compliance with our legal obligations – including compliance with health and safety law and monitoring equality of opportunity or treatment, employee wellbeing and diversity and inclusion

We may use your personal information to:

comply with our legal obligations, including our health and safety obligations;
produce statistics and research for internal and statutory reporting purposes;
manage our accounts and records; and
monitor our compliance with our responsibilities under equalities legislation and carry out employee surveys (or similar) to help us improve our working practices and deliver our commitment of creating a diverse and inclusive working environment where our staff can thrive – for example, through the conduct of diversity and inclusion surveys.

This may include the processing of special category personal information – for example, information relating to diversity and inclusion.

For all personal information – compliance with a legal obligation.

Much of our processing of your personal information in this context will be in order to comply with our legal obligations – for example, health and safety legislation and equal opportunities monitoring.

For all personal information – legitimate interests.
In these circumstances we may rely on our legitimate

interests when processing your personal information.

For all personal data – consent.

We may rely on your consent in certain circumstances when processing your personal information for these purposes.

For special category personal information – equality of opportunity or treatment.

We process certain types of special category personal information in order to monitor equality of opportunity/treatment.

For special category personal information –employment law obligations.

We may also process certain special category personal information where this is necessary so that we can meet our obligations in the field of employment law.

The provision of commercial services to third parties

We may, in certain circumstances, process your personal information when we provide our services to customers and you are involved in the provision of those services.
This may include monitoring support calls between Kpler Group staff members and our customers for the purpose of improving the quality of the support services provided to our customers.

For all personal information – legitimate interests.

In these circumstances we may rely on our legitimate interests when processing your personal information.

Identification and security, including information security

Where required by applicable law, or where it is necessary in order for us to comply with our obligations under applicable law, we may use geo-tracking of general IP addresses and/or API usage tracking to enable us to determine the geographic region in which our staff members are based.

For all personal information – legitimate interests.

In these circumstances we will generally rely on our legitimate interests in maintaining a secure environment for staff members and in protecting ourIT systems.

For all personal information – compliance with a legal obligation.

Much of our processing of your personal information in this context will be in order to comply with our legal obligations.

Marketing/publicity purposes

We may take photographs or videos of you during your employment or engagement, including where you attend events organised by us or by a third party in your capacity as a Kpler Group employee.These images will generally be used in our marketing/publicity materials.
Your personal information may also be processed by us in a social media context – for example, where we publish an interview with you, profile about you or information about your work on our website and social media platforms, or share photographs or other images of you. This will generally be for our marketing/publicity purposes.

For all personal information – legitimate interests.

When using your personal information for marketing or publicity purposes, we will generally rely on our legitimate interests in promoting our business, including our services, market intelligence reports and our events and seminars, our other activities and our overall aims and objectives.

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3.2 Provision of information

Please note that where the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract, and you do not provide us with the personal information required, we may:

not be able to process your application;
not be able to enter into, or perform an existing, contract of employment or engagement with you;

be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

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3.3 Consent

We do not generally process your personal information based on your consent as we can usually rely on another legal basis. If we process your personal information based on your consent, we will inform you of this before we start the processing and you will have the right to withdraw your consent at any time.
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. Where your withdrawal of consent means that we are unable to do something that we have

3.4 Do we share your information with anyone else?

We do not sell your information nor make it generally available to others. But we do share your information
in the following circumstances.

Your personal information may be disclosed to other organisations as required by law – for example, the provision of salary and tax data to governmental authorities such as tax authorities, for crime prevention, investigation or detection purposes or in order to protect your vital interests.

The Kpler Group is made up of a number of different entities around the world. Where it is necessary or appropriate for the purposes for which we hold your information, we share your relevant information across our affiliated companies. All of our affiliated companies covered by this notice manage your personal information in the manner and to the standards set out in this notice, subject to any local jurisdictional compliance requirements. Details of the affiliated companies to which this notice applies are set out in paragraph 1.1 above.
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Where necessary we may also share your information with:

family, associates and representatives of the person whose personal information we are processing;
current, past or prospective employers;
external companies which provide benefits, such as health cover and life assurance, whereapplicable. These external companies will sometimes need information about your health in order toprovide these benefits, and the only basis for this processing might be consent. You are not obligedto give consent, but without access to your health information these external companies might beunable to provide the benefit to you. Please be assured that we will not provide health-relatedinformation about you to these external companies;
suppliers and service providers;
financial organisations;
certification bodies, industry bodies or associations, or government bodies which have dealings withus in connection with our business operations;
auditors;
police forces and security organisations;
courts and tribunals;
legal representatives;
local and central government and their agencies – particularly those involved with tax and the rightto work;
consultants and professional advisers – for example, external companies which provide us withprofessional HR services, such as lawyers and employment advisers;
trade union and staff associations, where applicable;
survey and research organisations;
press and the media;
landlords;
shareholders;
we use the services of various external organisations to help us run our business operations efficiently, particularly in relation to our HR and IT systems. Some of these services, such as email hosting, data backups and payroll service providers, involve the service provider holding and using your personal information. In each case where we share your information with one of our service providers, the service provider is required to keep it safe and secure. They are also not permitted to use your information for their own purposes;
where we utilise an employer of record or similar arrangement in respect of you, your employer of record or similar; and
if we sell all or any part of our business, then your information will also be transferred to the new owner to enable the continuation of the business.

4 Other important things you should know

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4.1 Keeping your personal information safe
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We take security issues seriously. We implement appropriate steps to help maintain the security of our information systems and processes and prevent the accidental destruction, loss or unauthorised disclosure of the personal information we process.

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4.2 Profiling and automated decision making‍

We do not use profiling (where an electronic system uses personal information to try and predict something about you) or automated decision making (where an electronic system uses personal information to make a decision about you without human intervention).

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4.3 How long do we keep your personal information?‍

We do not keep your personal information forever. We keep your personal information for no longer than
necessary and, in any event, no longer than we are permitted to under applicable law.

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4.4 Cross border transfers of your personal information‍

We are a global business that operates, and provides products, services and solutions to customers located, in many different countries around the world.The global nature of our business means that your personal information may well be transferred across national boundaries, including, potentially, to countries that do not require organisations by law to look after your personal information in the way in which you have come to expect in your own country.

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Where we transfer your personal information across national boundaries, we will protect your personal information by ensuring that those transfers are made in compliance with all relevant data protection laws.
If you would like further details of how your personal information is protected when transferred from one country to another, then please email us at dataprotection@kpler.com.

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4.5 Local differences

‍Whilst this privacy notice describes the data protection practices adopted by us generally across the world in relation to Kpler Group staff members, local data protection laws may vary and our operations in some countries may mean that we are subject to different, or additional, local data protection requirements.

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We will inform you if our data protection practices in any country/state differ from those set out in the rest of the notice, and if there is any additional information that we are obliged to tell you in order to comply with local data protection law in that country/state. In such circumstances, if any of these country/state specific privacy practices and additional statements are relevant to you because of the way in which you engage with us as a Kpler Group staff member and there is a conflict between those practices or statements and the information set out elsewhere in this notice, then the country/state specific practices and statements will take precedence.

5 Your rights

5.1 Contacting us and your rights

‍If you have any questions in relation to our use of your personal information, please email us at dataprotection@kpler.com.

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Under certain conditions, you may have the right to require us to:

provide you with further details on the use we make of your personal information;
provide you with a copy of the personal information we hold about you;
update any inaccuracies in the personal information we hold about you;
delete any of your personal information that we no longer have a lawful ground to use;
where processing is based on consent, stop that particular processing by withdrawing your consent;
object to any processing based on our legitimate interests unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;
restrict how we use your personal information whilst a complaint is being investigated; and/or
transfer your personal information to a third party in a standardised machine-readable format.

In certain circumstances, we may need to restrict your rights in order to safeguard the public interest (for example, the prevention or detection of crime) and our interests (for, example the maintenance of legal privilege).
We are obliged to keep your personal information accurate and up to date. Please help us to do this by advising us of any changes to your personal information.

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5.2 Your right to complain

‍If you are not satisfied with our use of your personal information or our response to any request by you to exercise your rights, or if you think that we have breached any relevant data protection laws, then you have the right to complain to the authority that supervises our processing of your personal information or, where you are based in the EU, the data protection authority in your country.
If you are unsure of the authority that supervises our processing of your personal information then please email us at dataprotection@kpler.com.

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information

Kpler Global Staff Privacy Notice

1 The purpose of this Privacy Notice

2 Your personal information

2.2 What personal information do we collect about you?

4 Other important things you should know

5 Your rights and contacting us

1. The purpose of this privacy notice

1.1 Identity

1.2 This privacy notice

1.3 Updating this privacy notice

1.4 What is personal information?

1.5 Our responsibility to you

2. Your personal information

3. Our use of your personal information

Purpose

Legal basis