1. PURPOSE AND ACCEPTANCE

This disclaimer governs access to, browsing and use of the website http://www.alsider.com/ (hereinafter called the Website), owned by ALSIDER S.A. (hereinafter called the Website Owner).

On browsing this Website you are considered as a User of same. This implies full, unreserved acceptance of all the provisions of this disclaimer, which may be modified or replaced by the owner at any time without prior notice. If you, the User, disagree with this disclaimer as a whole or in part, you should refrain from using the Website.

You, the User, undertake to use this Website correctly, in compliance with the law, public order, good faith and all the provisions of this disclaimer. You, the User, are answerable to the Website Owner and to third parties for any damage that may be cuased by your failure to comply with this obligation.

The Website Owner reserves the right to modify the presentation, configuration and content of the Website and the conditions for access to/use of same. Any access to or use of the content of the Website after the entry into force of the modifications is considered as acceptance of same.

2. IDENTIFICATION

Under Article 10 of Act 34/2002 of 11 July on Services for the Information Society and Electronic Commerce (LSSI), you are informed as follows:

ALSIDER S.A. is a company whose registered address is C/ Ercilla, 19 5ª (48009 BILBAO). Its tax ID nº is C.I.F. A48490031 and it is duly entered in the mercantile register VIZCAYA at volume BI262, folio 55, sheet BI1262A; Inscription 1ª.

Communications with the Website Owner are considered effective when they are sent to the postal address indicated or to the following e-mail address infoalsider@erhardt.es

3. ACCESS & REGISTRATION

Access to and browsing on the Website are free of charge and registration is not required. However, the Website Owner may require registration for a customer area or the completion of a form before some of the services offered can be used.

All information provided by the User via the forms on the Website must be true and should be kept up to date. Responsibility for any consequences, errors or faults caused by falsehoods in data lies with the User.

The User undertakes to safeguard and make proper use of the user name and password required to access certain services on the Website. The Website Owner accepts no liability for any harm to Users or third parties that arises as a result of other persons using the password of a User with or without the knowledge and/or consent of the User. The Website Owner undertakes to maintain due secrecy in regard to the passwords registered by Users, and not to disclose them to any third party except in compliance with a compulsory disclosure order from judicial or administrative authorities.

4. INTELLECTUAL & INDUSTRIAL PROPERTY RIGHTS

The Website Owner is also the owner of or the holder of the relevant licences to the intellectual and industrial property rights pertaining to the use of the Website and the intellectual and industrial property rights to the information, materials and contents thereon. In no case may access to, browsing on or use of the Website by the User be deemed to entail any renunciation, transfer, licensing or assigning of all or any part of those rights by the Website Owner.

The User holds only the right of strictly private use of the contents and/or services of the Website. The Website Owner is not liable for the way in which each User uses the materials made available via the Website or for any action based thereon.

All references to brands, trade names and other distinguishing marks owned by the Website Owner or by third parties entail an implicit prohibition on their use without the consent of the Website Owner or their lawful owners.

All intellectual and industrial property rights pertaining to the contents and/or services of the Website are reserved, and it is specifically prohibited to change, copy, reproduce, communicate publicly, convert or distribute any part of the contents of the Website via any medium and in any form for public or commercial purposes without the express prior consent in writing of the Website Owner or of the owner of the relevant rights, as the case may be.

5. LINKS TO OTHER WEBSITES

The Website Owner informs you, the User, that if the Website contains links to other websites via buttons, banners or embedded content, such content is managed directly by third parties. The Website Owner has neither the personnel nor the technical resources to obtain prior knowledge, control and/or approve all the information, contents, products and services featured by other websites to which links may be posted on this Website.

The Website Owner therefore declines all liability for any issues concerning other websites to which links may be posted on the Website. Responsibility for reading and agreeing to the terms and conditions of use and privacy policies published on websites and applications to which links are posted lies with you, the User.

6. CONDITIONS OF USE OF THE WEBSITE

The Website must not be accessed or used for unlawful or unauthorised purposes, for financial ends or otherwise. Liability for the consequences of such actions lies exclusively with you, the User. Actions specifically prohibited include, but are not limited to, the following:

1. Using the Website to introduce, store or spread programs, data, viruses, codes or any other electronic or physical device liable to cause harm to it in any service or on any item of equipment, system or network of the Website Owner, of any other User and of third parties in general.
2. Registering on the Website under a false name or by supplanting the identity of a third party.
3. Obtaining unauthorised access to any section of the Website, any server of the Website Owner and to the services offered via the Website by means of piracy, falsification, password theft or any other unlawful method.
4. Taking any action that results in a disproportionate or unnecessary overloading of the Website infrastructure or the systems or networks of the Website Owner.
5. Failure to abide by these requirements may be grounds for the Website Owner to take such measures as may be available in law against you, the User.

7. LIABILITIES & WARRANTIES

The contents of this Website are general in nature and are provided for purely informational purposes. The Website Owner cannot fully guarantee access to all contents, or the reliability, usefulness or truthfulness of every item of information and/or all the services on the Website. Nor can it be guaranteed that the documentation made available to Users of the Website is current or up-to-date.

The Website Owner therefore provides no assurances and accepts no reliability in regard to: (i) the continuity of the Website contents; (ii) the absence of errors in those contents; (iii) the absence of viruses and/or other harmful components on the Website or on the server that hosts it; (iv) that the Website is in vulnerable to attack and/or to breaches of its security measures; (v) the usefulness or performance of the contents of the Website; and (vi) any damage or harm caused to themselves or to others by persons who infringe the terms and conditions, rules and instructions of the Website or breach the security systems of the Website.

However, the Website Owner declares that it has taken all necessary measures within its possibilities and given the state-of-the-art to ensure that the Website will work and minimise system errors from a technical aspect and in terms of the contents published on the Website.

In any event, the Website Owner reserves the right to suspend, modify, restrict or interrupt access to the Website temporarily or indefinitely, with or without prior notice. Users may not claim any compensation in this regard.

8. PRIVACY POLICY & COOKIES

Pursuant to the current legislation applicable to the protection of personal data, all personal data are provided during the use of the Website will be processed as provided for in the Privacy Policy, which you, the User must read, understand and accept in order to use the Website.

The Website uses cookies (small data files sent by the server to the devices of persons who access the Website) for the proper operation and displaying of the contents of the Website for Users. For more information see our Cookies Policy.

9. LEGISLATION AND JURISDICTION APPLICABLE.

The clauses of this disclaimer are governed by Spanish legislation. The parties hereto expressly submit to the courts and tribunals of BILBAO for the settling of any dispute, waiving any other jurisdictional rights that they may be entitled to claim.

The Website of ALSIDER S.A. (http://www.alsider.com/) uses cookies to enhance your browsing experience. This Cookie Policy seeks to inform you clearly and accurately about the cookies used on the Website.

1. WHAT ARE COOKIES?

Cookies are small data files downloaded on to the devices of users when they access a website. They enable the site owner to store information on visits such as preferred language, country, access credentials and other options. Cookies are also used to measure audiences and website traffic parameters.

The cookies used on this Website are associated solely with anonymous users and their devices, and do not in themselves provide any personal data on users. Cookies play a highly important role and help to make the browsing experience better for users.

2. TYPES OF COOKIES USED

Cookies may be broken down into own and third-party cookies, depending on who manages the domain from which cookies are sent and how the data obtained are processed.

Cookies may also be classed as session or persistent cookies according to how long they are stored on the user's browser.

Finally, cookies may be classed as technical, personalisation, analytical, advertising and behavioural advertising cookies depending on the purposes for which the data obtained are processed.

The Website Owner may use own technical cookies for which there is no need to seek your consent, given that they are excluded from the area of application of Article 22.2 of Act 34/2002 of 11 July on Services for the Information Society and Electronic Commerce.

However, this Website also installed cookies that require user consent. Information on those cookies can be found below:

Third-party cookies may also be installed if you, the user, share any content from the Website on social media. Such cookies are installed by the social media platforms where the content is shared, so it is advisable to visit the websites of the relevant platforms to learn more about them.

3. MANAGING COOKIES

You are hereby informed that you may accept or reject the use of cookies on the Website and may revoke consent given at any time by changing the configuration of cookies on the Website via the pop-up window in the browser. You may also permit, block or delete third-party cookies installed on your computer via your browser. Bear in mind that if you disable all cookies some contents and functions of the Website may be affected. The operation required differs from one browser to another. Check the "Help" tab to learn more.

• Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
• FireFox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies
• Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Safari: https://support.apple.com/en-us/guide/safari/sfri11471/mac
• Microsoft Edge: https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy

ALSIDER S.A. will process data on a confidential basis, with all the legal and security assurances required under the General Data Protection Regulation (EU Regulation 2016/679), hereinafter called the GDPR, Framework Act [Ley Orgánica] 3/2019 of 5 December on the Protection of Personal Data and Assurance of Digital Rights, Act 34/2002 of 11 July on Services for the Information Society and Electronic Commerce and all other applicable current Spanish legislation.

1. IDENTIFICATION

• Owner: ALSIDER S.A.
• Headquarters C/ Ercilla, 19 5ª (48009 BILBAO).
• Tax ID nº A48490031.

To assure proper processing of your data, ALSIDER S.A. has designated a Data Protection Officer (DPO), whom you may contact at the following address: dpd@erhardt.es.

2. INFORMATION & CONSENT

By agreeing to this Privacy Policy you, the User, accept that you have been duly informed and freely give your duly informed, specific, unequivocal consent for the personal data that you provide via the Website at the URL http://www.alsider.com/ (hereinafter called the Website) to be processed by ALSIDER S.A.. This also covers the data derived from your browsing and such other data as you may provide in the future.

3. OBLIGATION TO PROVIDE DATA

You are only obliged to provide personal data via the forms or email address of the Website when they are signposted as compulsory, or when they are required to fulfil the purpose of the query made. In such cases, failure to provide data correctly or at all means that the said purposes cannot be met, even though you may still be able to view the contents of the Website freely.

4. PURPOSES FOR WHICH USERS' PERSONAL DATA WILL BE PROCESSED ON THE WEBSITE

Personal data provided via the form or any messages sent to the email address of the Website will be processed for the purposes of managing the query submitted, sending information on products or services about which Users have expressed an interest and/or providing services requested.

5. WEBSITE USER DATA PROCESSED

The type of personal data obtained from Website Users and processed to deal with their queries, send them the commercial information requested and provide the services requested are identity details (full name), contact data (email address) and such other date as may be provided by Users themselves in the open "message" fields.

Users are responsible for providing accurate data and keeping same up to date. You, the User, undertake that if you provide any third party data you will do so with the consent of the relevant party, and will pass on to same the information contained in this Privacy Policy, so that the Website Owner is held harmless from any liability in regard thereto. However, the Website Owner may conduct checks from time to time to ensure this, adopting such due diligence measures as may be relevant in line with data protection regulations.

6. LAWFUL BASIS FOR THE PROCESSING OF USER DATA

The lawful basis for the processing of your personal data provided to the Website is your express consent as the data subject (Article 6.1.a of the GDPR) as you voluntarily send your personal data to the email address provided and/or mark the OK box on the form. You thereby give your lawful consent for your personal data to be processed for the purposes of this Privacy Policy.

Your data will be processed on the basis of the performance of the contract if the queries submitted via the Website imply the application at your request as the data subject of pre-contractual measures.

The lawfulness of the commercial messages concerned with services or products similar to those requested or contracted lies in the lawful interest of the data controller.

7. PARTIES WITH WHOM USER DATA MAY BE SHARED

The personal data provided may be passed on for the purposes indicated above to other member companies of the Erhardt Group, or to firms cooperating in the provision of services for the management of the contractual relationship sought by you, the User.

8. DATA CONSERVATION

Your personal data and information will be held for as long as necessary to fulfil the purposes for which they were obtained, and to cover any claims or liabilities that may arise as a result of the processing of the said data.

In general, once the query has been dealt with or the service has been provided, data will be blocked and will not be processed further, though they will remain available to the public authorities and the courts in regard to potential liabilities resulting from data processing. Once the statutory period of limitation has elapsed, they will be deleted. However, for data processing in which no liabilities arising from same need be taken into consideration, ALSIDER S.A. will delete the data at the end of the time required to ensure proper completion of the purposes for which they were obtained.

9. EXERCISING OF RIGHTS

You, the User, may at any time write to the postal address indicated in the heading of this policy document or to the email address dpd@erhardt.es, attaching a photocopy of your ID document, to revoke the consent given, to obtain confirmation of whether your personal data are being processed, to access your personal data, to correct wrong or incomplete data, to request the deletion of your personal data when they are no longer needed for the purposes for which they were obtained, to have their processing restricted if the conditions envisaged in data protection regulations are met, to request the portability of the data that you provided and to bring any concerning the protection of your personal data before the competent supervisory authority.

10. SECURITY MEASURES.

User data will at all times be processed with the utmost confidentiality, maintaining the necessary duty of secrecy in regard to same as envisaged in the applicable regulations. To that end, the necessary technical and organisational measures will be taken to assure the security of your data and prevent any alteration, Los, unauthorised access or processing thereof, taking into consideration the state-of-the-art, the nature of the data stored and the risks to which they are exposed.

1. Alsider

Expert management of steel.
Alsider is the leading company in the distribution of steel plates in the Iberian Peninsula. With more than one hundred years of experience, the company integrates steel trading, risk management, stock management and logistics distribution from its operating centers in Bilbao, Cartagena, La Coruña and Portugal.

2. The management system

Alsider has developed a management system that includes concepts such as social responsibility, quality, environmental issues, sustainability, energy efficiency, health and safety at work, industrial and information security, supply chain security, IT services, innovation and risks.

The management system of Alsider is firmly based on controlling and managing risks in all relevant areas.

The Management Committee of Alsider has established the policies listed below as a benchmark for constructing the management system and a basis for goals.

At Alsider we undertake to maintain and continuously improve our management system. We are all responsible for meeting the requirements set out in the management system and those laid down in law and in the regulations applicable in each case.

Management system policies are made known to and are binding on all employees. They are also available to our suppliers and subcontractors to sign up to, and to any other individual or organisation that may request them.

3. Policies

3.1. Social Responsibility Policy

At Alsider we strive to achieve growth that is sustainable in financial, social and environmental terms. Our goal is to provide high-quality services as we strive responsibly and efficiently to foster financial growth and create value for our customers, shareholders, employees, collaborating firms, public administrations and society as a whole, encouraging the development of the social setting in which we operate and using the natural resources required for our operations in a rational manner.

In line with this social responsibility policy, we commit to:

• Setting up responsible hiring practices in an effort to create jobs and combat social exclusion.
• Fostering behaviour conducive to health and safety at work among our employees and monitoring contractors more closely in health and safety matters.
• Encouraging greater awareness and sensitivity among our employees to our environmental impacts.
• Complying with the principles set out in the UN Global Compact.

3.2. Occupational Health & Safety Policy

WE ARE COMMITTED TO YOUR SAFETY

Alsider sees health and safety management as a priority, strategic factor in achieving corporate results. It is a key factor in corporate leadership, and is based on the following points:

Commitment

To safeguard the health and welfare of the employees of Alsider and provide safe, healthy working conditions so as to prevent injuries and damage to health. This commitment is inalienable, so Alsider factors it into its operations and takes all necessary measures to ensure that it is fulfilled.

To foster a culture of prevention as the basis of the corporate culture, making health and safety an individual responsibility that conditions the future of the company and encouraging consultation and engagement on the part of employees.

Principles

People are our organisation’s most valuable asset, and there is nothing more important than their health and safety.

In all operations, nothing should have greater priority than people’s health and safety. All tasks must be planned and implemented with safety in mind.

Safety is the responsibility of every individual at Alsider, but especially of the senior management and of those who manage groups of people. As such it needs to be managed.

Accidents arising from management failures can be avoided by eliminating hazards and reducing risks.

All provisions of law and other regulations to which the company subscribes voluntarily must be complied with.

Attitude

Everyone at Alsider must be aware of and take on board their functions and responsibilities in matters of health and safety.

This policy is known to everyone at Alsider and is public knowledge, which means that it is available to anyone who requests it.

Health and safety management is based on a process of continuous improvement, with specific goals set for the purpose.

3.3. Quality Policy

Throughout its history, Alsider has proved capable of meeting the various challenges posed by the market and of developing and providing effective solutions to address the requirements of its customers.

Our idea of helping customers in their businesses is to identify how things should be. For Alsider this means teamwork and a challenge; for customers, it means tailor-made solutions.

Believe, Create, Grow is the motto that represents our corporate philosophy.

Because only together, with the commitment and effort of each and every one of us, can we take our overall project forward. To grow we must create and to create we must believe; and in this there is only one recipe for success: work, work and more work. That is our commitment.

3.4. Environmental Policy

Alsider seeks to provide services for its customers in line with their needs and to be competitive on the market in which it operates while incorporating criteria of sustainable development, efficient resource management, environmental protection and respect for the demands of society.

Accordingly, we have published the principles that make up our environmental policy:

1. To meet the requirements of law regarding the environment and environmental requirements applicable to our operations and to the services that we provide.
2. To inform our suppliers, including contractors, of our environmental requirements and urge them to adopt environmentally-friendly practices.
3. To reduce our environmental impacts, including water and energy consumption, emissions into the atmosphere and improper waste management. This is the core task in our environmental management policy.
4. To encourage environmental protection and the prevention of pollution as a major responsibility that entails ensuring compliance with benchmarks suitable for our operations.
5. To continuously improve the efficiency of the management system so as to improve the environmental performance of the organisation.

Protecting the environment means that everyone at the organisation must behave responsibly, as required by current circumstances.

3.5. Safety & Security

At Alsider we see safety and security as integral aspects that must be factored into a risk analysis to ensure that each threat is addressed using the right resources so as to set mitigation mechanisms in place to reduce risks.

We therefore document, implement, maintain and continually improve our safety and security procedures so as to determine what measures need to be applied in each case.

Safety Policy

Effective safety must involve protective measures to prevent unauthorised access to facilities.

That is why at Alsider we have decided to implement safety measures including procedures to control access to our facilities by employees, suppliers, visitors and vehicles.

Information Security Policy

In knowledge-based societies, information is a strategic asset for organisations.

At Alsider we know how important it is to identify and protect our information assets to prevent the unauthorised destruction, disclosure or use of any information concerning customers, suppliers, strategies, management and other matters.

We are therefore committed to protecting our information resources at Alsider and to implementing the technology needed to safeguard against internal and external threats to the confidentiality, integrity, availability, lawfulness and trustworthiness of that information.

Personal Data Protection Policy

We undertake to exercise due diligence in processing all personal data to which we may have access.

All persons who have access to personal data are under obligation to comply with the provisions of the security document (which sets out technical and organisational measures consistent with the security regulations in force).

We provide the means for anyone who wishes to exercise their rights in law in regard to personal data on them which we process as controllers to do so.

Supply Chain Security Policy

At Alsider our priority is to draw up the best solutions for every customer who wishes to obtain a safe, efficient supply chain.

To that end, we seek to factor security management fully into the trading operations conducted in the supply chain.

At Alsider we are a transport and logistics platform operator. As such we undertake to provide all-round service in an effective, trustworthy, safe manner at all points in the supply chain, to help combat the main criminal activities that threaten operations (theft, smuggling, fraud, etc.), to ensure that we have personnel committed to using safe practices and safety/security parameters that foster the trustworthiness required to prevent the risks entailed by any irregular or suspicious activity.

3.6. Policy on Continuity of Operations and Availability of Information Systems

On the basis of good practices in continuity of operations and availability of information systems, this policy seeks to ensure the following:

• That there is a documented Continuity/Availability Plan in place (hereinafter called “the Plan”) to protect Alsider, its associates, customers, employees and resources against all threats, be they internal or external, deliberate or unintended.
• That all activities concerned with the Plan are carried out in an orderly, coordinated, consistent fashion.
• That the Plan is suited to the size, complexity and nature of the organisation and covers changing business needs at all times.
• That the management environment required to maintain the effectiveness of the Plan is set up.
• That the Plan is reviewed at least once a year to ensure that its provisions comply with the requirements agreed in all circumstances, from business as usual to serious loss of service.
• That the Plan is tested whenever there is a major change in the business environment.
• That the Plan is underpinned by back-up copies as established in the internal procedures of the organisation.