Compliance and ethics guidelines
Human rights and working conditions
PPM High Purity Metals GmbH respects and observes human rights at every level of the organization.
organizational level. Any kind of discrimination based on gender, age, origin or nationality, mental or
physical nationality, mental or physical disability, sexual orientation, religious or political views or trade
union political views or trade union involvement is prohibited. Ignorance and inaction are no justification
justification for any kind of discrimination. Therefore, any violation of human rights and discrimination will
not be tolerated. Any moral, sexual or generally unlawful attempts at intimidation, bullying intimidation,
bullying, harassment and victimization are prohibited. We ensure equal opportunities for all in terms of with
regard to career and work opportunities, working relationships and job offers. The human resources management
and employee relations are based on the principles of mutual trust and respect. mutual trust and respect, which
ensures that every employee is treated with the natural level of dignity. In compliance with local regulations,
trade union union independence and the pluralistic organization of industrial relations, a social dialogue is
conducted with the employee social dialog is conducted with employee representatives. It goes without saying
that the company and its employees comply with the applicable rules on employee privacy.
Data protection
Data is only collected and stored by PPM High Purity Metals GmbH to the extent that necessary for
the smooth running of the business, health and environmental protection and the fulfillment of legal
requirements is necessary.
The company reserves the right to make data available to external service providers if this is necessary for
the provision of the services. The data provided for this purpose is reduced to a minimum. reduced to a
minimum.
The data collected will not be used commercially by anyone other than the company. In particular, the
company excludes the forwarding of collected data to third parties for advertising purposes.
Further details on the handling of your data can be found in our
Privacy policywhich
is available for download here.
Prevention of crime
When working for PPM High Purity Metals GmbH, all employees must comply with the criminal laws of the
countries in which the the criminal laws of the countries in which the Group operates. Employees who work on
behalf of employees working on behalf of the company must comply with the criminal laws of the countries in
which the Group operates. discretionary powers to third parties (where this is permitted), they must ensure
that the persons appointed are well informed and are aware of their obligation to comply with applicable laws
and company policies.
Employees acting on behalf of the Company shall refrain from any involvement in any alleged or actual
criminal conduct. All employees must be sufficiently aware of the criminal laws laws and regulations applicable
to their area of work so that they can identify or prevent potential risks and recognize and recognize in which
cases (namely financial, environmental or safety issues) legal advice is required. or safety issues) legal
advice is required. Employees of PPM High Purity Metals GmbH who have questions or doubts regarding compliance
with criminal laws or regulations for a proposed intended activity in one of the companies should immediately
contact their superiors or the management. management.
Bribery and corruption
Directly or indirectly secret or undocumented payments or accounts are not permitted under any
circumstances. permitted under any circumstances.
Direct or indirect payments and expenditures for purposes unrelated or only partially related to the
supporting documents for these transactions will not be authorized or made. transactions will not be authorized
or made.
Activities and transactions on behalf of PPM High Purity Metals GmbH, are to be carried out in compliance
with the applicable regulations and internal procedures, must be fully, accurately and truthfully recorded in
the company's books.
Employees who record accounting data are responsible for the accuracy of the data recorded and must ensure
that each entry is properly documented. All transfers of funds require employees to be particularly
conscientious and vigilant with regard to the identity of the recipients and the recipients and the intended
use of the transfer.
Competition violations
All employees of PPM High Purity Metals GmbH are obliged to comply with the applicable laws and regulations
concerning antitrust violations. This applies regardless of their validity in in Germany or abroad. In
connection with violations of competition law, the misconduct of a single employee may employee, his or her
direct supervisors, the management and the company may be involved in difficult and costly administrative or
legal proceedings, including injunctive relief, high fines and, in some jurisdictions, imprisonment in the
worst case.
With regard to competition law infringements, the laws and regulations are based on the principle that free
competition without any collusion between competitors best serves the public interest. The participation in
agreements or arrangements in violation of applicable laws and regulations, namely in the area of
anti-competitive area of anti-competitive behavior are therefore strictly prohibited.
In particular, agreements, arrangements or procedures with the aim of
- to fix, directly or indirectly, prices, discounts or conditions of sale;
- to restrict or control production, technical development or investment;
- divide markets, customers or sources of supply among themselves;
- to tend to treat business partners unequally, to impose conditions on them that are contrary to
commercial practice or to refuse to do business with them for unlawful reasons.
- refuse to deal with them.
If, in the course of their work, employees of the Company are in doubt as to whether they are complying with
regulations in connection with anti-competitive behavior, they are required to contact the management
immediately. to contact the management immediately.
Privacy Policy
1. An overview of data protection
General information
The following information will provide you with an easy to navigate overview of what will happen with your
personal data when you visit this website. The term “personal data” comprises all data that can be
used to personally identify you. For detailed information about the subject matter of data protection, please
consult our Data Protection Declaration, which we have included beneath this copy.
Data recording on this website
Who is the responsible party for the recording of data on this website (i.e., the
“controller”)?
The data on this website is processed by the operator of the website, whose contact information is available
under section “Information about the responsible party (referred to as the “controller” in
the GDPR)” in this Privacy Policy.
How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for instance be information
you enter into our contact form.
Other data shall be recorded by our IT systems automatically or after you consent to its recording during
your website visit. This data comprises primarily technical information (e.g., web browser, operating system,
or time the site was accessed). This information is recorded automatically when you access this website.
What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data
may be used to analyze your user patterns. If contracts can be concluded or initiated via the website, the
transmitted data will also be processed for contract offers, orders or other order enquiries.
What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients, and purposes of your archived
personal data at any time without having to pay a fee for such disclosures. You also have the right to demand
that your data are rectified or eradicated. If you have consented to data processing, you have the option to
revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to
demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the
right to log a complaint with the competent supervising agency.
Please do not hesitate to contact us at any time if you have questions about this or any other data
protection related issues.
2. Hosting
We are hosting the content of our website at the following provider:
IONOS
The provider is the IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany (hereinafter referred to as:
IONOS). Whenever you visit our website, IONOS records various logfiles along with your IP addresses. For
details, please consult the data privacy policy of IONOS: https://www.ionos.de/terms-gtc/terms-privacy.
We use IONOS on the basis of Art. 6 (1)(f) GDPR. Our company has a legitimate interest in presenting a
website that is as dependable as possible. If appropriate consent has been obtained, the processing is carried
out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the
storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting)
within the meaning of the TDDDG. This consent can be revoked at any time.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website visitors
only based on our instructions and in compliance with the GDPR.
3. General information and mandatory information
Data protection
The operators of this website and its pages take the protection of your personal data very seriously. Hence,
we handle your personal data as confidential information and in compliance with the statutory data protection
regulations and this Data Protection Declaration.
Whenever you use this website, a variety of personal information will be collected. Personal data comprises
data that can be used to personally identify you. This Data Protection Declaration explains which data we
collect as well as the purposes we use this data for. It also explains how, and for which purpose the
information is collected.
We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications)
may be prone to security gaps. It is not possible to completely protect data against third-party access.
Information about the responsible party (referred to as the “controller” in the GDPR)
The data processing controller on this website is:
PPM High Purity Metals GmbH
Hoppenstedter Straße 6
38835 Osterwieck
Phone: +49 (39421) 691-0
E-mail: info@ppmhpm.com
The controller is the natural person or legal entity that single-handedly or jointly with others makes
decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail
addresses, etc.).
Storage duration
Unless a more specific storage period has been specified in this privacy policy, your personal data will
remain with us until the purpose for which it was collected no longer applies. If you assert a justified
request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other
legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in
the latter case, the deletion will take place after these reasons cease to apply.
General information on the legal basis for the data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or
Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of
explicit consent to the transfer of personal data to third countries, the data processing is also based on Art.
49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end
device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The
consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the
implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR.
Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of
Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest
according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in
the following paragraphs of this privacy policy.
Designation of a data protection officer
We have appointed a data protection officer.
Torben Bues
Wagenerstraße 14
30169 Hannover
Phone: 0511 93688170
E-mail: datenschutz@ppmhpm.com
Recipients of personal data
In the scope of our business activities, we cooperate with various external parties. In some cases, this
also requires the transfer of personal data to these external parties. We only disclose personal data to
external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to
do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure
pursuant to Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of this data. When using
processors, we only disclose personal data of our customers on the basis of a valid contract on data
processing. In the case of joint processing, a joint processing agreement is concluded.
Revocation of your consent to the processing of data
A wide range of data processing transactions are possible only subject to your express consent. You can also
revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of
any data collection that occurred prior to your revocation.
Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21
GDPR)
IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY
TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS
ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING
OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER
PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY
GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF
THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1)
GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO
OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS
ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR
PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART.
21(2) GDPR).
Right to log a complaint with the competent supervisory agency
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory
agency, in particular in the member state where they usually maintain their domicile, place of work or at the
place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other
administrative or court proceedings available as legal recourses.
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment
of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand
the direct transfer of the data to another controller, this will be done only if it is technically
feasible.
Information about, rectification and eradication of data
Within the scope of the applicable statutory provisions, you have the right to demand information about your
archived personal data, their source and recipients as well as the purpose of the processing of your data at
any time. You may also have a right to have your data rectified or eradicated. If you have questions about this
subject matter or any other questions about personal data, please do not hesitate to contact us at any
time.
Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data
is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies
in the following cases:
- In the event that you should dispute the correctness of your data archived by us, we will usually need
some time to verify this claim. During the time that this investigation is ongoing, you have the right to
demand that we restrict the processing of your personal data.
- If the processing of your personal data was/is conducted in an unlawful manner, you have the option to
demand the restriction of the processing of your data instead of demanding the eradication of this
data.
- If we do not need your personal data any longer and you need it to exercise, defend or claim legal
entitlements, you have the right to demand the restriction of the processing of your personal data instead
of its eradication.
- If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be
weighed against each other. As long as it has not been determined whose interests prevail, you have the
right to demand a restriction of the processing of your personal data.
If you have restricted the processing of your personal data, these data – with the exception of their
archiving – may be processed only subject to your consent or to claim, exercise or defend legal
entitlements or to protect the rights of other natural persons or legal entities or for important public
interest reasons cited by the European Union or a member state of the EU.
SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or
inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption
program. You can recognize an encrypted connection by checking whether the address line of the browser switches
from “http://” to “https://” and also by the appearance of the lock icon in the browser
line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.
Rejection of unsolicited e-mails
We herewith object to the use of contact information published in conjunction with the mandatory information
to be provided in our Site Notice to send us promotional and information material that we have not expressly
requested. The operators of this website and its pages reserve the express right to take legal action in the
event of the unsolicited sending of promotional information, for instance via SPAM messages.
4. Recording of data on this website
Server log files
The provider of this website and its pages automatically collects and stores information in so-called server
log files, which your browser communicates to us automatically. The information comprises:
- The type and version of browser used
- The used operating system
- Referrer URL
- The hostname of the accessing computer
- The time of the server inquiry
- The IP address
This data is not merged with other data sources.
This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate
interest in the technically error free depiction and the optimization of the operator’s website. In order
to achieve this, server log files must be recorded.
Request by e-mail, telephone, or fax
If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name,
request) will be stored and processed by us for the purpose of processing your request. We do not pass these
data on without your consent.
These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of
a contract or is required for the performance of pre-contractual measures. In all other cases, the data are
processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art.
6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be
revoked at any time.
The data sent by you to us via contact requests remain with us until you request us to delete, revoke your
consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request).
Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.
5. Online-based Audio and Video Conferences (Conference tools)
Data processing
We use online conference tools, among other things, for communication with our customers. The tools we use
are listed in detail below. If you communicate with us by video or audio conference using the Internet, your
personal data will be collected and processed by the provider of the respective conference tool and by us. The
conferencing tools collect all information that you provide/access to use the tools (email address and/or your
phone number). Furthermore, the conference tools process the duration of the conference, start and end (time)
of participation in the conference, number of participants and other “context information” related
to the communication process (metadata).
Furthermore, the provider of the tool processes all the technical data required for the processing of the
online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type,
operating system type and version, client version, camera type, microphone or loudspeaker and the type of
connection.
Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the
servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant
messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using
the service.
Please note that we do not have complete influence on the data processing procedures of the tools used. Our
possibilities are largely determined by the corporate policy of the respective provider. Further information on
data processing by the conference tools can be found in the data protection declarations of the tools used, and
which we have listed below this text.
Purpose and legal bases
The conference tools are used to communicate with prospective or existing contractual partners or to offer
certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally
simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art.
6(1)(f) GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this
consent; the consent may be revoked at any time with effect from that date.
Duration of storage
Data collected directly by us via the video and conference tools will be deleted from our systems
immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the
data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal
retention periods remain unaffected.
We have no influence on the duration of storage of your data that is stored by the operators of the
conference tools for their own purposes. For details, please directly contact the operators of the conference
tools.
Conference tools used
We employ the following conference tools:
Microsoft Teams
We use Microsoft Teams. The provider is the Microsoft Ireland Operations Limited, One Microsoft Place, South
County Business Park, Leopardstown, Dublin 18, Ireland. For details on data processing, please refer to the
Microsoft Teams privacy policy: https://privacy.microsoft.com/en-us/privacystatement.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is
an agreement between the European Union and the US, which is intended to ensure compliance with European data
protection standards for data processing in the US. Every company certified under the DPF is obliged to comply
with these data protection standards. For more information, please contact the provider under the following
link: https://www.dataprivacyframework.gov/participant/6474.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website visitors
only based on our instructions and in compliance with the GDPR.
