Corporate policies

PERSONAL DATA PROCESSING POLICY

The company CROYDON COLOMBIA S.A., in compliance with the provisions of Law 1581 of 2012, Decree 1074 of 2015 and the regulations issued by the Superintendence of Industry and Commerce, informs the applicable policy for the processing of personal data of natural persons. This personal data processing policy establishes: (i) the terms, conditions and purposes under which CROYDON COLOMBIA S.A. processes the personal data obtained from its shareholders, employees -both direct and on mission-, collaborators, clients, consumers, suppliers, contractors, visitors and sales force; (ii) the security and confidentiality conditions of the information collected; and (iii) the procedures established for the data owners or their representatives to exercise the rights inherent to the protection of personal data. The data controller is directly the company CROYDON COLOMBIA S.A. NIT 800.120.681-2, commercial company domiciled in the city of Bogotá, D.C., located at carrera 61 number 48 – 37 SUR, PBX (1) 770 9240, FAX (1) 770 9241, e-mail: datospersonales@croydon.com.co. This policy of treatment of personal data is subject to the provisions of Article 15 of the Political Constitution, Law 1266 of 2008, Law 1581 of 2012, Decree 1074 of 2015, Chapter II of Title V of the Single Circular of the SIC, Circular 2 of 2015 of the SIC and Ruling C-748/2001 of the Constitutional Court; welcomes the principles of legality, freedom, purpose, truthfulness or quality, transparency, restricted access and circulation, security and confidentiality established in the legislation in force and for its implementation and interpretation is governed by the legal definitions.

I. TERMS, CONDITIONS AND PURPOSES

Data collection and authorization of the owner. In order to fulfill its corporate purpose, CROYDON COLOMBIA S.A. collects from its holders – and according to the category to which each of them corresponds – at most the following personal information: names and surnames, identification document number, employer, correspondence address, e-mail address, telephone, tax classification, discount percentage, credit quota and video record, apart from those derived from the labor relationship. The authorization may be recorded in a physical, digital, electronic document or in any other format that guarantees its subsequent consultation. Except in relation to data that are public or related to the civil registry of persons, those required by public or administrative entities in the exercise of their legal functions -for which no authorization is required-, or private, semi-private and sensitive data collected for a purpose other than commercial prospecting -for which no authorization is required-, the owner of the data must expressly authorize CROYDON COLOMBIA S.A. to store, process and use personal information related to private, semi-private and/or sensitive data, partially or totally, for the purposes expressed in the law and in this policy, and in case of occurrence, the international transmission of personal data. CROYDON COLOMBIA S.A. does not collect private or sensitive personal data for commercial prospecting purposes, its collection corresponds to the strict compliance of a legal and/or contractual duty and/or for security reasons, and in case of minors -boys, girls and/or adolescents- will only be limited to collect data of public nature, always ensuring the proper use of personal data of children under 18 years, ensuring respect in its treatment in the best interest of those, ensuring respect for their rights. The way of collecting the data is as follows: .- through the stores directly by the personnel in charge; those related to the credit purpose, through commercial advisors and/or catalog sales coordinators, directly; labor, directly by the Human Management area for direct workers, and through temporary service companies for workers on assignment; .- those related to suppliers, directly by the purchasing area; those related to contractors, directly by the commercial area; those related to online sales, through the web page; for visitors to the industrial plant and stores, and their workers and/or collaborators, video capture by closed circuit television; and for direct workers and/or workers on mission, fingerprint reading through the corresponding application. Treatment. All the information contained in the company’s databases is treated in different ways: from the collection, compilation, organization, processing, systematization, reproduction and storage, to its updating, administration and use in compliance with the legal purposes and those indicated in this data treatment policy. Purpose. The data collected are used exclusively for the exercise of the corporate purpose of CROYDON COLOMBIA S.A., consequently, the policy of treatment of this information only responds to the fulfillment of legal obligations -including tax, labor and social security-, and/or contractual and/or security reasons, and to the management of internal information about contractors, consumers, collaborators, sales force, customers and suppliers, the latter information for credit, advertising and commercial prospecting purposes, as the case may be, in order to inform them about events organized by the company and their results, advertising campaigns and participation of the brands in specific activities, as well as instructions, for which -eventually- the international transmission of personal data may be carried out. Validity. The data processing policy of CROYDON COLOMBIA S.A. has been in force since July 29, 2013, date on which the privacy notice on personal data was published on the company’s website, however, with the publication of this data processing policy on November 1, 2016 on the company’s website www.croydon.com.co, the same is replaced to adjust it to the regulatory requirements, informing that the validity of the databases will be at least that required by the external control entities and according to the document retention tables adopted by the company, but may be indefinite while it fulfills the function of the exercise of the corporate purpose of the company. As an information mechanism, every time an update to this data processing policy is presented, it will be communicated via e-mail to the respective owners.

II. SECURITY AND CONFIDENTIALITY CONDITIONS

In order to guarantee the security and confidentiality of the information, CROYDON COLOMBIA S.A. has physical security in its facilities and an adequate technology that provides reasonable protection in the processes of information processing, designating officials duly trained for this purpose. In addition to the above, we propose as a basis the use of personalized authorizations for each of our employees, customers, and others who at some point are linked to us, likewise we propose through our internal network, mass communications to administrative staff and all area managers. The confidentiality and integrity of the data stored in the systems of CROYDON COLOMBIA S.A. are protected by access codes and passwords that ensure that only authorized employees have access. The Technology and Development Department (DTD) is responsible for the administration of the access controls to all the company’s information systems, as well as to the different services offered such as Internet, Intranet, VPN, shared folders, etc. DTD will disable the user codes of people who are on vacation, disabled and/or on paid or unpaid leave, according to the respective record in the Payroll Information System, and they will be enabled in the same way. Likewise, the user codes of employees who are removed from the payroll will be deleted. Additionally, CROYDON COLOMBIA S.A. has a TECHNOLOGY AND DEVELOPMENT POLICY of mandatory compliance for its employees, which in the part relating to databases, states: “The following postulates must be observed permanently, as follows: Each and every employee of CROYDON COLOMBIA S.A. is under the obligation to maintain, preserve and guarantee the veracity and quality of the data in the Information Systems they use for their daily work. The quality of the data in the databases or file systems is the primary responsibility of each user of the information systems. Its alteration, misuse, or out-of-date, will be cause for serious penalties. No employee, under any circumstances, may copy data to be used in external systems to CROYDON COLOMBIA S.A., proof of this may cause their removal from the company. All employees who handle customer data are obliged to keep the databases updated with the latest information about them. Blank fields or erroneous data may result in penalties. All employees of CROYDON COLOMBIA S.A., as well as for all customers, external consultants, temporary staff and guests, who make use of the resources and services of Network and / or Telecommunications provided by CROYDON COLOMBIA S.A. is mandatory and express compliance to observe and follow the policy of treatment of personal data. Any violation of confidentiality that is detected, threatening it or a treatment different from the purpose indicated in this policy, involving adulteration, loss, consultation, use or unauthorized or fraudulent access, will be investigated internally immediately and, if necessary, reported to the competent authorities. In any case, it will be reported to the data protection authority -within the legal opportunity- when incidents or security violations occur, or there are risks in the treatment of the information of the owners, and in the first week of the months of February and August of each year, about any type of complaint received from the owners during the previous six (6) months. Privacy or Data Protection Officer. Whoever is in charge of the Technology and Development Management of CROYDON COLOMBIA S.A. will act as Privacy or Data Protection Officer and will be the person who within the company has the responsibilities to coordinate, promote and supervise compliance with the rules on protection of personal data, procedures and security measures of personal information under the terms of the law. This person is the one who – in the name and on behalf of the Controller – solves the queries and claims made by the information holders. The Privacy Officer must: .- Know the rules that regulate the protection of personal data, the ways through which the information of the data holders is captured, how the personal information is used and the security procedures of the personal information, including the IT ones .- Propose improvement actions regarding the security of the personal information in accordance with the conditions and capacities of the Controller .- Answer the queries and claims of the information holders. To notify the different areas of the company on how to use the information they handle or to which they have access. To elaborate or coordinate the elaboration of internal updating documents regarding personal data. – Notify on inclusion, update or deletion of personal data in the different databases. Assess the impact on the privacy framework and the protection of personal data of new projects or regulations affecting the company. Respond and/or support responses to requests for information or procedures carried out by the authority for the protection of personal data. To make a biannual report on the number of queries and claims submitted by the owners of information. To carry out audits aimed at preventing and detecting violations in the procedures for the protection of personal data. To carry out or coordinate the periodic implementation of awareness, education and training programs among the members of the company aimed at a better knowledge of the applicable legislation on data protection. To comply with the instructions and recommendations on personal data protection issued by the SIC. In general, to encourage and promote good practices in data protection. Transfer of databases. CROYDON COLOMBIA S.A. will not transfer to third parties, in any way, nor will it transfer its databases or the information they may contain about personal data, other than in compliance with its legal obligations. International transmission of personal data. Depending on the nature of the permanent or occasional relationships that any person holding personal data may have with the company, the totality of their information may be transmitted abroad, subject to the applicable legal requirements and with the acceptance of this policy expressly authorizes the transmission of personal information. CROYDON COLOMBIA S.A. will take the necessary measures to ensure that these persons in charge know and undertake to comply with this policy, with the understanding that the personal information they receive may only be used for matters directly related to the company, and may not be used or intended for a different purpose or purpose.

III. RIGHTS OF THE OWNERS AND PROCEDURE FOR THEIR EXERCISE

The owners of the data have the right at all times to know, access, update and rectify the data, request proof of authorization, be informed of the processing, complain to the Superintendence of Industry and Commerce, as well as request the revocation of the authorization -in the appropriate cases- and/or the deletion of the data, as follows: .- To know, update and rectify their personal data. This right may be exercised in relation to partial, inaccurate, incomplete, incomplete, fractioned, misleading data, or data whose processing is expressly prohibited or has not been authorized. Request proof of the authorization granted. This right may be exercised except when expressly exempted as a requirement for the processing. To be informed, upon written request, regarding the use that has been made of their personal data and to have access at all times to the personal data that have been processed. To revoke the authorization and/or request the deletion of the data. This right may be exercised without any condition, as long as it corresponds to data that is not necessary for the fulfillment of a legal duty, that is public or related to the civil registry or those required by public or administrative entities in the exercise of their legal functions -for which no authorization is required-, and, in any case, when the treatment does not respect the constitutional and legal principles, rights and guarantees. To exercise these rights -in relation to CROYDON COLOMBIA S.A.- it is necessary to contact the Technology and Development Department of CROYDON COLOMBIA S.A., located at carrera 61 número 48 – 37 SUR in Bogotá, D.C, or by e-mail: datospersonales@croydon.com.co. The application must comply with the following requirements: Complete identification of the applicant with indication of first and last names and identity document. It must be clear and precise as to the purpose of the request, i.e.: (i) knowledge, updating or rectification of the data; (ii) obtaining proof of authorization; (iii) information on the processing; (iv) revocation of authorization; or (v) deletion of the data. Indication of the physical or electronic address where you will receive the response. If the request complies with these requirements, it must be resolved within ten (10) business days following its submission, otherwise it will be required within five (5) business days following its submission to correct the defects indicated, granting a term of ten (10) days for this purpose. After two (2) months have elapsed from the date of the requirement, without the applicant submitting the required information, it shall be understood that the application has been withdrawn and it shall be filed. If the request is submitted to a different agency, it shall be immediately forwarded to the Technology and Development Department for its respective processing. The attention, analysis and response to any request related to the processing of personal data is the responsibility of the Privacy Officer or Data Protection Officer, who will be responsible for implementing the measures in accordance with the decision taken. Once the request has been processed before the company, the holder who is dissatisfied with the response may go to the Superintendence of Industry and Commerce, in order to enforce their rights.

ENVIRONMENTAL POLICY

Croydon Colombia S.A., a company dedicated to the Design, Production and Sale of footwear, contemplates within its policy the Protection of the Environment and the Prevention of Pollution as essential elements in the development of its productive activities, through the planning, execution, verification and continuous improvement of the following guidelines:

  • The management and control of solid waste generated in the company, with special emphasis on Hazardous Waste.
  • Continuous consideration of the Environmental Aspects and Impacts associated with its economic activity.
  • Rationalization in the use of natural resources.
  • Environmental awareness and sensitization at all levels of the company.
  • Monitoring and control of emissions and discharges with a view to reducing the Carbon and Water Footprints generated by the production processes developed.

The adopted commitment requires that our actions are framed in accordance with the legal and other applicable requirements, include the Climate Variable as a fundamental criterion in Decision Making and seek at all times the continuous improvement of our operations and processes, all with the purpose of making Croydon Colombia S.A. an environmental and sustainable development leader in the footwear sector in Colombia.

QUALITY POLICY
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CROYDON COLOMBIA S.A., has as a policy to satisfy the needs and expectations of its customers, seeking continuous improvement of processes, by controlling the design and development of new products, the production processes of Injection PVC Boots, Rubber Boots, Conventional Footwear and Cold Gluing, making timely deliveries that meet customer requirements.

By considering the risks and opportunities, the probability of achieving the objectives will increase, through the identification, analysis, evaluation and implementation of effective and efficient actions; creating growth opportunities for suppliers, collaborators and shareholders.

CLIMATE CHANGE POLICY

Croydon Colombia S.A., a Colombian company dedicated to the design, manufacture and marketing of footwear, is committed to orienting the operational management of its processes and activities towards the reduction of Greenhouse Gas emissions with a view to achieving mitigation and adaptation to climate change through the planning, implementation, verification and
continuous improvement of the following guidelines:

  • Identification and prioritization of all direct and indirect sources and sinks of greenhouse gas emissions.
  • Measurement and reporting of greenhouse gas emissions and identification of the main reduction opportunities.
  • Formulation and implementation of the necessary measures to reduce the intensity of emissions generated or eliminate their cause.
  • Evaluation and selection of compensation alternatives oriented exclusively towards the neutralization of residual emissions.
  • Approaching and linking stakeholders in the supply chain to practices that promote their awareness and participation in climate change issues.
  • Analysis to identify, monitor and mitigate risks associated with climate change that may affect business continuity and take adaptation actions.

The goal proposed for 2024 within the framework of the Corporate Climate Change Management Plan is a 23.48% reduction in the emission indicator per pair produced (KgCO2e) with respect to the base year 2021 and is intended to be achieved through the development of strategies that seek to achieve carbon neutrality and promote a global economy with lower carbon emissions.
emissions, which are periodically updated and monitored within the Quality Management System and the management review. The elements of this Policy constitute a basic tool for the inclusion of the climate variable as a fundamental criterion in decision making, with the purpose of making Croydon Colombia S.A. a national reference in the adaptation of industrial processes with a view to reducing its impact on climate change.

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