Policy:

CONSTANTINOU GROUP OF COMPANIES is committed to protecting the right to privacy of its customers, employees, and business partners. As such it is our policy that the collection, security, quality, use and disclosure of information shall be conducted in accordance with relevant Privacy Legislation and Regulations.

Procedure:

CONSTANTINOU GROUP OF COMPANIES “Privacy Statement” is as follows:

“Other than as required by Federal and/or State/Province Legislation and/or in cases of emergency, CONSTANTINOU GROUP OF COMPANIES shall ensure that any personal or business-related information obtained by our organization from employees, customers, partner organizations or any other third party is, without exception, utilized solely for the purpose of conducting business and interaction between CONSTANTINOU GROUP OF COMPANIES and any other party involved.

Under no circumstances shall the information be knowingly provided to any external party without written permission from all parties involved.”

Information relating to external parties shall be obtained by lawful means only and shall be limited to information required to enable business interaction between the parties.

CONSTANTINOU GROUP OF COMPANIES will take reasonable steps to ensure that our Privacy Policy is public and that all customers and other relevant entities are aware of the above statement.

Private information relating to third parties shall be managed in accordance with the requirement of the “Australian Privacy Protection Principles” and all applicable Papua New Guinea legislation, generally in accordance with the following:

Customer Information:

Customer Information is collected to enable CONSTANTINOU GROUP OF COMPANIES to provide quality service. It may range from general information (e.g., address and telephone number) to more sensitive information including, but not limited to the following:

Customer business practices.

Customer financial status and credit checks.

General information about the status of an individual’s business.

Details of the products and services provided by the customer.

Personal details of the addresses and telephone numbers of business owners and managers; and

Relevant requirements and preferences are specific to the customer.

Provided that no legitimate reasons to the contrary exist at the time, all information relating to a customer that is held by CONSTANTINOU GROUP OF COMPANIES will be maintained in a way that it is unavailable to any third party, but available to the customer upon request for perusal and /or update of information.

Employee Information:

Employee Information is collected to enable CONSTANTINOU GROUP OF COMPANIES to recruit efficiently and effectively, train, manage and ensure the safety of employees. Information collected in relation to employees shall include but is not limited to:

Employee information is required to be maintained in accordance with relevant legislation.

Information is relevant to the work content and performance of an employee.

Performance feedback (whether positive or negative); and

Information relating to Workplace Health and Safety and an employee.

Provided that no legitimate reasons to the contrary exist at the time, personal information relating to employees shall be maintained as confidential information. Each employee shall be permitted access to information being held in relation to him or her and his or her employment with CONSTANTINOU GROUP OF COMPANIES for the purpose of perusal and/or update.

Partner Organizations and other Third Parties:

Information maintained shall be held solely for reasons relating to the conducting of business by either CONSTANTINOU GROUP OF COMPANIES, the third party or both.

Provided that no legitimate reasons to the contrary exist at the time, any third party with information held by CONSTANTINOU GROUP OF COMPANIES shall be allowed access to the information for the purpose of perusal and/or update.

Grievances:

Any party wishing to lodge a complaint in relation to the management of private information by CONSTANTINOU GROUP OF COMPANIES may lodge the complaint verbally or in writing with CONSTANTINOU GROUP OF COMPANIES management.

All complaints will be thoroughly investigated according to our internal procedures and processes and a response will be forwarded to the complaining party within a reasonable timeframe

Direct Marketing:

CONSTANTINOU GROUP OF COMPANIES may from time to time elect to use private information to market services directly to customers and potential customers. This information will be used only by the CONSTANTINOU GROUP OF COMPANIES and shall not be disclosed to any third party for the purposes of direct marketing conducted by that party.

Any third party who wishes to be excluded from receiving direct marketing information from CONSTANTINOU GROUP OF COMPANIES should advise our organization so that arrangements can be made to remove that party from our marketing listing.

Responsibility:

It is the responsibility of CONSTANTINOU GROUP OF COMPANIES to ensure that employees are familiar with this policy and procedure and to provide a written Privacy Statement to persons and entities involved with the organization as required.

It is the responsibility of all employees on a day-to-day basis, in everything that they do in the workplace, to ensure that their activities comply with this policy.

Failure by any employee to comply with the requirements of this Policy shall result in disciplinary action that may include termination of employment.