ENERGY POLICY

By implementing and certifying an LVS EN ISO 50001:2018 energy management system, Arbo Windows Ltd. undertakes to:

- use available resources rationally and sustainably;
- strive for increasingly energy-efficient work processes;
- ensure compliance with and fulfil the energy legislation requirements of both the European Union and the Republic of Latvia;
- support the purchase of energy-efficient products and services;
- inform employees, take into account their suggestions and knowledge in addressing energy issues;
- train employees in energy-efficient labour practices;
- provide the necessary resources to achieve the set objectives;
- regularly review progress and set new targets to improve energy management;
- integrate energy policy into all processes.

QUALITY POLICY

The quality policy of SIA “ARBO WINDOWS” focuses on:

- Understanding and fulfilling the client's wishes;
- Developing and improving the company;
- Achieving the company's mission and goals.

The quality policy and its implementation are based on the following key principles:

For clients

- To offer responsive and professional support to clients during project coordination and ordering;
- To ensure the delivery of a high-quality finished product within the promised time frame;
- To manufacture products in accordance with the construction regulations of target export countries;
- To independently improve and supplement the product range;
- To communicate with clients on an ongoing basis.

For employees

- To provide opportunities to improve and develop their professional knowledge and competence;
- To provide a safe and comfortable working environment;
- To provide support in the performance of work, to make the responsibilities of each employee more understandable;
- To promote unity and cohesion in achieving the set objectives;
- To make each employee accountable for his or her actions and the quality of work, remembering that the objectives are common and that together we build the image and reputation of the company;
- To ensure that the production process is carried out according to the established technologies and instructions.

For the enterprise system

- Developing and improving the quality management system;
- Using resources efficiently and reducing pollution;
- Increasing the speed and efficiency of production;
- Defining the interactions among production processes.

ENVIRONMENTAL POLICY

Introduction and Objectives

ARBO Windows is committed to sustainable development, continuous improvement and responsible business practices. Caring for the environment is an integral part of corporate responsibility and sustainable development. ARBO Windows has implemented an environmental management system in all areas of the company business. The purpose of this environmental policy is to set out the main guidelines and framework for relevant policies and activities within the company.

Scope

This environmental policy applies to the manufacture of wooden windows, doors and double-glazed windows.

Policy Guidelines

- Everyone at ARBO Windows is responsible for our contribution to protecting the environment. We meet our legal obligations. We ensure that we have the competence and skills needed to fulfil our environmental responsibilities. Our employees are aware of the environmental aspects of their work, the potential impacts and the necessary actions.
- We are continuously improving our environmental performance. We know our environmental impact at every stage of our operations. We aim to minimize the adverse environmental impacts of our activities, at all stages and throughout the life cycle of our products and services. To improve our contribution to environmental protection and energy efficiency, we develop our products and labour methods in line with the principles of sustainable development and continuously improve them. When designing production processes, we make sure they are as efficient as possible to protect the environment! We are improving our own and our partners' environmental knowledge.
- We use all our resources responsibly. We use wood residues and by-products for heating.

PRIVACY POLICY

SIA “Arbo Windows” (hereinafter – Arbo Windows) respects your privacy and is committed to protecting thereof.

This Privacy Policy provides information on how Arbo Windows collects, processes, stores, shares, erases and protects the personal data of individuals, thereby ensuring that personal data is processed lawfully, fairly and in a transparent manner.

This Privacy Policy applies to:
• natural persons – Customers (including potential, former and existing Customers), as well as third parties involved in the provision of services to a Customer;
• visitors to Arbo Windows production plants or sales offices, including those subject to video surveillance;
• visitors to the website maintained by Arbo Windows.

Personal Data Processing Controller

The controller of personal data processing is SIA “Arbo Windows”, reg. No.: 50103451301 , legal address: Kustes dambis 32, Ventspils, LV-3601, telephone: +371 25443666 (hereinafter –“Arbo Windows”), website: arbowindows.lv

Personal Data Processor

Arbo Windows processes personal data of natural persons to the extent and in the manner prescribed and permitted by the laws and regulations of the Republic of Latvia and the European Union.

Applicable laws and regulations:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data;
• Personal Data Processing Law (6 June 2018).

Your information will not be disclosed to third parties unless we have received your express consent or disclosure is required by law.

Purposes of data processing

Data is collected for specific, explicit and legitimate purposes and is not further processed in a manner incompatible with those purposes.

Personal data is collected for the following purposes:
• customer identification and preparation of offers;
• drawing up, conclusion, supplementation, renegotiation and termination of the contract;
• customer service;
• provision of services (fulfillment of contractual obligations);
• commercial purposes;
• handling and processing objections;
• measuring customer satisfaction;
• administration of settlements;
• maintenance and improvement of the website;
• personnel management;
• business planning and analytics;
• other specific purposes, of which the Customer is informed upon providing the relevant data to Arbo Windows.

Duration of storage of data

Arbo Windows stores personal data of natural persons for no longer than is reasonably necessary for the purposes for which the personal data in question is processed. Time limits for the storage of personal data are determined on the basis of applicable laws and regulations or the legitimate interests of the company. At the end of the specified period, the personal data shall be destroyed.

Our legitimate interests are the development and quality assurance of our products, ensuring compliance with our internal rules and legislation, promoting our products, protecting the legitimate interests of the company, improving the quality of customer service, and informing the public about our activities.

Data security

We use a variety of security technologies and procedures to ensure that personal data can only be accessed by authorized persons and to prevent unauthorized disclosure or use of personal data.

Access of third-country subjects to personal data

Arbo Windows provides the procedures required by laws and regulations to ensure the processing of personal data and a level of protection equivalent to that required by the Regulation.

Your right to rectification and updating

You have the right to request us to rectify or update your personal data, as well as to stop processing it, if, after getting acquainted with the personal data we process, you have found that the data is incorrect, outdated, incomplete, unlawfully processed or no longer necessary for the purpose of collection.
If you wish to review, rectify, update or otherwise change the information you have provided to us, or if you wish to prohibit us from managing it, please contact us at info@arbowindows.lv.

Information about cookies

A cookie is a small text file which is sent to your computer or mobile device when you visit a website and which the website places on your computer or mobile device when you access the website. On each subsequent visit, the cookie is sent back to the originating website or to another website which recognizes the cookie. Cookies act as a memory for a particular website, allowing that website to remember your computer on subsequent visits, including cookies which remember your preferences or improve user experience. Depending on the functions performed and the purpose of use, Arbo Windows uses strictly necessary, functionality, and analytical cookies.

The Arbo Windows website uses cookies which allow the website to:
• remember your screen settings, such as text size, language;
• remember whether or not you have consented to our use of cookies on this website;
• analyse the intensity of visits to the website from certain geographical regions.

Cookie information is not transferred for processing outside the European Union and EEA.

Accepting and disabling cookies

When visiting the Arbo Windows website, the user is presented with a window indicating that cookies are being used on the website. By closing this message window, the user confirms that he or she has read the information about cookies, their purposes and accepts them. Accordingly, the legal basis for the use of cookies is the user's consent.

The security settings of each web browser allow the restriction and deletion of cookies. However, it should be noted that the use of strictly necessary and functionality cookies cannot be refused, as the full use of the website cannot be ensured without them.

Should Arbo Windows update this policy, any changes will be published on the Arbo Windows website www.arbowindows.lv, in the “Privacy Policy” section.

WHISTLEBLOWING PROCEDURE

Based on the Whistleblowing Law, which entered into force on 1 May 2019. The purpose of the Law is to promote whistleblowing on violations in public interests and ensure the establishment and operation of whistleblowing mechanisms, and also due protection of whistleblowers.

Whistleblower – a natural person who provides information on a possible violation which may harm the public interests if the person considers this information to be true and it has become known to him or her while fulfilling the work duties or establishing legal relations related to the fulfilment of work duties.

A whistleblower is entitled to blow the whistle especially on the following violations:
• failure to act and negligence of officials, or abuse of the official position by them;
• corruption;
• fraud;
• squandering of financial resources or property of a public person;
• tax avoidance;
• public health threat, food safety threat, construction safety threat, environmental safety threat, labour safety threat, public order threat;
• infringement of human rights;
• violation in the field of public procurement;
• violation in the financial and capital market sector;
• violation of competition law.

The following is not regarded to be whistleblowing:
• deliberate provision of false information;
• disclosure of information containing the official secret;
• reporting only on infringements of personal interests;
• anonymous whistleblowing reports;
• whistleblowing by a legal person

The contact person for whistleblowing at SIA ARBO Windows is:
Accountant Sintija Gūtmane, tel. 28355734, e-mail: aw@arbowindows.lv

The following methods are available for submitting a whistleblowing report:
• in paper form, indicating “Whistleblower’s Report” on the envelope, sent to the legal address of SIA ARBO Windows: Kustes dambis 32, Ventspils, LV-3601;
• electronically to the e-mail address: aw@arbowindows.lv.

The whistleblower's report must contain the following information:
• description of the violation by providing particular facts;
• information regarding such natural or legal persons who may be reasonably considered as being involved in committing the violation;
• whether the information regarding the violation has been obtained while fulfilling the work duties or establishing legal relations related to the fulfilment of work duties;
• information on whether this violation has been previously reported.

Action taken in the event of receiving a whistleblower's report:
• the conformity of the report with the criteria determined for whistleblowing is evaluated within __ days;
• within 3 days of recognition/non-recognition of the whistleblower's report, a reply is sent to the submitter;
• in cases where additional information is required to evaluate the report, the whistleblower will be contacted by the person responsible for matters related to whistleblowing;
• a reply letter will be sent to the whistleblower on the outcome or progress of the whistleblower’s report within two months after the recognition of the whistleblower's report.

Within seven days after receiving a report, the competent institution in whose competence the report falls examines it to determine whether it is a whistleblower's report. Within three days of the decision to recognise/not recognise the report as a whistleblower’s report, a reply letter is sent to the submitter.

If further information is required for the examination of the report, the submitter will be contacted by the institution's contact person responsible for matters related to whistleblowing or the person responsible for the examination of the report.

Within two months from the date on which the report is recognised as a whistleblower's report, the submitter will be informed of the outcome of the examination or, if the examination has not yet been completed, of the progress of the examination of the report, subsequently informing the submitter on the outcome of the examination as well.

Detailed information on whistleblowing can be found at www.trauksmescelejs.lv