Our policies reflect a commitment to ethics, transparency, safety, and continuous improvement.
Privacy & Personal Data Protection Policy
1. Introduction
In accordance with Article 15 of the Political Constitution of Colombia, which states: "All persons have the right to their personal and family privacy and to their good name, and the State must respect them and make them respected. Similarly, they have the right to know, update, and rectify information that has been collected about them in databases and archives of public and private entities. In the collection, processing, and circulation of data, freedom and other guarantees enshrined in the Constitution shall be respected."
In accordance with Law 1581 of 2012, regulated by Decree 1377 of 2015, Decree 1074 of 2015, added by Decree 255 of 2022, S&J FULL SERVICES S.A.S., identified with Tax ID (NIT) 814000064-4, whose main domicile is in the Municipality of Orito – Putumayo, in its commitment to guarantee and protect the fundamental rights of employees and, in general, of the various persons who supply personal data to the company, adopts this personal data policy, regulated by the aforementioned norms and other concordant regulations governing the matter.
2. Objective
The main objective of this policy is to inform the general public of their fundamental right to have the personal information supplied to S&J FULL SERVICES S.A.S. processed in accordance with the guidelines established in current regulations.
Furthermore, to make known the guidelines established by the company to data subjects for the collection, storage, use, circulation, deletion, and rectification of information held under the custody of the company.
3. Data Controller
S&J FULL SERVICES S.A.S., identified with NIT 814000064-4, with principal address at KM 0.7 ZONA INDUSTRIAL VIA ECOPETROL, Municipality of Orito – Putumayo, email: sjfs@sjfs.com.co.
Therefore, S&J FULL SERVICES S.A.S., as data controller, delegates personal data processing to the Quality Department, which will be responsible for ensuring compliance with this policy and for handling Inquiries, Complaints, Claims, and Petitions submitted by data subjects or those authorized by law, pursuant to Law 1581 of 2012.
4. Key Definitions
In the development of this policy, key concepts shall be interpreted pursuant to definitions from Law 1581 of 2012, transcribed below:
- Authorization: Prior, express, and informed consent of the Data Subject to carry out the Processing of personal data.
- Personal Data: Any information linked or that can be associated with one or more specific or determinable natural persons.
- Habeas Data: Fundamental right providing that all persons have the right to personal privacy, good name, and to know, update, and rectify information collected about them in databases and archives of public/private entities (Sentence T - 238 of 2018).
- Data Controller: Natural or legal person, public or private, that by itself or in association with others, decides on the database and/or the Processing of data.
- Data Subject: Natural person whose personal data is subject to Processing.
- Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation, or deletion.
5. Sensitive Data
Pursuant to Law 1581 of 2012, sensitive data is that which affects the privacy of the Data Subject or whose misuse may generate discrimination. Thus, these data may only be processed by S&J FULL SERVICES S.A.S. when authorized by law or with explicit written consent from the Data Subject.
6. Rights of Data Subjects
Pursuant to Article 8 of Law 1581 of 2012, the Data Subject shall have the following rights:
- a) Know, update, and rectify their personal data before S&J FULL SERVICES S.A.S. This right may be exercised against partial, inaccurate, incomplete, fragmented data, or data whose processing is prohibited/unauthorized.
- b) Request proof of the Authorization granted to S&J FULL SERVICES S.A.S., except when explicitly exempted by law.
- c) Be informed by S&J FULL SERVICES S.A.S., upon request, regarding the use given to their personal data.
- d) Submit complaints to the Superintendency of Industry and Commerce for violations of current data protection laws.
- e) Revoke authorization and/or request data deletion when constitutional and legal principles are not respected in the Processing.
- f) Access personal data that has been subject to Processing.
7. Authorization of the Data Subject
Prior written consent must be supplied by the Data Subject for personal data processing. The Data Subject may revoke authorization at any time via a claim, provided there is no legal or contractual duty to remain in the database.
8. Exceptions to Authorization
Authorization is not required in the following cases:
- • Information required by a public/administrative entity in exercise of legal duties or by court order.
- • Data of a public nature.
- • Medical or health emergency cases.
9. Duties of the Controller
S&J FULL SERVICES S.A.S. shall comply with the duties established in Article 17 of Law 1581 of 2012, including guaranteeing full habeas data rights, conserving proof of authorizations, storing data under security protocols, and updating/rectifying information timely.
10. Purpose of the Information
S&J FULL SERVICES S.A.S., as data controller, shall use information exclusively for authorized purposes aligned with its corporate purpose.
INTEGRATED HSEQ MANAGEMENT POLICY
S&J FULL SERVICES S.A.S as a company providing Engineering Services, Onshore Freight Transport, and WorkOver for the Oil and Gas sector, is committed from Senior Management to the promotion and protection of safety, occupational health, and well-being of all our collaborators, process quality, respect for the environment, and promotion of corporate social responsibility.
Senior Management Guidelines
From senior management, the following guidelines are established applicable to employees, suppliers, contractors, and other stakeholders:
- Comply with legal, regulatory, and other requirements subscribed by the Organization in Quality, Occupational Health and Safety, Environment, and Corporate Social Responsibility.
- Maintain and continuously improve the standards and requirements of the Integrated HSEQ Management System.
- Allocate and support the economic, physical, and technological resources required to fulfill objectives, targets, and proposed activities for the Integrated HSEQ Management System.
- Actively contribute to a work environment that promotes professional growth, health, and well-being of all stakeholders through transparent communication and commitment to corporate values.
Priority Objectives
To achieve these guidelines, the following priority objectives are established:
- Seek increased satisfaction in meeting requirements of interested parties such as clients, suppliers, subcontractors, communities, workers, and shareholders.
- Maintain and continuously improve the Integrated HSEQ Management System, ensuring resource availability to achieve its effectiveness.
- Identify hazards, evaluate and assess occupational health and safety risks, establishing respective controls to minimize risks.
- Promote quality of working life under safe working conditions, strengthening healthy lifestyles focused on preventing work incidents/accidents, property damage, personal injuries, health deterioration, and occupational diseases.
- Promote the preservation, protection, and care of the environment through optimization, sustainable use of resources, pollution prevention, and responsible waste disposal; minimizing socio-environmental impacts of our operations toward cleaner production under renewable energy parameters and climate change adaptation.
- Guarantee technical competence and professional promotion of our staff.
- Promote worker consultation and participation in the Integrated HSEQ Management System.
- Strengthen safety culture knowledge, generating well-being for workers and extending it to their family unit and community.
- Foster corporate social responsibility with employees, families, and community, seeking well-being, healthy coexistence, and contribution to human rights protection.
NO ALCOHOL, TOBACCO, AND PSYCHOACTIVE SUBSTANCES POLICY
S&J FULL SERVICES S.A.S, led by General Management and aimed at fostering well-being, maintaining a healthy and safe environment for all employees, committed to the company's image and quality, supported by Resolution 2400/79 Ch. III Art. 3 literal f, Decree 1295/94 Ch. X Art. 91 literal b; determines that under no circumstances is working under the influence of Alcohol or Hallucinogenic Drugs allowed, as it poses a high risk to self-health, coworkers, people, and physical plant.
At S&J FULL SERVICES S.A.S, consumption, possession, and/or sale of intoxicating beverages, tobacco, and hallucinogenic drugs at workplace or working under their effects is strictly prohibited.
Control Measures, Testing, and Sanctions
Failure to comply with this Policy leads to application of Internal Work Regulations provisions, with full authority to remove the employee from facilities to avoid unsafe acts, incidents, or accidents.
The company reserves the right to conduct random, unannounced testing for alcohol and drugs on employees, following the signed AUTHORIZATION AND INFORMED CONSENT FOR ALCOHOL AND PSYCHOACTIVE SUBSTANCE TESTING.
Prevention and Awareness Strategies
- Conduct awareness and education sessions on preventing consumption of alcohol, tobacco, electronic nicotine delivery systems (ENDS), non-nicotine delivery systems (ENNDS), and psychoactive substances (PAS).
- Disseminate physical, social, economic, and psychological effects of substance consumption to all workers.
- Design and implement promotion and prevention actions to decrease workplace risk factors.
Additional Guidelines
- Reporting Violations: Employees are encouraged to report any suspected violation to their immediate supervisor or HR Department confidentially without retaliation.
- Support Resources: The company will provide information on employee assistance programs and external addiction resources.
- Prescription Medications: Employees taking prescribed medications affecting safe job performance must inform their supervisor.
WORKPLACE HARASSMENT PREVENTION AND CONTROL POLICY
S&J FULL SERVICES S.A.S is a company committed to complying with all laws, decrees, resolutions, and other regulations issued to promote a healthy, safe, and appropriate work environment for its workers, as well as those aimed at regulating the approach to gender-based violence, workplace and sexual harassment, or acts of discrimination[cite: 3]. The Company has the firm purpose of implementing, driving, and executing all actions aimed at its prevention within its scope[cite: 3].
For the company, it is a priority to promote courteous, respectful, and dignified treatment of all people, carrying out activities aimed at generating collective awareness and creating and maintaining a favorable workplace environment under fair and impartial conditions for the development of daily tasks, seeking at the same time to foster workers' self-fulfillment[cite: 3].
Therefore, conscious of the importance of establishing mechanisms to prevent conduct involving gender-based violence, workplace and sexual harassment, or discrimination, S&J FULL SERVICES S.A.S maintains a Workplace Coexistence Committee with the active participation of employees, fulfilling Resolution 2646 of 2008, Ministry of Social Protection Art. 14 items 9 and 1.7, and Resolutions 652 and 1356 of 2012[cite: 3]; this committee will provide the necessary tools to protect employees against psychosocial risks affecting their health or dignity and will be guided by the procedures in the company's internal regulations[cite: 3].
All workers and other stakeholders have the right to work in an environment free from all forms of discrimination and behaviors that may be considered harassment, coercion, or disturbance[cite: 3]. Therefore, S&J FULL SERVICES S.A.S commits to providing the means to promote mutual respect among colleagues, prevent workplace harassment in all its modalities, and defend the right of all workers to be treated with dignity; gender-based violence, workplace and sexual harassment are rejected at their core, in all modalities and forms, regardless of who the victim or offender is, or their hierarchical rank[cite: 3].
Institutional Commitments
In accordance with the above, S&J FULL SERVICES S.A.S commits to[cite: 3]:
- Train employees on topics related to gender-based violence, workplace and sexual harassment, psychosocial risk, conflict management, communication, and interpersonal relations[cite: 3].
- Promote a healthy, safe, and appropriate work environment through techniques that exclude behaviors that could constitute workplace harassment, always striving to promote dignity and health for every collaborator in the company[cite: 3].
- Implement and monitor compliance with standards aimed at preventing any behavior implying gender-based violence, workplace and sexual harassment, safeguarding collected information, and giving timely processing to complaints regarding workplace harassment submitted to the WORKPLACE COEXISTENCE COMMITTEE[cite: 3].
Legal Framework
- Political Constitution of Colombia[cite: 3]
- Law 1010 of 2006[cite: 3]
- Law 776 of 2002[cite: 3]
- Law 1482 of 2011[cite: 3]
- Decree 1295 of 1994[cite: 3]
- Resolution 2013 of 1986[cite: 3]
- Resolution 2646 of 2008 (Prevention)[cite: 3]
- Resolution 652 of 2012 and its amendment 1356[cite: 3]
- Circular 026 of 2023[cite: 3]
- Substantive Labor Code[cite: 3]
- Colombian Criminal Code[cite: 3]
- Internal Work Regulations[cite: 3]
- Those that modify and regulate related standards[cite: 3].
Our Values
Our values are founded on[cite: 3]:
- Respect[cite: 3]
- Responsibility[cite: 3]
- Safety[cite: 3]
- Commitment[cite: 3]
- Compliance[cite: 3]
Declaration of Senior Management Commitment
The senior management of S&J FULL SERVICES S.A.S firmly commits to preventing and managing workplace harassment, declaring that no form of harassment will be tolerated within the company[cite: 3]. Failure to observe this policy may result in the application of corresponding disciplinary measures and sanctions[cite: 3]. Any person involved in behavior constituting workplace harassment or violating this policy will be subject to investigation in accordance with applicable legal provisions, Internal Work Regulations, and internal procedures[cite: 3].
This Policy will be published, disseminated, and updated whenever deemed relevant and will also be attached as an annex to the Company's Internal Work Regulations[cite: 3].
ROAD SAFETY POLICY
S&J FULL SERVICES S.A.S, providing Engineering, Freight Transport, and WorkOver services, commits to protecting life on the roads and allocating physical, technological, financial, and human resources for the Strategic Road Safety Plan (PESV).
Senior Management Commitments
- Comply with National Transit Code regulations (Law 769 of 2002 and Law 1383 of 2010).
- Employ qualified personnel for vehicle operations.
- Implement training in defensive driving, adverse weather driving, first aid, and traffic sign compliance.
- Enforce strict monitoring of mission vehicles to prevent road incidents.
- Prohibit driving under fatigue, illness, or influence of alcohol/drugs/drowsy medication.
- Promote active breaks, avoiding continuous driving over 8 hours (maximum 12-hour workday).
- Prohibit smoking and mobile phone usage while driving.
- Enforce strict compliance with speed limits and permanent seatbelt usage for all occupants.
- Maintain vehicle preventive maintenance programs, regular driving license verifications, and clear incident reporting procedures.
Obligatoriness and Compliance
All direct collaborators and sub-contracted drivers must comply with road safety norms. Failure to comply with the Strategic Road Safety Plan will result in administrative measures under Internal Labor Regulations.