Privacy Policy.

1.0 Definitions & Scope

Valmont Australia is committed to protecting the privacy of individuals’ personal information by complying with the National Privacy Principles set out in the Privacy Act 1988 (Cth). The purpose of this policy is to set out the privacy commitments of Valmont Australia and its Australian subsidiaries when it collects, uses, discloses or otherwise handles the personal identifiable information of customers, suppliers, contractors, its employees and other workplace participants.

This policy details how personal information in Valmont Australia (ABN 58 000 507 415) and its Australian subsidiaries [its subsidiary companies within Australia, being; Donhad Ltd; Industrial Galvanizers Corporation Pty Ltd (including: Industrial Galvanizers, Ingal Civil Products, Ingal EPS, AusZinc Metals & Alloys); Webforge Australia Pty Ltd; Hi-Light Industries Pty Ltd; and Locker] (referred to as the “Company” "we", "our" or "us" throughout this policy) is handled.

Personal information (as defined by the Privacy Act) means information that identifies you or could identify you. This includes information or an opinion, whether true or not, recorded in a material form or not, about an individual whose identity is apparent or could be reasonably ascertained from the information or opinion.

Specifically, this policy outlines what personal information the Company will hold, the purpose for which it is held, how that information is used and disclosed, and how you can access the information held about you to update or correct it.

2.0 Collection of Personal Information

The company will only collect personal information about you that is necessary for the purpose of conducting our business and / or meeting our employer obligations. We collect the information that you provide in your communications with us and/or as required on forms associated with employment records. We may also collect information from a third party or publically available source, where consent has been provided by the individual or the individual would reasonably expect us to collect personal information in this manner.

We do not collect or hold sensitive information (as defined in the Privacy Act) about you without your consent, or use or store government identifiers in relation to your personal information (with the exception of Tax File Numbers to meet government taxation requirements).

There may be situations where the Company will be required by law to collect certain personal information on/from individuals. In such a situation, the Company is obliged to inform the individual of this.

3.0 Use of Personal Information

The company only collects personal information which is necessary for its purposes which include, but is not limited to:

• Enabling the Company to provide customers with more effective customer services
• Communicating with customers, such as to let them know of other products and/or services which might interest them
• Communicating with suppliers
• Managing employees, contractors and other workplace participants, such as to ensure that they are meeting obligations under relevant legislation as well as their contract of employment and to administer any employee share plans and employee option plans
• Ensuring the health, safety and welfare of workplace participants tat times when they are preforming work for the Company
• Allowing appropriate insurance coverage for workplace participants to be obtained
• To meet our Australian taxation & superannuation obligations.

4.0 Disclosure of Personal Information

We may disclose your personal information in confidence to related bodies corporate, subcontractors and service providers in the course of conducting our business. We may also disclose your personal information in confidence to third parties when undertaking joint promotions. In these cases, we require the subcontractor, service provider or third party to hold and use the personal information strictly in accordance with the terms of this Policy.

Your personal information may be disclosed to potential buyers of Valmont Australia, our assets or businesses under an undertaking of secrecy as part of a bid or sale process.

We will not sell your personal information to third parties for the purpose of enabling them to market their products and services to you.

Otherwise, the Valmont Australia will only use or disclose your personal information as required to fulfil the purpose for which it was collected, unless:

• The person has expressly or impliedly consented to its further use or disclosure; and/or
• The person would reasonably expect the Company to use or disclose it in such a way.

Further, in accordance with the Privacy Act, we may use or disclose your personal information if we reasonably believe that the use or disclosure:

• Is necessary to lessen or prevent a serious and imminent threat to an individual’s life, health or safety or a serious threat to public health or public safety:
• Is necessary to investigate or remedy suspected unlawful activity or in reporting concerns to relevant persons or authorities;
• Is required or authorised by or under law; or
• Is in preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.

5.0 Security and Confidentiality

The Company must retain certain personal records in accordance with legislation. In many cases this includes maintaining records for the prescribed period of time after the last entry is made.

6.0 Openness, Access and Correction

We will take reasonable steps to ensure that personal information held by the Company is accurate, up to date and complete. These steps include maintaining and updating personal information when we are advised by individuals that their personal information has changed, and at other times as necessary.

If an individual requests access to the personal information the Company holds about them, or requests that we change that personal information, we will facilitate access or make the requested changes as appropriate unless we consider that there is reason under the Privacy Act (or any other relevant legislation or law) to withhold or restrict access to the information.

7.0 Technology & Privacy

Individuals interacting or transacting with Valmont Australia should be aware that most software used to operate networks, including web servers, mail servers and gateways will log transactions and communications.

Such logs normally include the e-mail addresses of senders and recipients of e-mail and the time of transmission. The content of e-mails themselves would not normally be logged by software, but may be stored on mail servers. Similarly, web server logs record information on the sites that people visit. It should also be noted that Company System Administrators are also capable of reading the contents of e-mails sent and received by the corporate network

Individual’s accessing Company email or internet services should be aware that the Company cannot guarantee that recipients of communications or information provided to external sources abide by the same privacy practices applied by Valmont Australia.

It should be noted however, that e-mails which contain personal information are records for the purposes of the Privacy Act and accordingly the personal information contained in email transmissions utilising company provided email or internet services are covered by this policy.

Important Note:
Employees utilising email and internet services provided by the Company in the course of their employment should familiarise themselves with the Company Systems Usage Policy, which sets out the proper and permitted use of the network, including Internet e-mail and web browsing.

Notification of Changes
The Company may revise this policy from time to time by distributing a revised policy electronically, or by posting the revised policy on our website.

Please note that our use of your personal information will be based on the privacy policy in effect at the time the information is used.

For Further Information Regarding the Privacy Act 1988
Contact the Australian Government Office of the Privacy Commissioner.

Telephone:	1300 363 992
Email:	privacy@privacy.gov.au
Or visit their website:	www.privacy.gov.au