Code of Conduct policy
The Arctic Paper Code of Conduct describes the fundamental rules of behavior which applies to all Arctic Paper employees and everyone who represents Arctic Paper. We are committed to have a fair and ethical conduct in our dealings with all stakeholders.
This means that:
- Arctic Paper employees must practice honesty and integrity in every aspect of dealing with other employees, customers, suppliers, other business partners, communities and government authorities.
- Neither Arctic Paper nor any of its employees shall make or receive illegal or improper payments or bribes and will refrain from participating in any corrupt business practices.
- Arctic Paper shall follow antitrust and fair competition legislation and not be involved in activities that restrain free trade or limits competition.
- Arctic Paper employees shall avoid entering into situations where their personal, family or financial interests may be in conflict with that of Arctic Paper. Where any such potential conflict of interest arises, the employee shall disclose this and seek authorization from his/her superior.
- Arctic Paper employees shall respect physical and intellectual property rights. This includes the obligation to respect and protect the physical and intellectual properties of Arctic Paper as well as not being engaged in activities that violate property rights of other organizations or individuals.
- Arctic Paper is committed to open and transparent communications within the bounds of commercial confidentiality. Arctic Paper shall practice fair marketing and provide customers and other business partners with factual and unbiased information about its products and services.
- Arctic Paper shall provide adequate customer service and support, and handle complaints and dispute situations according to business practice and applicable legislation.
- Arctic Paper shall respect the privacy of data relating to individual persons (whether employees or third parties) and protect such data by adequate security safeguards. No Arctic Paper employee shall without proper authority access, modify, disclose or make use of any personal information for any purpose other than is allowable legitimately. Arctic Paper shall be open towards employees and third parties about developments and practices regarding collection and usage of personal data.
- Any Arctic Paper employee aware of a violation of applicable law or of this policy shall report that information immediately to his/her supervisor.
- Arctic Paper has implemented a Whistleblower policy to support the compliance of the Code of Conduct provisions and EU legislation.
If you are a job applicant, we process your data as follows:
| Purpose of processing | Description of the legal basis | GDPR provision |
|---|---|---|
Personnel recruitment – current recruitment processes | Fulfilment of legal obligations imposed on us by legislation (in particular Article 221 of the Labour Code) – as far as the personal data provided for by the legislation is concerned | Article 6(1)(c) |
Consent – for personal data not provided for by legislation | Article 6(1)(a) |
Personnel recruitment – current recruitment processes
- Purpose of processing
Personnel recruitment – current recruitment processes
- Description of the legal basis
Fulfilment of legal obligations imposed on us by legislation (in particular Article 221 of the Labour Code) – as far as the personal data provided for by the legislation is concerned
- GDPR provision
Article 6(1)(c)
- Purpose of processing
- Description of the legal basis
Consent – for personal data not provided for by legislation
- GDPR provision
Article 6(1)(a)
Your data will be kept until the recruitment process to which you have applied has been completed.
If you provide us with services or goods and are therefore our contractor or a representative of our contractor, we process your data as follows:
| Purpose of processing | Description of the legal basis | GDPR provision |
|---|---|---|
Contractor data processing – for the purpose of fulfilling a contract with a contractor or taking action prior to entering into a contract with a contractor | Necessity for the performance of a contract to which the data subject is party or for taking steps prior to entering into a contract | Article 6(1)(b) |
Processing of contractor's representative data – for the purpose of fulfilling a contract with a contractor or taking action prior to its concluding a contract | Legitimate interest in being able to conclude and perform a contract between us and a contractor | Article 6(1)(f) |
Performance of legal obligations related to the contract with the contractor | Fulfilment of legal obligations imposed on us by law, in particular tax and accounting obligations | Article 6(1)(c) |
Redressing or defending against possible claims | Legitimate interest to establish, assert or defend against claims | Article 6(1)(f) |
Contractor data processing – for the purpose of fulfilling a contract with a contractor or taking action prior to entering into a contract with a contractor
- Purpose of processing
Contractor data processing – for the purpose of fulfilling a contract with a contractor or taking action prior to entering into a contract with a contractor
- Description of the legal basis
Necessity for the performance of a contract to which the data subject is party or for taking steps prior to entering into a contract
- GDPR provision
Article 6(1)(b)
Processing of contractor's representative data – for the purpose of fulfilling a contract with a contractor or taking action prior to its concluding a contract
- Purpose of processing
Processing of contractor's representative data – for the purpose of fulfilling a contract with a contractor or taking action prior to its concluding a contract
- Description of the legal basis
Legitimate interest in being able to conclude and perform a contract between us and a contractor
- GDPR provision
Article 6(1)(f)
Performance of legal obligations related to the contract with the contractor
- Purpose of processing
Performance of legal obligations related to the contract with the contractor
- Description of the legal basis
Fulfilment of legal obligations imposed on us by law, in particular tax and accounting obligations
- GDPR provision
Article 6(1)(c)
Redressing or defending against possible claims
- Purpose of processing
Redressing or defending against possible claims
- Description of the legal basis
Legitimate interest to establish, assert or defend against claims
- GDPR provision
Article 6(1)(f)
Your data will be retained until the expiration of the statute of limitations for civil law claims and tax liabilities, and until the mandatory retention periods for accounting records have elapsed, as stipulated by civil, tax and accounting legislation.