Biometric handling policy

INFORMATION ON THE COLLECTION, RETENTION, AND DESTRUCTION OF EMPLOYEE BIOMETRIC INFORMATION

Dywidag Systems International, USA has adopted this policy to address how it will collect, use, store, disclose and destroy biometric information, including any fingerprint information. This policy is intended to promote compliance with state and federal laws, including the Illinois Biometric Information Privacy Act (collectively, the "Laws"). Dywidag reserves the right to amend this policy at any time, with or without advance notice.

As an employee of the Dywidag, you may be required as a condition of your employment to provide your handprint and/or fingerprint ("Biometric Identifier"). Your Biometric Identifier will be used only for work-related purposes in accordance with the Laws, including for door entry/access, timekeeping, payroll or similar purposes. All affected employees will be required to execute a Biometric Waiver From, which acknowledges receipt and agreement to the terms of this policy, and consent to Dywidag's use and disclosure (or redisclosure) of his or her Biometric Identifier for such work-related purposes, and, in certain instances, in the course of workplace investigations by Dywidag or other legal authorized searches.

Dywidag has undertaken measures to safeguard all personal information connected to the Biometric Identifier to minimize the risk of fraud or identity theft, and it is understood that Dywidag will use the same reasonable standard of care in the storage, transmission, disclosure, and protection of the Biometric Identifier as it does in the storage, transmission, and protection other confidential and sensitive employee information.

Dywidag's use of the Biometric Identifier is limited to lawful purposes, which primarily include controlling or limiting access to biometric equipment (the "Equipment") and related data to authorized personnel. In accordance with the applicable Laws, Dywidag does not sell, lease, trade or otherwise profit from a Biometric Identifier. In addition, Dywidag will not disclose an employee Biometric Identifier unless: (1) the disclosure completes a financial transaction requested or is authorized by the employee; (2) the disclosure is required by state or federal law, or municipal ordinance; (3) the disclosure is required pursuant to a valid warrant or subpoena; or (4) the employee otherwise consents to the disclosure. Any Biometric Identifier will be stored and used by Dywidag during the course of employment, and for an additional period of time thereafter in accordance with the applicable Laws.

Any Biometric Identifier will be permanently destroyed no later than two years following the employee's date of separation from Dywidag or when the initial purpose for collecting or obtaining the Biometric Identifier has been satisfied, whichever occurs first.

Dywidag will take reasonable steps in an effort to ensure that its payroll provider and/or any other vendor who receives or may have access to the Biometric Identifier complies with this Policy.