Company Policies

At Swagefast we believe that the environment represents a strategic resource for both current and future generations.

We need to minimize the impact, which its activities have on the environment by applying appropriate, cost effective measures to foster environmental, sustainable economic development.

The following principals are embodied in the company’s practices:

• Environmental concerns are part of the day to day activities of the Company’s Operations. All activities, from planning to implementation of projects, incorporate efficient use of resources and minimization of both environmental impacts and waste generation.

• The company strives to continuous improvement of environmental performance in the light of economic, technical and scientific change as well as recycling.

Swagefast is committed to a policy of ethics, integrity and honesty in conducting business. This policy applies equally to directors, employees and representative of the company.

Conflict of Interest
It is expected from all employees to perform their duties professionally and honestly and to act in the best interests of the company at all times. Employees must not use their positions or knowledge gained through their employment with the company for private or personal advantage, or in a manner that conflict/or an appearance of conflict arises between the company’s interest and their personal trust. A conflict of interest could arise where a supplier of goods or services is known or related to a staff member, who is also in a position to make a decision regarding the procurement of those services by virtue of the staff member’s position in the company, thereby resulting in a profit/gain to the staff member and/or loss/opportunity cost to the company. A person is “known” if he/she is a friend, acquaintance, family member or other relation.

Outside Activities, Employment and Directorships
Employees should avoid acquiring any business interest or participating in any activity outside the company that would create or appear to create an excessive demand upon their time, attention and energy that would deprive the company of their best efforts in their work/or a conflict of interest – that is, an interest which would interfere or appear to interfere with the independent exercise of judgement in the company’s best interests.

Employees may not take up outside employment or hold outside business directorships without the prior approval of the company. Relationships with clients, customers and suppliers The company recognises that relationships with clients, customers and suppliers give rise to many potential situations where conflict of interest, real or perceived, may arise. Employees should ensure that they are independent, and are seen to be independent, of any business organisation having a contractual relationship with the company or providing goods or services the company.

Personal investments
The company respects the right of all employees to make investment decisions as they see fit, as long as these decisions adhere to the conflict of interest provisions of this code. Employees should not permit their personal investment transactions to have priority over transactions for the company and its clients. An employee’s personal investment decision should not adversely influence their actions on behalf of the company.

Compliance
Employees must comply with all applicable laws and regulations which relate to activities for and on behalf of the company. The company will not condone any violation of law or unethical business dealings by any employee, including any payment for, or other participation in, an illegal act such as fraud, bribery or money laundering activities.

Employees must ensure that their business conduct is professional and ethical at all times. They should bear in mind that the perception of their actions by others is important, and should act accordingly. The directors, employees and staff of the company must promote the reputation and image of Swagefast through their actions and conduct.

Contravention of the Code
The company regards any contravention of the code as a serious matter. At the same time, any suspected or alleged contravention under investigation must be treated with utmost confidentiality. If employees believe that their own actions have, or may have contravened the code, they should immediately inform the managing director.

If employees suspect that another employee of the company has been responsible for a contravention of the code, they should report this promptly and confidentially, preferably in writing, to the chairperson.

As contravention of the code is a serious matter, it may result in disciplinary action, including the termination of employment. Certain breaches of the code could also result in civil or criminal proceedings.

Swagefast is committed to constantly improve and develop the skill set/level of all employees, by means of an integrated approach to the advancement of education, training and development. Our Company commitment to the development of our Human Resources is based on the following principals, in that:

• we are obligated to educate, train and develop our employees;
• we acknowledge that all employees have a basic right to continual and applicable education, training and development within the framework of their appointment;
• we acknowledge that all employees must be trained and developed according to their potential, aptitude, interests and abilities;
• we acknowledge that training needs must be identified on a continual basis to ensure employee growth and empowerment;
• the training and development of employees as such, are of extreme importance to render the appropriate quality-and constant level of service;
• the development of human resources should be aimed at improving knowledge, skills, attitude and to unlock employee potential to the benefit of the employee, organisations and community;
• to create a culture and climate conductive to human resources training and development;
• we accept this responsibility by establishing and maintaining a learning environment that respects and accommodates the values and culture of its employees and community at large;
• we will ensure the creation of appropriate structures and procedures for the implementation of this policy.

To accomplish this goal, we will commit the necessary resources, encourage development and follow through on all identified training needs.

Swagefast strives to ensure that every individual within the company respects the rights and freedoms enunciated below and to secure their effective recognition and observance throughout the company. Subject to considerations of health and safety and within the constraints posed by the nature of its business, Swagefast seeks to protect the right to:

• human dignity;
• fair treatment (subject to considerations of affirming previously disadvantaged groups);
• freedom and security of person;
• not be subjected to slavery, servitude and forced labour;
• freedom of conscience, religion, thought, belief and opinion;
• freedom of expression (subject to considerations of confidentiality and the prohibition of hate speech and incitement to cause harm);
• peacefully assemble;
• freedom of association;
• make political choices and to exercise those rights outside of working hours;
• freedom of movement;
• fair labour practices;
• not be employed if you are a child;
• not be arbitrarily deprived of property or possessions;
• freely participate in the cultural life of your choice;
• lawful, reasonable and fair action; and
• not be subjected to arbitrary arrest or detention.

Swagefast takes its data protection and privacy responsibilities seriously. This Privacy Notice also applies to swagefast.com and any other external Swagefast websites that link to this Notice (the”sites”).This Notice describes the types of personal information we collect electronically and on the sites, how we use the information, with whom we share it and the choices available to users of our services and sites regarding our use of the personal and corporate information provided. We also describe them easures we take to protect the security of the personal information and how users can contact us about our privacy practices. Internal company policies and procedures govern our internal networks and systems and the processing of personal information relating to employees and other authorized Swagefast network users.

When We Collect Information

We collect personal information about you if you visit one of our facilities, request access to our network and/or computing assets apply for employment with us, or have any type of business relationship with us. We will collect your personal information via the following methods:

• By recording details you provide to us (communications with us through emails, calls, or via our websites)
• By visiting one of our facilities; and/or
• By engaging in a consulting, customer, vendor or other type of business agreement with us.

Information We Collect

The types of personal information users/visitors of our sites/spaces may submit include:

• contact information (such as name, postal address, telephone number and email address);
• visitor information (such as full name, home address, email address, telephone number, company name, business contact information, citizenship/residency status, identity number, security clearance information, date of birth, passport and/or photograph);
• employment/consultant information (such as name, title, division, personal and business address, fax number, phone number, email address, biography with work history, photo, banking information provided with invoices, business reference information including name and contact information and employer);
• login credentials for the sites (such as IP address of the computer/personal device being used to access our network, approximate location information from where you access our network and information about your device and browser);
• other personal information submitted by current or prospective suppliers and subcontractors, such as identity number, diversity-related information (such as ethnicity), tax ID number, disability status, and civil/criminal conduct history;
• other personal information submitted by job applicants, such as a résumé or C.V., work authorization information, salary history, education history, information about security clearances, citizenship information and ethnicity, race and gender; and other personal information found in content that users provide.

Information We Collect by Cookies and Other Related Technology

When you use our Sites, we may collect certain information technologies such as cookies, web server logs, web beacons and JavaScript. For more information on how we collect and use this information, please refer to our cookie policy.

The Legal Basis for Using Your Personal Data

We will only collect, use and share your personal data where we are satisfied that we have an appropriate legal basis to do this. This may be because:

• you have provided your consent to us using the personal data;
• our use of your personal data is in our legitimate interest as a commercial organisation (for example our legitimate interests in communicating with you – in these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the “Your Rights and Choices” section below);
• our use of your personal data is necessary to perform business or take steps to enter into a contract with you (for example where you are one of our consultants, customers or vendors) and/or;
• our use of your personal data is necessary to comply with a relevant legal or regulatory obligation that we have for example fulfilment of a legal order.

If you would like to find out more about the legal basis for which we process personal data please contact us at webmaster@swagefast.com

How We Use the Information We Collect

We may use the information described above to:

• provide products and services;
• send you promotional materials and/or other communications;
• communicate with you about, and administer your participation in, special events, programs, offers, surveys and market research, respond to your inquiries;
• process employment applications, including by assessing qualifications, verifying information, and conducting reference or other employment-related checks;
• evaluate potential suppliers and subcontractors and manage our relationships with them;
• provide and administer human resources services for our employees;
• perform data analyses (including anonymization and aggregation of personal information);
• operate, evaluate and improve our business (including developing new products and services; enhancing and improving our products and services, managing our communications, analysing our products, services and communications, and performing accounting, auditing and other internal functions);
• protect against, identify and prevent cybersecurity and other security events, espionage, fraud and other unlawful activity, claims and other liabilities; and
• comply with and enforce applicable legal requirements, relevant industry standards and our policies.

We also may use the information in other ways for which we provide specific notice at the time of collection.

Information We Share

We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Notice. We share your information in the manner and for the purposes described below:

• within Swagefast, where such disclosure is necessary to provide you with our services or to manage our business;
• with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal data we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include IT service providers who help manage our IT and back office systems;
• with our regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
• we may share in aggregate, statistical form, non-personal data regarding the visitors to our website, traffic patterns, and website usage with our partners, affiliates or advertisers;
• if in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third-party purchaser of our business or assets.

In addition, we may disclose information about you:

• if we are required to do so by law or legal process;
• to law enforcement authorities or other government entities, and;
• when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual espionage, cybersecurity or security events or other fraudulent or illegal activity.

We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).

Transferring Personal Information Globally

Swagefast operates on a global basis. Accordingly, your personal data may be transferred and stored in countries outside South Africa (including Canada, the United States, Mexico, China, Brazil, South Korea, Japan, Australia and Russia, the EU) that are subject to different standards of data protection. We will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights.

To this end:

• we ensure transfers within Swagefast will be covered by an agreement entered into by members of Swagefast an intra-group agreement) which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred within Swagefast;
• where we transfer your personal data outside Swagefast to third parties who assist in providing our products and services, we obtain contractual commitments from them to protect your personal data. Some of these assurances are well recognized certification schemes; or
• where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal data are disclosed.

If you are located outside South Africa we will endeavour to comply with applicable legal requirements, providing adequate protection for the transfer of personal information to recipients in countries outside of South Africa. With respect to transfers of personal information to South Africa, we comply with the regulations provided by government regarding the transfer of personal information.

You have a right to contact us at webmaster@swagefast.com for more information about the safeguards we have put in place to ensure the adequate protection of your personal data when this is transferred as mentioned above.

Your Rights and Choices

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal data. We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. You can exercise your rights by contacting us at webmaster@swagefast.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Right to Access Personal Data

You have a right to request that we provide you with a copy of your personal data that we hold and you have the right to be informed of:

• the source of your personal data;
• the purposes, legal basis and methods of processing;
• the data controller’s identity; and
• the entities or categories of entities to whom your personal data may be transferred.

Right to Rectify or Erase Personal Data

You have a right to request that we rectify inaccurate personal data. We may seek to verify the accuracy of the personal data before rectifying it. You can also request that we erase your personal data in limited circumstances where:

• it is no longer needed for the purposes for which it was collected; or
• you have withdrawn your consent (where the data processing was based on consent), and
• where there is no other legal ground for the processing; or
• following a successful right to object (see right to object); or
• it has been processed unlawfully; or
• to comply with a legal obligation to which we are subjected to.

We are not required to comply with your request to erase personal data if the processing of your
personal data is necessary:

• for compliance with a legal obligation; or
• for the establishment, exercise or defense of legal claims; or
• for performance of a contract/to conduct business.

Right to Restrict the Processing of Your Personal Data

You can ask us to restrict your personal data, but only where:

• its accuracy is contested, to allow us to verify its accuracy; or
• the processing is unlawful, but you do not want it erased; or
• it is no longer needed for the purposes for which it was collected, but we still need it to establish,
• exercise or defend legal claims; or
• you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal data following a request for restriction, where:

• we have your consent; or
• to establish, exercise or defend legal claims; or
• to protect the rights of another natural or legal person.

Right to Transfer Your Personal Data

You can ask us to provide your personal data to you in a structured, commonly used, electronic format, or you can ask to have it transferred directly to another data controller, but in each case only where:

• the processing is based on your consent or on the performance of a contract with you; and
• the processing is carried out by automated means.

Right to Object to The Processing of Your Personal Data

You can object to any processing of your personal data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to Object How We Use Your Personal Data for Direct Marketing Purposes

You can object to any processing of your personal data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to Obtain a Copy of Personal Data Safeguards Used for Transfers Outside Your Jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of South Africa. We may redact data transfer agreements to protect commercial terms.

Right to Lodge a Complaint with your Local Supervisory Authority

You have a right to lodge a complaint with the regulatory authority if you have concerns about how we are processing your personal data. We request however that you please attempt to resolve any issues with us first, although you have a right to contact your regulatory authority at any time.

How We Protect Personal Information

Security

We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. As the security of information depends in part on the security of the computer being used to communicate with us and the security being used to protect User IDs and passwords please take appropriate measures to protect this information.

Storing Your Personal Data

We will store your personal data for as long as is reasonably necessary for the purposes for which it was collected, as explained in this notice. In some circumstances we may store your personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements.

In specific circumstances we may store your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.

Links to Other Websites

Our Sites may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked sites may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for the websites’ content, any use of the websites, or the privacy practices of the websites, even though you may enter that site directly from visiting ours.

Updates to Our Online Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post the updated version on our sites and indicate when it was most recently updated.

How to Contact Us

If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us at:

Swagefast (Pty) Ltd.
Att: Data Controller
P.O Box 2688
Krugersdorp
1740
South Africa
webmaster@swagefast.com

Because Swagefast offers a wide range of online business opportunities for its customers, the amount of information Swagefast needs to collect in order to serve you in a particular business transaction will sometimes vary from case to case. Regardless of the amount of information collected, the principles listed above will apply. Wherever we collect personal information, you will find a link to a privacy statement. If you choose not to provide some information, for example to enable confirmation of credit status or contact information to permit sending you requested information, it may not be possible for you to proceed with your chosen business activity with us.

“Our policy is to market products of a quality standard that will provide Customer satisfaction by performing expected functions reliably and effectively.”

The Quality Management System (QMS) that we have established has the total support of senior management and the commitment of all other company personnel concerned to ensure specified procedures are adhered to.

In our commitment to Quality our Quality Management System (QMS) has been certified as ISO 9001:2008 compliant.

Training is done on an on-going basis to familiarise personnel with our technical objectives, products, codes, standards, design and corporate procedures.

Quality is of utmost importance and our Clientele can be assured that all our products are Inspected, Tested and Certified.

Swagefast is committed to consistently working in a safe manner. Our Company commitment, as well as our personal commitment is subject to considerations of health and safety and within the constraints posed by the nature of its business, Swagefast seeks to protect the right to:

• maintain a safe working environment;
• maintain an injury-free working environment;
• maintain safe and healthy working relations; provide and maintain safe plant and equipment;
• review and revise this policy as necessary;
• be in compliance with all associated laws and regulations.

To accomplish this goal we will commit the necessary resources, encourage development of safe working attitudes, develop and communicate safety programs and standards. Always have the necessary signs and indicators applied and displayed to indicate hazardous areas and or conditions. Ensure adherence and discipline throughout the organization. In the final analysis we are all responsible for our personal safety as well as the safety of those around us.