FLSMIDTH & CO. A/S’ DATA ETHICS POLICY

1. Purpose
FLSmidth Co. A/S (“FLSmidth”) and its entities are committed to the protection of privacy and to transparent, secure and ethical data processing. This Data Ethics Policy sets out the data ethic principles applied by us and describes our approach to data processing covering all data types. The Policy is supplemented by our Privacy Policy and Cookies Policy as well as our internal HR Data Protection Policy and IT Security Policy.

2. Data Processing
Data is a vital asset for our business. We process personal data about our current, potential and former employees, business contacts and shareholders as well as website users. Such data are primarily collected directly from the data subjects and, if relevant and always subject to specific guidelines, from other sources such as public databases, joint marketing partners, and social media platforms, as well as other third parties. Personal data is processed and handled in accordance with applicable rules and regulations, including GDPR.

We also process large amounts of data that is not personally identifiable e.g., aggregate data, technical data, statistical data, enterprise IoT device data, industrial IoT device data or similar Such data is used to improve performance and reliability of our products and increase the productivity of our customers through digital solutions. Data is only shared with third parties in a form where the customer or installation is fully anonymous, unless otherwise agreed with the customer. 

When using machine learning, artificial intelligence or algorithms, e.g., in connection with IoT device data collection, we strive to ensure that the results are not discriminatory or biased in any way. Furthermore, the short and long term consequences of data processing activities, especially where new technology is applied, are considered and the impact on the data subjects are taken into account.

Personal data processed by FLSmidth is not subject to automated decision making, nor is it sold to third parties or used for artificial intelligence systems.

3. Security
The security of data is important to us. Our website and connected IT systems are protected against access by technical and organizational security measures also protecting data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage. 

4. Principles and Methods 
FLSmidth adheres to the six fundamental ethical values developed by the expert group on data ethics to the Danish Data Ethics Council. These values (see below) provide the foundation for our collection, processing and data usage and will be considered when developing or applying new technology:

• Self-determination: Individuals must maintain as much control as possible over their data.
• Equality and justice: Technology must not discriminate.
• Dignity: A person’s dignity is given priority over commercial interests.
• Progressiveness: The societal advances in the use of data can be achieved using data ethical solutions.
• Responsibility: All business areas are responsible for the technological solutions applied. 
• Diversity: As many professional groups as possible with diversity in gender, age, ethnicity, etc. shall be involved in the development of technological solutions.
  
  

5. Organization and Responsibility
Group Legal is the owner of this Policy. The policy is established December 2021.

The overall responsibility in connection with decisions, use and implementation of new technologies as well as the use of personal and non-personal data is anchored in Group Legal (personal data) and Group Digital (other data).