Main Sustainable development Management and ethics

Management and ethics

Corporate Codes

Interpipe is a large international company that strives to ensure compliance with the principles of transparency in business conduct, as well as respect for employees and partners.

Interpipe has developed and adopted the appropriate corporate codes and monitors the observance of their principles at all enterprises of the Company.

Code of Ethics

The main internal set of rules, principles and values of Interpipe.

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Responsible Purchasing Charter

A set of rules and principles for responsible business conduct.

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Equality, Diversity and Inclusion Charter

The principles coincide with the values and principles of the Company when hiring employees.

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Human Rights Policy

The policy clearly formulates the fundamental elements of Interpipe's approach and how we fulfill our commitment to respect human rights.

Compliance Program

The program is used for the purpose of generalization, transparency and compliance by all Interpipe employees with the provisions of corporate codes and policies.

Interpipe Information Security

Interpipe is responsible for the data protection and security of the company, its employees, customers and partners. For this purpose, each enterprise of the company has adopted a policy for the protection of personal data and information security. The document ensures the protection of personal and confidential information of personnel and partners or their representatives. The company undertakes not to disclose information without the prior consent of the person concerned, to protect information from loss or disclosure, and to store the data no longer than necessary and destroy it accordingly.

Data protection and information security measures

To ensure the confidentiality of any information held by Interpipe, the company conducts internal (monthly) and external audits to assess the risks of data leakage with a total duration of 45 days a year. On average, as a result of the audit, about 30 problems and / or weaknesses are identified, which are eliminated in full. Corrective measures for detected faults include replacing or updating the antivirus system, eliminating hardware and software vulnerabilities.

The process of collecting permits for the processing of personal data in Interpipe is completely open and transparent. Each Interpie employee must sign a consent to the processing of personal data when applying for a job. All clients and partners of the company also give their consent while signing contracts. In addition, all partners providing information services to the company conclude a non-disclosure agreement (NDA) with Interpipe.

Interpipe has a password policy that applies to all enterprises of the company, as well as a procedure for backing up and restoring data. Every Interpipe employee gets acquainted with the password policy and information security memo during hiring. To ensure a high level of protection, the company uses access to confidential information through certificates with a limited validity period.

A separate area of minimizing the risks of Interpipe data leakage is the implementation of approved anti-phishing measures, namely the Interpipe Cybersecurity project, which is aimed at preventing users from receiving phishing emails. Additionally, the Company has an automatic anti-phishing system that analyzes incoming mail of all employees. In addition, the company raises employee awareness of phishing emails and methods of detecting them by regularly mailing memorials to corporate mail.

A reserve remote data center (RDC) was built in 2023 to increase system reliability and ensure disaster recovery readiness. In addition, a mobile device management system was implemented to ensure control and security of corporate data on employee devices.

In order to effectively assess the risks of data leakage, protect information and timely detect and respond to data leakage cases, Interpipe constantly communicates with customers, IT solution providers and other partners.

Data protection and information security training

Interpipe employees receive training on how to work safely with Office 365 products, as well as training on information security policies and procedures. As of the end of 2023:

all managers and external partners of Interpipe are familiar with the policies and procedures for the protection of information,
40% of senior and mid-level executives and 25% of other employees in the company have received information security training in Microsoft Teams,
11 webinars were held on the issues of secure work with Office 365 products,
employees of the Information Security and Information Technology services attended additional specialized seminars in the field of Information Security.

Violation notification procedure

For prompt notification of information leakage and filing data protection complaints, the company operates a specialized Alert Line of the Economic Security Service for information leakage and the Information Security Service. Employees of the company and external contractors contact the hotline and specialized mail antifraud@interpipe.biz every year. In particular, there were no substantiated complaints about violation of confidentiality and loss of customer data in the recent years. Interpipe considers, processes and responds accordingly to each request.

The company regularly informs employees and external contractors about the procedure for notifying the relevant services of the company about the facts of information leakage. Interpipe places contacts and mail of hotlines at stands, corporate newspapers, regularly sends reminders by corporate mail and publishes messages in corporate chat bots Viber and Telegram. Messages provided to any of the hotlines are processed promptly and in full.

Personal Data Protection Policy

Dnipro 31.05.2019

PERSONAL DATA PROTECTION POLICY OF INTERPIPE UKRAINE, LLC

Introduction

Interpipe respects the privacy of its partners, clients, employees and online visitors and complies with applicable laws for the protection of such privacy, including, without limitation, the European Union General Data Protection Regulation ("GDPR") and other applicable regulations.

Definitions

“BENEFICIARY” – means an owner of the Personal Data or a user of any of Interpipe’s web-sites or related services.

“Interpipe” – means each and every company from the list [linked or below] or all of them together as a Group:

Interpipe Ukraine LLC, represented at the following sources:

Main website
http://www.interpipe.biz
Informational websites with brief pieces of news
http://blog.interpipe.biz/ http://blog.klw.biz/
Landing page for hiring
http://work.interpipe.biz/
Interpipe TechFest website
http://techfest.interpipe.biz
Purchasing website
https://tender.interpipe.biz/
Interpipe NTRP
http://ntrp.interpipe.biz
Interpipe Niko Tube
http://nikotube.interpipe.biz/
Interpipe NMPP
http://nmpp.interpipe.biz
Interpipe Steel
http://www.interpipesteel.biz
Dneprosteel Energo
http://dse.interpipe.biz
Interpipe Vtormet
http://vtorm.interpipe.biz
Interpipe Middle East
http://me.interpipe.biz/
North American Interpipe
http://http://na.interpipe.biz
Interpipe Europe
http://eu.interpipe.biz
Interpipe Unified Medical Care Center
http://med.interpipe.biz/

“Personal Data” means any information that can either itself identify BENEFICIARY as an individual ("Personally Identifying Information") or that can be connected to the BENEFICIARY indirectly by linking it to Personally Identifying Information.

Interpipe also processes anonymous data, aggregated or not, to analyze and produce statistics related to the usage patterns and demographics of online-visitors as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. Interpipe may share such anonymous data, aggregated or not, with third parties.

Why Interpipe сollects and processes Personal Data

Interpipe collects and processes Personal Data based on the following reasons:

where it is necessary for the performance of the agreements with Interpipe’s partners/clients to comply with the local legislation;
where it is necessary for compliance with legal obligations that Interpipe is subject to (e.g. obligations to keep certain information under tax laws and regulations);
where it is necessary for the purposes of the legitimate and legal interests of Interpipe or a third party, except where such interests are overridden by Beneficiary’s prevailing legitimate interests and rights; or
where the Beneficiary have given consent to it.

These reasons for collecting and processing Personal Data determine and limit what Personal Data Interpipe collects and how it is used (section 3), how long it is stored (section 4), who has access to it (section 5) and what rights and other control mechanisms are available to the data Beneficiary (section 6).

What Personal Data Interpipe collects and processes

3.1. Online information [Global IP Address]

When an online visitor enters one of Interpipe’s web-sites for the first time, the servers log the global IP address, which is a number that is automatically assigned to the network visitor’s computer is part of. The visitor is not required to set up an account, choose a user name and/or a password or provide any other Personal Data.

There is also another way for Interpipe to collect and process Beneficiary’s Personal Data online - via special form whenever any of the Beneficiaries decides to submit his (hers) data via the platforms described in the Definition chapter to be able to participate in Suppliers’ Tenders, purchase Interpipe’s products or participate in PR/HR activities.

Personal Data collected online may include, but is not limited to, browser and device information, interactions with our web-pages and sites’ usage data.

3.2. Other Data

Interpipe will collect and process Personal Data whenever it is explicitly provided to us or sent as part of regular business communication with our employees or agents, or when Beneficiary provides feedback or other user generated content. This data includes:

Information that Beneficiary post, comment or follow in any of our web-pages (including, but not limited to FB, Twitter, Instragram, else);
Information sent in emails;
Information Beneficiary provides when Beneficiary request information or support from us or purchase Products and Services from us, including information necessary to process orders with the relevant payment methods or shipping providers/other kind of agents;
Information provided by Beneficiary when Beneficiary wants to sell Products and Services to us, including but not limited to participation in tenders or other activities arranged by Interpipe, or responding to surveys, including Beneficiary’s contact details.

3.3. Personal Data required for employment

In order to:

evaluate any possible candidate for employment;
make and offer for employment;
employ a person to any of Interpipe’s subsidiaries,

any Beneficiary may be requested to provide curriculum vitae and copies of other supporting documents which will contain Personal Data to Interpipe. This information and/or documents will be processed and stored as per Interpipe’s subsidiary local laws and regulations requirements.

3.4. Tracking Data and Cookies

We and/or some of our partners may use "Cookies", which are text files placed on Beneficiary’s computer, to help us analyze how many users and from which region/Country are visiting our corporate webpage(s) with a purpose to improve the webpage and/or its functionality, analytics and marketing. These days one of the standard things on the internet is the use of cookies, because cookies are the part of the HTTP (HyperText Transfer Protocol). But regardless of the fact that most web browsers automatically accept cookies, Beneficiary are the one to decide whether to accept it or not. Any browser settings may be adjusted to prevent the reception of cookies, or to provide notification whenever a cookie is sent to Beneficiary. The use of cookies may also be turned off completely via selecting the appropriate settings on the browser. The management of the use of cookies for each browser is usually detailed on its help page. However, if Beneficiary turns off the cookies, Beneficiary may not be able to access the full functionality of our webpages.

When Beneficiary visit any of our services, our servers log Beneficiary’s global IP address, which is a number that is automatically assigned to the network Beneficiary’s computer is part of.

3.5. Google Analytics

Interpipe’s websites use Google Analytics, which is a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on visitors' computers, to help the website operators analyze how visitors use the site. The information generated by the cookie about the visitors' use of the website will generally be transmitted to and stored by Google on servers in the United States.

On Interpipe’s websites, IP anonymization has been activated. The IP addresses of users visiting webpages of Interpipe will be shortened. Only in exceptional cases will a complete IP address be transferred to a Google server in the United States and shortened there. On behalf of the website operator, Google will use this information for the purpose of evaluating the website for its users, in order to compile reports on website activity, and to provide other services relating to website activity and internet usage for website operators.

Google will not associate the IP address transferred in the context of Google Analytics with any other data held by Google. Beneficiary may refuse the use of cookies by selecting the appropriate settings on Beneficiary’s browser. However, please note that in this case Beneficiary may not be able to use the full functionality of this website.

Furthermore, users can prevent the collection of data about their use of the website (including their IP address) generated by the cookie, and the processing of data by Google, by downloading and installing the browser plug-in through the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

3.6. Content Recommendations

We may process information collected under this section 3 so that content, products and services shown on the pages of the Interpipe can be improved to meet our clients’ needs. This is done to improve our clients’ experience.

How Long is the Data stored

The collected information will be only stored as long as necessary for the purposes for which the information is collected and processed. In case any applicable legislation provides for longer storage and retention period — we will pursue the law requirements. After that Beneficiary’s Personal Data will be deleted, blocked or anonymized, as provided by applicable law.

However:

If a person exercises a right to object the processing of the Personal Data, we will review an objection and delete any Personal Data that Interpipe or any of its partners has collected and processed without undue delay, unless the opposite is required by the applicable law.
If a person withdraw the consent on which the Personal Data of such person is processed, Interpipe will delete any Personal Data without undue delay to the extent that the collection and processing of the Personal Data was based on such withdrawn consent.

Who Has Access to Data

5.1. Interpipe and its subsidiaries may share Beneficiary’s collected Personal Data with each other to achieve the purposes mentioned in section 2 of this Policy.

5.2. Interpipe may also share collected Personal Data with its third party providers. In such case any Personal Data will be used in accordance with this Policy and only as far as this is necessary for performing required services.

5.3. Interpipe may release Personal Data to comply with court orders or laws and regulations that require us to disclose such information.

Beneficiary’s Rights and Control Mechanisms

The data protection laws and regulations of the European Union and other countries grant their citizens and visitors certain rights in relation to their Personal Data.

As a resident (or a visitor, whose Personal Data is being processed while Beneficiary are in the European Union, in certain cases) of the European Union Beneficiary has the following rights in relation to the Personal Data:

6.1. Right of Access

Beneficiary has the right to access his/hers Personal Data, i.e. the right to require free of charge (i) information whether such Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained

6.2. Right to Rectification

If Interpipe processes Beneficiary’s Personal Data, Beneficiary have the right to obtain from Interpipe, without undue delay, the rectification of inaccurate Personal Data. Taking into account the purposes of the processing, the Beneficiary shall have the right to have incomplete personal data completed, including, but not limited to, by means of providing a supplementary statement.

6.3. Right to Erasure

Beneficiary has the right to obtain deletion of Personal Data concerning him/her if the reason why Interpipe collected such Personal Data does not exist anymore or if there is legal ground for its erasure. Beneficiary can request the full deletion of his/hers Personal Data via request to the Data Protection Officer of Interpipe.

6.4 Right to Object

When the processing of Beneficiary’s Personal Data is based on Interpipe’s legitimate interests according to Article 6(1)(f) of the GDPR / section 2 of this Policy, Beneficiary have the right to object to this processing. If Beneficiary objects Interpipe will no longer process his/hers Personal Data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular if the data is necessary for the establishment, exercise or defense of legal claims.

Beneficiary also has the right to file a complaint to a supervisory authority.

6.5 Right to restriction of processing of Beneficiary’s Personal Data

Beneficiary has the right to obtain restriction of processing of his/hers Personal Data under the conditions set out in article 18 of the GDPR.

6.6 Right to Personal Data portability

Beneficiary has the right to receive his/hers Personal Data in a structured, commonly used and machine-readable format and has the right to transmit that data to another controller under the conditions set out in article 20 of the GDPR.

Contact Info

Beneficiary can contact Interpipe's data protection officer at the address below.

Interpipe

Att. Data Protection officer

address: 01032. Saksaganskogo str., 36b, office 21, Kyiv, Ukraine

Other regulations

Being a responsible and law abiding company Interpipe also complies with all local applicable laws and regulations in all jurisdictions of its business. If Beneficiary requires any specific clarification – he/she can contact our DPO for that matter.

Anti-corruption policy

Interpipe's policy to combat bribery, abuse of office, and misappropriation is intended to ensure transparent cooperation at all production assets of the company.

Today, the fight against bribery, abuse of office, and misappropriation has become an integral part of Interpipe's corporate culture. Economic offenses in any form always harm both the operation and reputation of any company and contribute to the development of corruption. The policy was developed by the Interpipe’s Economic Security Service. It sets goals and objectives for the company in the field of countering bribery, abuse of office, and misappropriation. This is a document of the company-wide importance, and its effect extends to all companies and industrial assets of Interpipe.

This policy applies to all cases or suspicions of the above offenses, the commitment of which involve both employees of the company and consultants, suppliers of goods and services, and employees of contractors, who collaborate with Interpipe.

Cases of such actions are investigated and brought to their logical conclusion, including, if necessary, the filing of lawsuits and instituting administrative actions or criminal prosecution. During the conduct of investigations, the length of service, position of the suspects, and their relationship with the company are not taken into consideration.

Provisions of this document apply to all employees of the company and are mandatory for use in their activities by managers of all enterprises and operational divisions.

Interpipe is responsible for developing and implementing effective policies to prevent and detect cases of economic offenses. The company has created an anonymous report system for suspected bribery, abuse of office, and misappropriation for employees, customers, and partners – hotlines and provision of information through the website and electronic mail.

Economic Security Service confidential hotline:

+38 (056) 747-40-90, +38 (056) 747-40-76

Direct number of the Economic Security Service Director:

+38 (0562) 747-40-70

Helpline email:

antifraud@interpipe.biz

Anti-corruption policy