Human Resources and Careers · Borgstena Group

Human Resources and Careers

Data protection, ethics and conduct documentation applicable to the people of the Borgstena Group throughout the career cycle, from recruitment to the end of the employment relationship.

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Reference#PEPD-0847-20260526

Version202605

Date26 May 2026

NatureInstitutional page

People are at the heart of the Borgstena Group's project. This page brings together the data protection, ethics and conduct documentation applicable to applicants and workers throughout the career cycle, demonstrating the Group's commitment to transparency, equity and the safeguarding of people's rights in the employment context.

1. Commitment to people

The Borgstena Group has placed the well-being, inclusion and knowledge of its people at the heart of its sustainability strategy, in line with the institutional commitment expressed by the Group's leadership and with the social responsibility objectives set out in its strategic plan. In the field of data protection, this commitment is reflected in a consistent set of policies, information sheets and procedures that govern the processing of applicants' and workers' personal data.

2. Regulatory framework

The documentation on this page is based on Regulation (EU) 2016/679 (GDPR) and Law No. 58/2019 of 8 August, as regards the protection of personal data, and on the Labour Code, approved by Law No. 7/2009 of 12 February, as regards the employment relationship. In matters of ethics and conduct, the Borgstena Code of Conduct applies, in conjunction with the regime of Law No. 93/2021 of 20 December on whistleblower protection and with Decree-Law No. 109-E/2021 of 9 December on the prevention of corruption.

3. Documentation applicable to the career cycle

Applications

Data Processing Policy in Application Management

GDPRSpecial policy applicable to the processing of personal data of job applicants, complementing the general Policy. Accessible at borgstena.dataprotectionofficer.help/borgstena/policies.

Applications

Special Data Processing Information Sheet — Applicants

GDPRSheet detailing the processing activities, lawful bases and retention periods applicable to applicants. Accessible at borgstena.dataprotectionofficer.help/borgstena/information.

Employment

Data Protection and Privacy at Work Policy

GDPRLCSpecial policy on the processing of personal data of workers, in conjunction with the Labour Code.

Employment

Special Data Processing Information Sheet — Workers

GDPRLCDetailed sheet on processing activities in the employment relationship, including the special categories of data — trade union membership, biometric data and health data.

Ethics and conduct

Borgstena Code of Conduct

EthicsCode of Conduct in force at the Borgstena Group, setting out the ethical principles applicable to all employees. Available in Portuguese and English versions.

Equality and diversity

Commitment to Equality and Diversity

SA 8000Borgstena Group's commitment to an inclusive and diverse work environment, inscribed in the certification objectives [under the SA 8000 — Social Responsibility standard, to be confirmed depending on the current status of the certification].

Safety and health

Occupational Safety and Health

OSHProcessing of data on occupational safety and health, namely occupational medicine and biometric data for access control. Detail in the Special Sheet — Workers.

Rights

Rights Exercise Form

GDPRChannel for the exercise, by applicants and workers, of the rights of access, rectification, erasure, restriction, portability and objection. Accessible at borgstena.dataprotectionofficer.help/borgstena/forms.

Whistleblowing

Borgstena Group Whistleblowing Channel

Law 93/2021Secure and confidential channel for reporting irregularities in a professional context, with whistleblower protection. Accessible at whistleblowingofficer.com/borgstena.

Integrity

Anti-Corruption Platform

DL 109-E/2021Platform dedicated to policies and procedures for the prevention of corruption and related offences. Accessible at anticorrupcao.pt/borgstena.

4. Relationship with the Data Protection Platform

This page is integrated into the architecture of the Data Protection Platform and is cross-connected with:

the Policies page, where the special policies on applications and labour are set out;
the Information Sheets page, with detail on processing activities;
the Forms page, with the instruments for the exercise of rights and the reporting of incidents;
the Whistleblowing page, for the exercise of the right to report in a professional context.

5. Contacts

For any matter relating to the processing of their personal data in the context of an application or of the employment relationship, the data subject may contact the Borgstena Group's Data Protection Officer at dataprotection@borgstena.com. For matters relating to the employment relationship, Borgstena's general contacts, namely info@borgstena.com, may also be used.

6. Term and review

This page, as well as the documentation to which it provides access, is subject to periodic review, under the responsibility of the Data Protection Officer, whenever developments in the regulatory framework or in the Group's practices so warrant.