Legal

The health and wellbeing of our employees are paramount to us.

We continue to follow the advice from the government and the relevant public health authorities in all locations that we operate, to ensure the safety and protection of all our staff.

Our teams are fully committed to ensuring business continuity to ensure the business continues to function normally and our commitment to our counterparties and customers remains unaffected.

SEFE Marketing & Trading – Website Terms of Use

By using our Site you accept these terms

This document (together with our Privacy Policy sets out the terms and conditions of use (‘Terms’) of our website www.sefe-mt.com (our ‘Site’). Please read these Terms carefully before you start to use our Site. By accessing and using our Site, you agree to be bound by these Terms.

Information about us

www.sefe-mt.com is a site operated by SEFE Marketing & Trading Limited. We are registered in England and Wales under company number 03768267 and have our registered office at 20 Triton Street, London NW1 3BF. Our VAT number is GB-927 405129.

Accessing our Site

Access to our Site is permitted on a temporary basis, and we reserve the right to withdraw, amend or restrict access to our Site without notice (see below). We will not be liable if for any reason our Site is unavailable at any time or for any period.

Reliance on information posted

The content of our Site has been prepared solely for the purpose of providing you with general information about SEFE Marketing & Trading Limited and it is not intended to constitute any offer or advice on which you should rely.

The content of our Site, nor the commentary or other materials posted on it, must not be relied upon in connection with any investment decision. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content of our Site.

Any of the material on our Site may be out of date at any given time, and we are under no obligation to update such material. We disclaim all liability and responsibility arising from any reliance placed on such materials by any visitor to our Site, or by anyone who may be informed of any of its contents.

Intellectual property rights

We are the owner or the licensee of all intellectual property rights in our Site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

How you may use our Site

You must not use any part of the materials on our Site for commercial purposes without obtaining a licence to do so from us or our licensors.

You may print off one copy and download extracts of any part of the material on our Site for your personal use and you may draw the attention of others within your organisation to material posted on our Site.

Without our prior written consent, you may not copy, distribute, broadcast, modify, alter or tamper with in any way or otherwise use any material contained on, printed off or downloaded from our Site, except as set out herein and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

You may not remove any copyright, trade mark or other intellectual property notices contained in the original material from any material copied or printed off from our Site.

The status of SEFE Marketing & Trading Limited (and that of any identified contributors) as the authors of material on our Site must always be acknowledged.

You must not use a part of our Site on any other website, or link any other website to our Site, without our prior written permission.

These restrictions apply in relation to all or part of the material on our Site. If you print off, copy, download, use or link to any part of our Site in breach of these Terms, your right to use our Site will cease immediately and you must, at our option, cease to use or link, return or destroy any copies of the materials you have made.

Changes to our Site

We may update and change our Site at any time. If the need arises for business or operational reasons, we may suspend or withdraw or restrict the availability of all or any part of our Site, or close it indefinitely.

Information about you and your visits to our Site

We will only use your personal information as set out in our Privacy Policy. By using our Site, you consent to such processing and you warrant that all data provided by you is accurate.

Links to other websites

Where our Site contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those sites or resources and accept no responsibility for them or for any loss or damage that may arise from your use of them.

Such links should not be interpreted as endorsement or approval by us of any third parties or their advice, opinions, information, products or services expressed or implied by any information on our Site.

Our liability

The content of our Site is provided without any representations, conditions or warranties as to its accuracy, correctness or completeness, information is provided on an “as is” basis, “as available” basis and we do not give or make any warranty or representation of any kind, whether express or implied.

To the extent permitted by law, SEFE Marketing & Trading Limited and other members of our group of companies hereby expressly exclude:

• All conditions, warranties, representations and other terms which might otherwise be implied by statute, common law or the law of equity;
• Any liability for any direct, indirect or consequential loss or damage, incurred by any user in connection with our Site arising under or in connection with the use, inability to use, or results of the use of, or reliance on any content displayed on our Site, any websites linked to it and any materials posted on it, including, without limitation any liability for loss of income or revenue; loss of business; loss of profits or contracts; loss of anticipated savings; loss of data business interruption; loss of business opportunity, goodwill or reputation; wasted management or office time; and for any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract, breach of statutory duty or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above.

This does not affect the liability of SEFE Marketing & Trading Limited for death or personal injury to you arising from our negligence or the negligence of our employees, agents or subcontractors, and for fraud, fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.

We are not responsible for viruses

Whilst we use reasonable endeavours to ensure our Site is secure and free of errors, viruses and other malware, we give no warranty or representation that the Site will be available and meet your requirements, that access will be uninterrupted, that there will be no delays, failure, errors or omissions or loss of transmitted information, that no virus or other contaminating or destructive properties will be transmitted or that no damage will occur to your computer system.

We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Site or to your downloading of any material posted on it, or on any website linked to it.

You must not introduce viruses

You take sole responsibility for the security of your personal details and your computers and for the backup of data and/or equipment and for undertaking reasonable precautions to scan for viruses or other destructive properties.

You must not misuse our Site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our Site, the server on which our Site is stored or any server, computer or database connected to our Site. You must not attack our Site via a denial-of-service attack or a distributed denial-of service attack.

By breaching this provision, you would commit a criminal offence. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our Site will cease immediately.

We may amend our Terms

We may amend our Terms at any time. You are expected to check these Terms from time to time to take notice of any changes we made, as they are binding on you. You are responsible for ensuring that any person who may access our Site through your computer or internet are aware of these Terms and that they comply with them.

Some of the provisions contained in these Terms may be superseded by provisions or notices published elsewhere on our Site.

General

You may not transfer any of your rights under our terms to any other person. We may transfer our rights and obligations under these Terms, where we reasonably believe your rights will not be affected.

Unless otherwise agreed, no delay, act or omission in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

If any of these provisions or part-provision is or becomes unlawful, invalid or otherwise unenforceable then it shall be deemed deleted and that shall not affect the validity and enforceability of the rest of the Terms.

Governing law

These Terms are governed by and interpreted in accordance with the laws of England and Wales and the courts of the above jurisdiction will have exclusive jurisdiction in respect of any dispute which may arise.

Background

This is SEFE Marketing & Trading Limited’s statement on slavery and human trafficking. This statement is made pursuant to section 54(1) of the Modern Slavery 2015 (“Act”) for the financial year ending on 31 December 2024 and includes SM&T’s subsidiaries (together “SM&T”).

SM&T is fully committed to ensuring that it  complies with all applicable legal requirements, including without limitation the Act.

Our business

SM&T comprises the following companies which together are part of the integrated energy company that is SEFE (Securing Energy for Europe):

• SEFE Marketing & Trading Switzerland AG
• SEFE Energy Limited
• SEFE Energy France SAS
• SEFE LNG Limited
• SEFE Marketing & Trading Singapore PTE Ltd
• SEFE Marketing & Trading USA, Inc

SM&T employs in the region of 850 people and has business operations in the UK, Singapore, Switzerland, France, USA and the Netherlands. [1]

Our policy on slavery and human trafficking

SM&T fully supports the aims of the Act. Our policy reflects our commitment to acting ethically and with integrity in all our business relationships and to endeavour to ensure that slavery and human trafficking is not taking place anywhere in our business or supply chains.

Our processes to prevent slavery and human trafficking

SM&T has taken the following action to ensure the prevention of modern slavery and human trafficking:

1. Prepared a revised and consolidated SEFE-wide Code of Ethics & Business Conduct which requires staff to, amongst other things, uphold our commitment to acting ethically and with integrity in all our business relationships, and clearly states the company’s commitment to combating modern slavery and human trafficking.
2. Implemented a comprehensive Compliance Management System, managed by the Legal & Compliance department, which assigns responsibility for varying ethics and compliance topics to respective ‘responsible functions’ within the company. Human Rights, Social and Labour Standards are addressed by the Compliance Management System.
3. Refreshed and reintroduced a SEFE-wide whistleblowing telephone hotline and web portal to facilitate the making of anonymous whistleblowing reports, and appropriate underlying whistleblowing investigation and handling procedures to provide adequate protection for whistleblowers, should anyone wish to make a report related to modern slavery and human trafficking.
4. Developed and introduced SEFE-wide Human Rights Policy Statement which explicitly stipulates that SEFE is committed to respecting, safeguarding and ensuring adherence to all internationally recognized human rights both at our company and along our value chains.
5. Formally appointed a SEFE Human Rights Officer to monitor human rights risks across SEFE and within its supply chains.

As part of our commitment to combating modern slavery, SM&T will be taking the following steps:

1. Implement further supply chain due diligence screening tool to aid third party business partner assessments.
2. Continue reviewing the various parts of our business to ensure no slavery or human trafficking takes place in any part of our business or the supply chains.
3. Reinforcing the messages of the united SEFE Code of Ethics & Business Conduct and Human Rights Policy Statement, and continue to review and improve underlying processes and policies to identify how we can try to ensure that no slavery or human trafficking takes place within any part of our business or the supply chains.
4. Continue to incorporate appropriate anti-slavery and human trafficking provisions into our procurement and third party supplier contracts on a risk assessed basis.
5. Continue monitoring potential risk areas in our supply chains, as part of our periodic business-wide risk assessment.

SM&T will continue to review our procedures in relation to the prevention of slavery and human trafficking in our business and supply chains.

A new statement will be published each year on the corporate website http://www.sefe-mt.com

SEFE Marketing & Trading is committed to making its site as widely available as possible, and as such we have worked to make this site a good experience for users of all abilities and technologies.

Standards Compliance

All pages on this site are XHTML 1.0 Transitional. All pages on this site use structured semantic mark-up. For example, h1 and h2 tags are used to convey document format. h1 tags are used for main titles, h2 tags for subtitles etc.

All pages on this site use valid mark-up. All visual styling on this site are presented using Cascading Style Sheets (CSS) and have been validated using the CSS validation service provided by the W3C.

Navigation

Navigation is made accessible using unordered lists to logically order and define menu hierarchy. Main pages (Home and What we say) have only a global navigation, and all other content pages have both a global and a left navigation.

Navigation aids

A link to the home page is available on each page. Navigation menus are marked up as HTML lists and styled with CSS. Content skips (content and search) are enabled.

JavaScript

To enhance user experience this site utilises a small amount of JavaScript. If JavaScript is disabled or your browsing software does not support JavaScript the site is still fully functional.

Flash

To enhance visual presentation of information some Flash objects are used.

Where Flash has been used to communicate information, alternative text-only versions of the same content is available on the same page or a page linked from the Flash location.

Links

Many links have title attributes, which describe the link in greater detail, (unless the text of the link already fully describes the target). Links are written to make sense out of context.

Images

All content images used in this site include descriptive ALT attributes or are commented out.

Visual design

This site uses cascading style sheets for visual layout. If your browser or browsing device does not support stylesheets at all, the content of each page is still readable. This site uses relative font sizes, compatible with the user-specified “text size” option in visual browsers.

Colour Combinations

Foreground and background colours have been used that provide a good level of contrast and therefore easy to read. Throughout the site, colour is never used as the only way to convey information.

The European Union has adopted a Regulation on wholesale energy market integrity and transparency (known as “REMIT”), which came into force on 28th December 2011. REMIT provides a market abuse framework for wholesale energy markets and, amongst other things, requires market participants to publicly disclose inside information which they possess.

It is SEFE Marketing and Trading Limited’s (“SM&T”) policy to conduct all of our business dealings professionally, fairly and with integrity and to uphold all laws and regulations wherever we operate. SM&T will use this page and any related or linked pages on its website to make REMIT public disclosures (“REMIT Public, Disclosures Pages”).

Disclaimer

SM&T take every care and precaution to ensure that information published on its REMIT Public Disclosures Pages is accurate when posted and regularly updated, but we cannot be held liable for its accuracy or timeliness, and we may change the information at any time without notice. You must not rely on information on SM&T’s REMIT Public Disclosures Pages and, in the event that you chose to use this information in any way, you acknowledge that you must take appropriate steps to verify this information before acting upon it. No warranty or representation is made in respect of the timeliness or accuracy of any information.

We reserve the right to remove, alter or amend the content or format of any information or material on SM&T’s REMIT Public Disclosures Pages without warning, and without prejudice to any other accrued rights, and/or to make available such information or material when required to do so by law or when requested to by regulatory bodies or law enforcement organisations.

SM&T  PUBLISHES THIS REMIT PUBLIC DISCLOSURE INFORMATION “AS IS” WITHOUT ANY WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, AS TO THE ACCURACY OF  SUCH INFORMATION AND SM&T  SHALL NOT BE LIABLE, EXCEPT FOR DEATH AND PERSONAL INJURY ARISING FROM OUR NEGLIGENCE OR MISREPRESENTATION, FOR ANY LOSSES OR DAMAGE, WHETHER DIRECT OR INDIRECT ( INCLUDING, WITHOUT LIMITATION DIRECT OR INDIRECT LOSS OF PROFITS), CONSEQUENTIAL, SPECIAL OR OTHERWISE INCIDENTALTHAT MAY RESULT FROM USE OF SUCH INFORMATION HOWSOEVER ARISING.

The information contained on SM&T’s REMIT Public Disclosures Pages is not an invitation to invest in shares or other securities, or any other products or services or otherwise deal in these or enter into a contract with SM&T or any other company. The information provided should not be relied upon in connection with any investment decision. You should always seek appropriate professional advice as the information published on these pages by SM&T results from SM&T’s obligations under REMIT and does not in any way constitute legal or professional advice. SM&T cannot be held liable for actions arising from its use. In addition, SM&T cannot be held responsible for the contents of any externally linked pages and it is important that you take necessary precautions, especially to ensure appropriate safety from viruses, worms, Trojan horses and other potentially destructive items.

At SEFE Marketing & Trading Ltd (SM&T) (“We”), we are committed to protecting and respecting your privacy.

As part of any recruitment process, we collect Personal Data which relates to you, the job applicant.

SM&T are transparent about how Personal Data is processed and carries out this activity in accordance with applicable Data Protection Legislations and Regulations.

This Privacy Notice (together with our Cookie Policy) sets out how we process your Personal Data. Please read it carefully.

This Privacy Notice covers:

• Data which we collect from you directly during the recruitment process;
• Data which is provided to us by a third party (for example, a recruiter, former employer or referee); and
• Data we collect from you via your use of www.sefe-mt.com (the “website“).

For the purpose of this Privacy Notice and in line with applicable Data Protection legislation related to the jurisdiction in which you reside and, the jurisdiction in which the vacancy you have applied for is located, the Data Controller is:

SEFE Marketing & Trading Ltd, a company registered in England and Wales under company number 3768267 and, whose registered address is: 20 Triton Street, London NW1 3BF.

By visiting our websites and applying for a job with us, you acknowledge the terms of this Privacy Notice and agree to our collection, use and disclosure of your Personal Data for the purposes stipulated herein in accordance with this Privacy Notice.

What Information Do We Collect About You?

We will process the following data about you during the recruitment process:

• Your name, date of birth, e-mail address, home address, phone numbers and passport or other identity documents you provide us with;
• Details of your qualifications, skills, experience and employment history (including any CV or Resume provided as part of your application), information about your current level of remuneration, including benefit entitlements and information gathered from interviews and assessments we invite you to participate in;
• Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process;
• Information about your entitlement to work in the jurisdiction where the job vacancy is advertised;
• Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief;
• Records of any correspondence we have with you. We may also monitor and record any communications we have with you, including phone conversations and emails to meet our regulatory and legal duties;
• Information that you provide by filling in application forms; and
• Details of your visits to our website recruitment page including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access;
• Where permitted by applicable law(s), we may collect information about you and update any existing information that we currently hold from other third-party sources, including publicly available data sources.

How Do We Collect Your Personal Data?

We collect your Personal Data in three main ways:

• Personal data that you give to us;
• Personal data that we receive from other sources; and
• Personal data that we collect automatically.

Personal data that you give to us

We mainly collect your Personal Data directly from you.

There are a number of ways in which you can share your Personal Data with us, including:

• When you make an application for a vacancy through our website recruitment page;
• Where you contact us proactively (for example, by phone, email or social media); or
• When you send us or submit your CV or Resume to us either by post or online.

In certain circumstances, we may process the Personal Data of third parties, such as an emergency contact or a referee. The Personal Data regarding third parties that you provide to us will be processed for the purposes of your application and to contact your next-of-kin in an emergency. Before you provide data relating to third parties to us, you should ensure you are permitted to do so and ensure that the third-party consents to our use, collection and disclosure of the third party’s personal data for the purposes stipulated herein in accordance with this Privacy Notice prior to making your application. You also confirm that you are authorised by the third party to provide such consent to us on the third party’s behalf.

Personal data we receive from other sources

We will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks.

From time to time as permitted by applicable law(s), we may collect information about you and update any existing information that we currently hold from other third-party sources, including publicly available data sources, and publicly available social networking sites such as LinkedIn and Facebook.

Personal data that we collect automatically

When you access the website recruitment page, we collect certain technical information about your device (as set out above). We use this data for statistical reporting about the website’s users browsing actions and patterns, and do not link it to any individuals.

Cookies

Our website recruitment page uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them and how to remove them see our Cookies Policy

Why Do We Collect and Process Your Information?

We process your personal data for the following reasons:

• To assess your application or to provide you with information about potential vacancies;
• To assess your qualifications for a particular vacancy;
• To verify information, we have received from third parties (for example, recruiters), or through information requests (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with applicable laws);
• To promote diversity and prevent discrimination;
• To ensure the quality and effective operation of the website;
• To provide you with information that you request from us;
• As part of the research that we conduct about our website for statistical purposes;
• For internal purposes, such as internal reviews, website and system administration, internal audits; and
• To comply with our legal and regulatory obligations.

Legal Bases for Processing Your Personal Data

There are a number of legal bases which allow us to lawfully process your Personal Data, and which may apply depending on the laws of the relevant jurisdiction:

• Where using your personal data is necessary for us to carry out our obligations under our contract with you;

In most cases, we process your data in order to enter into contracts with you relating to your employment or engagement with us.

• Where the processing is necessary for us to carry out our legal obligations;

In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant’s eligibility to work in the UK before employment starts.

• Where using your data is in our legitimate interests;

We have a legitimate interest in processing personal data during the recruitment process and in keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims. Where we rely on legitimate interests as a reason for processing data, we have considered whether or not those interests are overridden by the rights and freedoms of employees or workers and have concluded that they are not.

• Processing your special category personal data and/or criminal records data;

We process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.

Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.

For some roles, we are obliged to seek information about criminal convictions and offences. Where we seek this information, we do so because it is necessary for us to carry out our legal obligations and exercise specific rights in relation to employment.

How Long We Will Keep Your Data For?

We process and store your personal data to the extent necessary for the duration of the application process. If your application for employment is successful, your personal data will be transferred to your personnel file. The periods for which your data will be held will be as detailed in the standards on the handling of staff data policy. However, if your application for employment is unsuccessful, your personal data and/or application documents will be erased 12 months after the application process is completed.

This does not apply if your data is processed and stored in order to assert or exercise legal claims, or to defend against legal claims (duration of litigation) or we obtain separate consent from you to keep your application documents longer.

How Do We Keep Your Personal Data Secure?

• Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email);
• We use a variety of technical and organisational methods to secure your Personal Data in accordance with applicable laws;
• We are committed to protecting the security of the Personal Data you share with us. In support of this commitment, we have implemented appropriate technical, physical and organisational measures to ensure a level of security appropriate to the risk;
• We require our vendors and suppliers to keep the Personal Data that we provide to them securely, both in transit and once received by them. This includes the use of encryption methods, where appropriate.

Who Do We Disclose Your Information To?

• Sharing your data within our organisation;

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

We may also share your Personal Data with other members of our corporate group, depending on the role you have applied for.

• Sharing your data with our service providers;

We disclose information to service providers who provide services on our behalf. Your data will only be used by our third-party providers to provide the requested services to us and each service provider is subject to a set of terms consistent with this Privacy Notice. We use the following types of third-party providers to provide us with services:

1. Providers of website management and hosting services;

2. Providers of email communication tools and webinar platforms;

3. Providers of professional services, such as accountants and legal advisors, where necessary; and

4. Third-party auditors, where necessary to meet our legal and regulatory obligations;

Sharing your data with potential purchasers of SM&T or its assets.

In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.

• Sharing your data where we have a legal or regulatory obligation to do so;

If we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or to protect our rights, property, or safety, or the rights, property or safety of our customers, or others.

We will not otherwise share your data with third parties unless your application for employment is successful and we make you an offer of employment. We will then share your data with your former employers to obtain references for you, employment background checks providers to obtain necessary background checks and the relevant agency to obtain necessary criminal records checks.

Sharing Personal Data overseas

Some of our service providers and group companies are located outside of the EU, or Singapore (as the case may be).

If we share your Personal Data with those organisations, we will ensure that appropriate safeguards are in place to protect your Personal Data and that transfer of your Personal Data is in compliance with applicable data protection laws.

Where necessary, we have ensured that service providers (including other SEFE Group affiliates) sign standard contractual clauses as approved by the European Commission or other Supervisory Authority with jurisdiction over the relevant data exporter.

Your Rights

You have various rights in relation to the data which we hold about you, as described below. To get in touch with us about any of these rights, please use the contact details set out below. We will seek to deal with your request without undue delay, and in any event within any time limits provided for in applicable Data Protection law (subject to any extensions to which we are lawfully entitled).

Please note that we may keep a record of your communications to help us resolve any issues which you raise.

• Right to object;

This right enables you to object to us processing your Personal Data, if such right is provided under the data protection laws of the applicable jurisdiction.

• Right to withdraw consent;

Where we have obtained your consent to process your personal data for certain activities (for example, for marketing), you may withdraw this consent at any time and we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.

• Right of access;

You may ask us for: (a) a copy of the information we hold about you; and (b) information about the ways in which such personal data has been or may have been used or disclosed by us within a year from the date of the request, at any time. If we provide you with access to the information we hold about you, we will do so within a reasonable time and not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for doing so.

• Right to erasure;

You may have the right to request that we “erase” your Personal Data in certain circumstances, under the applicable data protection laws of the applicable jurisdiction. Normally, this right exists where:

1. The data is no longer necessary;

2. You have withdrawn your consent to us using your data, and there is no other valid reason for us to continue;

3. The data has been processed unlawfully;

4. It is necessary for the data to be erased in order for us to comply with our obligations under law; or

5. You object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so. When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.

• Right to restrict processing;

You may have the right to request that we restrict our processing of your Personal Data in certain circumstances, under the applicable data protection laws of the applicable jurisdiction. For example, if you dispute the accuracy of the Personal Data that we hold about you or you object to our processing of your Personal Data for our legitimate interests. If we have shared your Personal Data with third parties, we will notify them about the restricted processing.

• Right to rectification;

You have the right to request that we rectify any inaccurate or incomplete Personal Data that we hold about you. If we have shared this Personal Data with third parties, we will notify them about the rectification. You may also request details of the third parties that we have disclosed the inaccurate or incomplete Personal Data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

• Right of data portability;

If you wish, you may have the right to transfer your Personal Data between service providers. In effect, this means that you are able to transfer the details we hold about you to another third party, under the applicable data protection laws of the applicable jurisdiction. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you.

You may seek to exercise any of these rights by updating your information online (where possible) or by sending a written request to resourcing@gazprom-mt.com.

Right to complain

You also have the right to complain to your applicable Data Protection Authority.

If You Do Not Provide Us with Your Personal Data:

• You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

Dated 26 July 2022

At SEFE Marketing and Trading (“SM&T”), we are committed to protecting and respecting your privacy.

This policy (together with our cookie policy) sets out how we will treat your Personal Data. Please read it carefully.

This policy covers the data we collect from you via our website.

For the purpose of Data Protection regulations, the Data Controller is SM&T Limited, a company registered in England and Wales under number 3768267, whose registered address is 20 Triton Street, London NW1 3BF.

Our website may contain links to other websites which are managed by third parties (including their use of cookies). If you are a user of these links, it is your responsibility to understand how those third parties will use your data. Once you leave our website using these links, we have no control over any information which is submitted to or collected by any third parties. We are not responsible for these other websites.

What information do we collect from you and how do we collect it?

We will collect and process the following data about you:

• Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access;
• We may also collect information about your computer, which may include, your IP address, operating system and browser type, for system administration.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookies policy.

Who do we disclose your information to?

Our Service Providers

We disclose information to service providers who provide services on our behalf. Your data will only be processed by our third-party providers to provide the requested services to us, and each service provider is subject to a set of terms consistent with this Privacy Policy.

We use the following types of third-party providers to provide us with services:

• Providers of website management and hosting services;
• Providers of email communication tools and webinar platforms; and
• Third party auditors, where necessary to meet our legal and regulatory obligations

Other third parties

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may also disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• You request or authorise the disclosure of information to a third party;
• If SM&T or substantially all its assets are acquired by a third party, in which case personal data held by it about its counterparties will be one of the transferred assets; and/or
• If we are under a duty to disclose or share your personal data to comply with any legal or regulatory obligation, or in order to enforce or apply our terms and conditions of supply and other agreements; or to protect the rights, property, or safety of SM&T, our customers, or others.

Transfers of your data outside the European Economic Area  (“EEA”)

Data that we collect from you may be transferred to, stored at, and processed in destinations in the UK, within the EU and outside the EEA.

Processing will only take place where it is necessary for the purposes of the service being provided to us. We will only transfer data to the EU and outside the EEA where we have made arrangements to ensure that your data is treated securely and in accordance with this privacy policy.

Your rights 

As a data subject, you have the following rights:

• The right to be informed about the collection and the use of your personal data;
• The right to access your personal data;
• The right to have inaccurate personal data rectified or completed if it is incomplete;
• The right to erasure (to be forgotten) in certain circumstances;
• The right to restrict processing in certain circumstances;
• The right to data portability, which allows for you to obtain and reuse your personal data for your own purposes across different services;
• The right to object to processing in certain circumstances;
• Rights in relation to automated decision making and profiling;
• The right to withdraw consent at any time (where relevant).

If you have a complaint in relation to the processing of your data carried out under this privacy policy, you have the right to lodge a complaint with your local supervisory authority.

Changes to our Privacy Policy 

Any changes we may make to our privacy policy in the future will be posted on this page.

Dated 26 July 2022

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a text file which is stored on your browser or the hard drive of your computer.

INFORMATION ABOUT OUR USE OF COOKIES

Below details the type of cookies which are used on websites. We use cookies on this website to help us better understand how our visitors use and interact with our website as well as to make improvements to the user experience. Some cookies are also essential for the website to work.

Strictly Necessary Cookies

Strictly Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. Please see below a list of all the Strictly Necessary cookies we use on our website:

Performance & Analytical cookies

Performance cookies are used to monitor and assess our website’s performance. This is done by collecting data (anonymous data) on how a user navigates through our website. Analytic cookies work in a similar way; the help us collect information as to how our online services are accessed, for example, the number of users that are on our website at any given time, which parts of our site are visited and how long a user remains on our site for.

Marketing & Advertising

These types of cookies help send tailored and/or generic marketing and advertising to the user of our website through our website. They can sometimes be used to share certain types of marketing and advertising based on the user’s navigation through our website.

Dated 26 July 2022

The following data privacy information describes how and for what purpose SEFE Securing Energy for Europe Group (hereinafter also “SEFE Group” or “we”) processes the personal data of their job applicants.

Personal data is any information relating to an identified or identifiable natural person. Anonymous data, without the possibility to identify you, are not treated as personal data. We store your personal data in a safe and secure way to protect it from loss, unauthorized disclosure or access and process it in accordance with the provisions of GDPR[1] and applicable national laws.

Our Recruitment process aims at ensuring a smooth and easy process to all applicants and legal entities within the SEFE Group. This means, that for some business areas we recruit globally for all locations and legal entities to ensure a best possible outcome for both the applicants and the SEFE Group. Consequently, you may face more than one SEFE Group entity involved in and accountable for the processing of your personal data alongside your application. The respective SEFE Group company is responsible for the processing of your personal data in accordance with Art. 4 No. 7 GDPR. This means that this SEFE Group entity determines the objectives and purposes for the processing of personal data.

In addition, SEFE Group companies act under joint responsibility in organising and conducting the application process pursuant to Art. 26 of the GDPR. The companies of the SEFE Group have concluded a joint controllership agreement for this purpose. They have stipulated that SEFE Marketing and Trading Ltd. is responsible for the overall Recruitment process management, informing the data subjects and fulfilling requests regarding the rights of the data subjects pursuant to Art. 15 to 21 of the GDPR when carrying out the Group wide application procedure. However, within the scope of joint controllership, you can in principle assert your data subject rights against each of the joint controllers. For more details on your rights, please refer to section 11.

1. RESPONSIBILITY FOR DATA PROCESSING AND CONTACT DETAILS

Jointly responsible data controllers for processing personal data within the meaning of Art. 4 No. 7 GDPR for the job applications to the SEFE Group are

SEFE Securing Energy for Europe GmbH

Markgrafenstraße 23, 10117 Berlin

phone: +49 30 20195 0

email: personal@sefe-group.com

SEFE Marketing & Trading Ltd.

20 Triton St, London NW1 3BF, United Kingdom

phone: +44 207 756 0000

email: resourcing@sefe-mt.com

SEFE Energy Ltd.

20 Triton St, London NW1 3BF, United Kingdom

phone: +44 207 756 0000

email: resourcing@sefe-energy.com

WINGAS GmbH

Königstor 20, 34117 Kassel, Deutschland

phone: +49 561 99858 0

email: jobs@wingas.de

astora GmbH

Karthäuserstr. 4, 34117 Kassel, Deutschland

phone: +49 561 99858 3333

email: personal@astora.de

You can reach the data protection officer and/or our data protection team at SEFE Securing Energy for Europe GmbH, Data Protection, Markgrafenstraße 23, 10117 Berlin, or at dataprivacy@sefe-group.com.

2. TYPE OF PROCESSED DATA

We process your personal data as part of your application, in case you provide this personal data with your application documents or in the further course of the application process.

Personal data processing includes the following categories of personal data if they are necessary for the purposes set out in Section 3:

• Master data (e.g. title, last name, first name, email address, telephone number, zip code and city),
• Application data (e.g. information about previous activities in the group, period of notice, salary expectations),
• Special data categories (Art. 9 GDPR) that you voluntarily provide with your application,
• Data on your education,
• Data about your non-professional interests,
• Other data that you voluntarily provide to us as part of the application process, e.g. data contained in your application letter, CV or job references,
• Communication data: content of personal email or telephone conversations and other data that arise when we exchange data with you (e.g. when raising queries or using the contact form),
• Information on how you became aware of us or, if applicable, the name and data of the career fair through which you contacted us,
• Data on who recommended you, in the case of the internal referral scheme where employees can suggest other employees,
• Data that is needed to support the application process in IT systems (e.g. language settings, general settings, technically necessary cookies),
• Statements on data protection:
  • Consent to the processing of personal data,
  • Declarations on the revocation of a consent given by you,
  • Declarations of objection against the processing of personal data,
  • Statements on how to exercise your rights of access, rectification, erasure, restriction of processing and data portability, including the information you provide to us when exercising your rights.
• Internal applicant number,
• If applicable, job number.

In addition, if applicable and required by national legislation, we may also process other data:

• Test results or certificates (e.g. eye test, police clearance certificate).

As a rule, we do not process any personal data that we have received from third parties. However, when we work with third parties, such as head-hunters and recruitment agencies, they provide your applicant data to us.

3. COUNTRY SPECIFIC INFORMATION

In the case of application of the UK GDPR, its applicable paragraphs apply accordingly. In the scope of application of the German Federal Data Protection Act (BDSG) or the UK Data Protection Act 2018 (DPA), the relevant paragraphs apply accordingly.

4. PURPOSES OF DATA PROCESSING AND LEGAL BASIS

Our recruitment management takes place electronically via a Recruiting Management System. You can access the Recruiting Management System via a link on the job advertisement and/or our company website.

If you apply via a recruitment service provider or a job agency that places job advertisements on our behalf, your application may reach us via the recruiting portals of these partners.

We process your personal data for the purpose of receiving and assessing your application and subsequently forwarding it to the entity of the SEFE Group for which your application is most suitable. We process your personal data in compliance with and on the basis of the relevant data protection regulations, in particular the GDPR and national data protection laws:

• Processing of data relating to the employment relationship, i.e. to fulfil contractual obligations or to carry out pre-contractual measures (Art. 6 Para. 1 lit. b GDPR),
• To protect legitimate interests (Art. 6 Para. 1 lit. f GDPR),
• After your prior consent (Art. 6 Para. 1 lit. a GDPR) and/or
• To fulfil legal obligations (Art. 6 Para. 1 lit. c GDPR).

If you provide special categories of personal data in accordance with Art. 9 GDPR, data processing generally will take place on the basis of Art. 9 Para. 2 lit. b GDPR for the purpose of carrying out the obligations and exercising specific rights in the field of employment and social security and social protection law.

In detail, we process your personal data for the following purposes and on the legal basis specified in each case:

1. Application process and contract initiation including communication with you

Data or categories of data processed: Master data; application data; information on how you became aware of us; data about your education; data about your non-professional interests; other data that you voluntarily provide to us as part of the application process; communication data.

Legal basis: Art. 6 Para.1 lit. b GDPR.

2. When concluding an employment contract with us: Transfer of the data to the personnel file of the individual concerned.

This serves as a check for abuse and as a basis for the subsequent professional development of the individual concerned.

Data or categories of data processed: Master data; application data; information on how you became aware of us; data about your education; data about your non-professional interests; other data that you voluntarily provide to us as part of the application process; communication data.

Legal basis: Art. 6 Para.1 lit. b and f GDPR.

3. Assertion of legal claims and defence against legal disputes

Data or categories of data processed: Master data; any personal data that is the subject of the legal claim or dispute.

Legal basis: Art. 6 Para.1 lit. f GDPR.

4. Management of declarations of consent and revocation in relation to data privacy

Data or categories of data processed: Master data, privacy declarations.

Legal basis: Art. 6 Para.1 lit. a and c GDPR.

5. Objection management (management of objections related to data privacy issues).

Data or categories of data processed: Master data, privacy consent and objection declarations.

Legal basis: Art. 6 Para.1 lit. c GDPR.

6. Management of data subjects’ rights (handling data subjects’ requests for access, rectification, erasure, restriction of processing and data portability in order to exercise data subjects’ data protection rights).

Data or categories of data processed: Any data or category of data that is the subject of the specific request.

Legal basis: Art. 6 Para.1 lit. c GDPR, if applicable, Art. 9 Para. 2 lit. f GDPR.

7. Access management in the Recruiting Management System

Data or categories of data processed: Logging of data for security measures and ensuring appropriate measures are taken to secure your data.

Legal basis: Art. 6 Para.1 lit. f GDPR.

8. Information you voluntarily provide to us to give us a better picture of your profile

Data or categories of data processed: Any data that you voluntarily share with us.

Legal basis: Art. 6 Para.1 lit. a GDPR, if applicable, Art. 9 Para. 2 lit. a GDPR.

9. Further data processing within the framework of national legislation

Data or categories of data processed: Data that must or may be processed under national law: e.g. police clearance certificate.

Legal basis: Art. 6 Para.1 lit. c and f GDPR.

5. DATA RETENTION

We process and store your personal data for the required duration of the application process. If the application process ends without you being hired, your data and application documents will be deleted within 6 months of completing the application process. You will not be informed separately about the deletion.

Application documents submitted in paper form by post will be returned to you, as our application process is exclusively digital.

The above does not apply if your data is processed and stored to assert, exercise or defend legal claims (for the duration of the process) or if we obtain your separate consent to store your application documents for a longer period of time.

If you are hired at the end of the application process, both your personal data and your application documents will be used to draw up the employment contract and then included in your personnel file.

The data processed here is subject to various storage and documentation obligations, which result from national legal provisions, often from tax, labour and company law regulations. Finally, the storage period is also assessed according to the national statutory limitation periods.

If necessary, we process and store your personal data for the duration of the application process. This includes i.a. including the initiation and execution of a contract. In addition, we are subject to various storage and documentation obligations, which result from the national legislation, which is in Germany, among other things, German Commercial Code (Handelsgesetzbuch – HGB) and the Fiscal Code (Abgabenordnung – AO). The storage and documentation periods stipulated there are two to ten years. Finally, the storage period also depends on the statutory limitation periods, which is in Germany e.g. according to §§ 195 et seq. of the German Civil Code (Bürgerliches Gesetzbuch – BGB) as a rule three years, but in certain cases it can also be up to thirty years.

6. COOKIES ON THE WEBSITE OF THE RECRUITING MANGEMENT SYSTEM

We use the so-called cookies or similar functions on the website of our Recruiting Management System to make our website technically available. We base the processing of your data through the cookies used for the aforementioned technically necessary purposes on our legitimate interest in the efficient operation of our website pursuant to Art. 6 Para. 1 lit. f GDPR and the applicable national implementations of the EU-Directive 2002/58/EC (ePrivacy Directive), such as the German TTDSG and the UK PECR. The setting of these cookies and similar functions is absolutely necessary for the operation of the website.

The recruiting portals of our recruitment service providers may also use cookies or other tracking technologies. Further information on this processing can be found in the data protection declarations of the respective recruitment service providers, which are usually linked in the job advertisements.

7. DATA RECIPIENTS AND CATEGORIES OF RECIPIENTS

Personal data can be passed on to the following recipients and categories of recipients:

Internally, access to your data is only granted on the basis of authorization. In the case of ongoing application procedures, these are the involved business functions of the SEFE Group companies, e.g. global and local HR business partners within the Human Resources functions, interview partners and managers from the relevant business units and, if necessary, social partners (works council, possibly also representatives for severely disabled people). Our Corporate IT provides technical support and ensures the functionality of the Recruiting Management System.

We use service providers who process personal data on our behalf (so-called processors, cf. Art. 4 No. 8, Art. 28 GDPR). This includes service providers in the areas of IT, telecommunications and recruitment service providers. In these cases, we have concluded order processing agreements with the service providers.

Insofar as we are authorized to do so on the basis of contractual or legal provisions, or on the basis of consent, we also pass on the above-mentioned personal data to other companies who process the data in joint responsibility (Art. 26 GDPR). Such joint responsibility is given in the following areas

• Application process and HR,
• IT services.

In these cases, we have concluded joint responsibility agreements with these companies. The main content of these agreements on joint responsibility is the ruling on the area of responsibility in the processing of your personal data. For example, any party against whom you make a claim is responsible for settling that claim. Each party is also responsible for the lawfulness of its own data processing in relation to the organisation of the recruitment process. In addition, the agreement regulates the responsibility between the data controllers for the cases in which the data subjects exercise their rights. This relates i.a. to the right to have personal data rectified or erased or to restrict processing.

8. TRANSFER OF DATA TO A THIRD COUNTRY OR TO AN INTERNATIONAL ORGANISATION

Given the international nature of SEFE Group’s business and corporate governance, it may be necessary for an entity in a third country outside the European Union (EU) or outside the United Kingdom to have access to your personal data, or it may be necessary to transfer your personal data to an entity in a third country.

As a general rule, we do not transfer your data from to a third country or international organisation. However, should this become necessary, the transfer will only take place within the framework of valid contractual agreements or legal obligations and if the prerequisites pursuant to Art. 44 et seq. GDPR are fulfilled.

We will only transfer your personal data if

• sufficient guarantees are provided by the recipient in accordance with Art. 46 Para.1 GDPR for the protection of the personal data,
• you have expressly consented to the transfer in accordance with Art. 49 Para.1 lit. a GDPR after we have informed you of the relevant risks,
• the transfer is necessary for the performance of contractual obligations between you and us in accordance with Art. 49 Para.1 lit. b GDPR, or
• another exception from Art. 49 GDPR applies.

Guarantees according to Art. 46 GDPR can be so-called standard contractual clauses. In these standard contractual clauses, the recipient assures to sufficiently protect the data and thus to ensure a level of protection comparable to the GDPR.

A “third country” is defined as a state outside the European Economic Area (EEA) in which the GDPR is not directly applicable. A third country is considered “unsafe” if the EU Commission has not issued an adequacy decision for this state pursuant to Art. 45 Para. 1 of the GDPR confirming that an adequate level of protection for personal data exists in the country.

A transmission will only take place if an appropriate level of data protection is ensured in the third country (Art. 45 GDPR), suitable guarantees exist (cf. Art. 46 GDPR) or there is another legal permission (cf. Art. 49 GDPR) and insofar as this is necessary for processing and thus for the fulfilment of the contract or, at your request, for the implementation of pre-contractual measures, the transfer is required by law or you have given us your consent.

9. OBLIGATION TO PROVIDE DATA

As part of your application, you only have to provide the personal data required to start and carry out the recruitment process. The application process cannot be started without this data.

10. AUTOMATIC DECISION MAKING AND PROFILING

We do not use your personal data for automated decision-making, including profiling.

11. YOUR RIGHTS

Every data subject has the right to information under Art. 15 GDPR, the right to rectification under Art. 16 GDPR, the right to erasure under Art. 17 GDPR, the right to restriction of processing under Art. 18 GDPR and the right to data portability from Art. 20 GDPR. In order to exercise the aforementioned rights, you can contact the offices named under number 1.

You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data relating to you, which is based on Art. 6 Para.1 lit. f GDPR (data processing on the basis of legitimate interest). to insert this also applies to any profiling based on this provision within the meaning of Art. 4 No. 4 GDPR. If you file an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If we process your personal data in order to operate direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising. If you object to the processing for direct marketing purposes, we will no longer process your personal data for these purposes.

The objection can be made in any form and should be addressed to the offices named in section 1. You will not incur any costs other than the transmission costs according to the basic tariff.

If you have given us your consent to the processing of your personal data, you can revoke this consent at any time. As a result, we will no longer continue the data processing based on this consent for the future. The lawfulness of the processing carried out on the basis of the consent until the revocation remains unaffected.

Please address the revocation of consent to the office specified in section 1.

12. RIGHT TO COMPLAIN TO THE SUPERVISORY AUTHORITY

According to Art. 77 Para. 1 GDPR, you have the right to complain to a supervisory authority if you believe that the processing of your personal data is not lawful, in particular that it violates the GDPR. In this case, you have the choice of contacting the supervisory authority, in particular in the member state of your place of residence, your place of work or the place of the alleged violation. Irrespective of the aforementioned right to lodge a complaint, we will also accept your request ourselves (for contact details, see section 1).

[1] REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). In this document, GDPR shall always be applied and interpreted in conjunction with the applicable national legal provisions (e.g. BDSG in Germany and DPA2018 with UK GDPR in the United Kingdom).