Employee Privacy Notice

This Employment Privacy Notice applies to Olam Americas, LLC, and all subsidiaries and affiliates (collectively “ofi” or “we”).

Who We Are

ofi is a global leader in the food and agri-business industries, supplying food ingredients, feed, and fibre to thousands of customers worldwide, ranging from multi-national organizations with worldfamous brands to small family-run businesses. Our people are the most valuable part of our business and provide our greatest competitive advantage. They are the architects of our future, transforming our culture into a unifying force for our business. Six values form the foundation of our people’s diverse careers within our business: entrepreneurship, stretch and ambition to do more, partnership and long-term relationship building, mutual respect and teamwork, integrity, and ownership. We strive for all of our people to work and live by these values every day.

This Employee Privacy Notice applies to all employees of ofi who work in or for our operations in the United States, regardless of their place of residence.

ofi is sensitive to privacy issues, and it is important to us to protect the Personal Information of our employees. This Employee Privacy Notice (“Notice”) details the privacy practices of ofi that apply to your employment and operates as an extension of our general privacy policy, which can be found at https://www.ofi.com/privacy.html. ofi provides this notice to inform you about our privacy practices with respect to employment, the kinds of information we may collect, how we intend to use and share that information, how you can correct or update such information, and privacy rights that may apply. This Notice also incorporates by reference and is subject to the terms of ofi human resources and information security policies and procedures that apply to your position or office location, and which can be accessed at any time by reaching out to your local HR representative.

Definitions of Personal Information

“Personal Information” means any information relating to an identified or identifiable natural person (as opposed to a business entity); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Under specific laws, personal information may include any information relating to a household.

Information We Collect

ofi collects different types of Personal Information for employment purposes in accordance with applicable law. We collect and process Personal Information through the onboarding, employment, exit, and post-employment phases. We categorize the Personal Information as: (a) Contact Information; (b) Job Applicant Information; (c) Employment Information; (d) Employment Benefits Information; (e) Medical Information; and (f) Payment Information. Examples of actual data collected, including during the last 12 months, are provided below for each of these categories:

1. Contact Information: Full name, physical address, personal phone number, work phone number, personal email address, work email address, workplace address, social media account information, photograph, and emergency contact information.
2. Job Application Information: All information related to a job application such as resume, portfolio, education, experience, background, preferences, attributes, references, licenses, certificates, ethnicity, race, gender, residency and work permit status (if applicable), and other similar information becomes part of your employment file when you are hired. For more details about the information that we collect during the job application process, please review our Recruitment Privacy Notice, which is available through the Careers section of our website at https://www.ofi.com/careers/job-opportunities.html.
3. Employment Information: As applicable, employee name, job title, position within the company, wage, salary, bonuses, rewards, awards, performance ratings, performance reports, evaluations, complaints, investigative reports, disciplinary actions, achievements, promotional considerations, job progress, protected class, military status, work permit status, residency status, driver’s license number, Social Security number, individual tax identification number, residency number, passport number, visa number, insurance number, citizenship certificate or papers, information in forms such as the I-9 and W-4, other tax information, workplace address, voicemails, emails, correspondence, documents, other work product and communications, information captured on security systems and key card entry systems, policy acknowledgments, time entry records, sick pay, paid time off, and information about employee spouse, partner and dependents (including birthdate, phone number, Social Security number, tax identification number). Where permitted by law and applicable, this information may include the results of credit and criminal background checks, the results of drug and alcohol testing, screening, health certifications, driving license number, vehicle registration, driving history, and other verifications.
4. Employee Benefits Information: Medical insurance information, dental insurance information, vision insurance information, retirement account information, life insurance information, supplemental benefit enrollment, wellness participation, name, phone number, social security number, birthdate, bank information, account number, routing number, information about employee spouse, partner, beneficiaries and dependents (including birthdate, phone number, Social Security number tax identification number).
5. Medical and Disability information: Medical records, health statistics, medical conditions, disabilities, health assessment results, medical information about employee spouse, partner, beneficiaries, and dependents. Please note ofi complies with applicable law, including the Health Insurance Portability and Accountability Act (“HIPAA”), in the collection, processing and storage of medical and disability information. Please note, this Notice does not apply to the privacy practices of any health plan that employees are eligible to participate in through their employment. Any such health plan’s privacy practices are explained in such plan’s privacy policy.
6. Payments Information: With respect to employees issued with a corporate credit card – we will collect your name, address, birthdate, your Social Security number or a portion thereof, salary deduction authorization, bank information, account number, routing number, transaction history, card balance, and card limit.

How we Use Collected Information

We collect and process personal information for all aspects of employment and categorize these purposes as follows: (a) Employee profile; (b) payroll; (c) benefits; (d) performance; and (e) business operations.

1. Employee Profile: We maintain an employee profile for each of our employees. This profile includes Personal Information such as your name, address, phone number, email address, job title, job role, and reporting lines. This information is part of the employee personnel file. We maintain Personal Information such as emergency contacts in your profile for the purpose of communicating to a designated third person in the event of a medical emergency, natural disaster, or other event. Some employee profile information such as work location address, work phone number, and work email address is made available in the company directory, and, depending upon the job role, may be available to the general public. Additional information such as job role or reporting lines or internal organizational structure may also be made available for various company purposes. We may maintain an employee bio, which we may provide to our business partners, as an example.
2. Payroll: To process payroll involving a Direct Deposit payment method, we collect and use your bank account information, including the account name, name of your financial institution, routing number and account number. We use your Social Security number, or other tax identification number, to process the required withholding tax, payroll tax, and any otherrelevant taxes associated with your payroll. We process other information such as medical insurance account details and other pre-tax benefit deductions made as part of the payroll process. We also may be required to comply with other deductions, such as court-ordered wage garnishments and court-ordered medical enrolment, or other payroll deductions determined by regulation. We generate payroll documents such as pay-stubs, pay statements, tax statements, and letters relating to required deductions as part of the payroll process. Your Personal Information is used extensively in this payroll process.
3. Benefits: ofi offers employee benefits, including medical, dental, vision, retirement, supplemental benefits, and insurance benefits. We process your Personal Information to provide these benefits. Core benefits are offered through third-party service providers. Your Personal Information is collected and passed onto third-party administrators per benefit needs. You are also given access to employee portals administered by the third parties for direct access to general information, plan coverage, benefit details, transactions history, balances, and statements.
4. Performance: ofi processes Personal Information to record achievements and employment progress, determine performance ratings, bonuses, and awards, and to identify individuals for promotional consideration. As part of the human resources function, Personal Information will also be processed in the event of an investigation and any resulting action.
5. Business Operations: Your job role will largely determine how your Personal Information will be used. Where you are an ofi representative (e.g., sales or customer service), your business contact information may be shared as part of your interactions with customer representatives, and third-party service providers. Where required, we may use your Personal Information for registration with events, conferences, software licenses, travel, or for corporate credit card requirements. Your photograph may be published on our website (e.g., either on our intranet or internal portal or as part of a blog).

How your Personal Information is Shared

We share your personal information with the following types of recipients:

• Other employees. Some categories of your Personal Information, (e.g., name, work email, work phone number, job title) are published in a directory and shared with other employees. Your Personal Information is also shared with other employees for workplace purposes such as line reporting, team projects, and role integrations. Your Personal Information is also shared with human resources for payroll, compensation, performance assessments, promotions, and other business functions. Appropriate access to your Personal Information is restricted based upon job role. ofi operates as part of a group of entities. Your Personal Information may be shared with any of our affiliates.
• Business customers and third-party service providers. ofi’s customers and third-party service providers are key to its business operations. Business contact information, of ofi representatives is shared with our business partners, vendors, and third-party service providers.
• Other third-party service providers. We use third-party service providers to administer payroll, benefits, and other human resource functions and share your Personal Information with these service providers. For benefits such as medical insurance and retirement, your Personal Information is provided either directly by you to the third-party service provider or provided by ofi’s payroll service provider. We also use third-party service providers for services like cloud hosting, analytics or other technical tools. These service providers only process your Personal Information as directed by us. We do not sell your personal information to third parties
• Regulatory bodies and authorities, and Legal Proceedings. Your Personal Information is shared with the relevant tax authorities. In addition, your Personal Information may be shared with law enforcement, courts of law, government agencies,regulatory authorities, legal counsel, or other third parties as required by law or in order to meet our legal needs, or regulatory or contractual obligations.
• Entities associated with mergers, acquisitions and other business transfers. ofi may be part of a merger, acquisition, or other business transfer and as such, may disclose your Personal Information as part of this process.

The Categories of Personal Information that may be shared with third parties as part of these activities described above, including during the last 12 months, include:

• Identifiers such as a real name, alias, postal address, email address, unique personal or online identifier, Internet Protocol address; account name; Social Security number; driver’s license or passport number; and other similar identifiers;
• Your signature; state identification card; insurance policy number; education; employment or employment history; bank account number; credit card number (if issued a corporate credit card);medical information or health insurance information; driver’s license or passport number; and other similar identifiers;
• Characteristics of protected classifications under California or federal law;
• Internet or other electronic network activity information, including browsing history; search history; and information regarding an employee’s interaction with an Internet Website or application;
• Professional or employment-related information; and
• Inferences drawn from any of the information identified in this subdivision to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Storage of Personal Information and Data Transfers

All personal information sent or collected via or by ofi may be stored anywhere in the world, including but not limited to, the United States, the Netherlands, Singapore, France, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request.

In the case of transfers of data out of Europe, we utilize Standard Data Protection Clauses approved by the European Commission to legitimize the transfer of personal information from the European Economic Area or Switzerland to the United States and other countries. We place third-party service providers under the same contractual obligations with regard to personal data processing to ensure compliance with the EU General Data Protection Regulation.

Privacy Rights

We rely upon you to ensure we have accurate and up-to-date Personal Information on file. If you need to make a change to your Personal Information, please do so through the relevant portal or software, or alternatively, contact your representative in human resources for assistance. Where you have personal needs and/or concerns on the use and public availability of your Personal Information, we will endeavor to accommodate a request to limit the use of your Personal Information in this way.

In certain jurisdictions, individuals have rights in relation to Personal Information. Employees who are residents in the European Economic Area (“EEA”) have certain rights which may be subject to limitations and/orrestrictions. These rights include the rightto: (i)request access to and rectification or erasure oftheir personal data; (ii) obtain restriction of processing orto object to processing oftheir personal data; and (iii) ask for a copy of their personal data to be provided to them, or a third party, in a digital format. If you wish to exercise one of the above-mentioned rights, please send us your request to the contact details set out below. Employees in the EEA also have the right to lodge a complaint about the processing of their personal data with their local data protection authority.

Please direct all inquiries relating to your Personal Information to the Human Resources Department or through the contact details provided at the end of this policy

Data Retention

The retention of Personal Information varies greatly depending upon the purpose of collection, who controls the Personal Information, and regulatory requirements. To better describe how retention may apply to your Personal Information, we categorize your Personal Information by purpose as follows: (a) employee profile; (b) payroll; (c) benefits; (d) performance; and (e) business operations.

1. Employee profile. Your Personal Information is retained as part of your employee profile for the duration of your employment with ofi. At the end of your employment, we retain your employee profile in its entirety for ten years if you are employed in the United States, and for a minimum of four years if you are employed at any otherlocation. We then maintain a limited profile and retain this information for an appropriate time period.
2. Payroll. Your Personal Information, including financial account information is used to process your salary. Personal Information associated with your profile necessary for operating payroll, such as yourfinancial account information, social security number ortax identification number, is retained for the duration of your employment. At the end of your employment, we retain all relevant information for ten years if you are employed in the United States, and for a minimum of four years if you are employed at any other location. Personal Information utilized in each payroll transaction is retained indefinitely as part of that payroll transaction. Pay-stubs, pay statements, and tax statements are retained for an appropriate time period.
3. Benefits. ofi uses third-party service providers to administer employee benefits. While ofi selects the third-party service providers for benefits such as medical, retirement, and life insurance, each employee will be registered with the third-party service provider independently. These third-party service providers determine the retention of Personal Information processed for their respective services. Employees will be required to contact the relevant service provider for inquiries related to the use and retention of their Personal Information.
4. Performance. Forthe duration of your employment, ofi processes information related to yourjob performance, including: achievements, performance reports, performance ratings, complaints, investigations, disciplinary actions, bonuses, stock awards, awards, and promotional considerations. This information is retained for a minimum of ten years following your termination and may be retained for a longer time period, depending upon legal considerations.
5. Business operations. As an employee, depending upon your job role, your business contact information may be shared with our customers, hackers, and third-party service providers. Personal Information may also be published on our website. Your Personal Information will be retained in alignment with the retention practice for each specific business operation; the following are examples:
   • Email communication: Personal Information used in email communication is retained until the email is deleted by the individual or per our standard email deletion process.
   • Employee badge: Your Personal Information (e.g., your first and last name and your photograph) may be used to issue an employee badge for security and identification purposes. If you have been issued this type of employee badge, at the end of your employment, the employee badge is returned to us and the badge is physically destroyed. Your employment status on your employee profile is updated and retained as part of a limited employee profile for ten years.
   • Non-employee information: Employees can store non-employee information on workplace laptops and devices. As an employee, you are responsible for complying with our policies on use of workplace laptops and devices. You may have chosen to store Personal Information that is unrelated to work on workplace laptops and devices. While ofi reserves the right to monitor the use of all workplace laptops and devices, it allows the storage of non-workplace data that complies with its policies. At the end of employment, ofi expects the employee to remove any non-workplace data from the workplace laptops and devices and then return the equipment. ofi then performs its standard data cleanse process, removing and destroying personal data and resetting the workplace laptops and devices for future business use.
   • Personal items: ofi allows its employees to decorate their workstations and employees frequently choose to do so with personal items thatinclude Personal Information. Atthe end of employment, the employee is expected to clean their workstation and remove any personal items. Any items left behind and not claimed within a reasonable time period (3 working days) that include Personal Information will be destroyed.

Security of Your Personal Information

ofi uses technical and organizational measures to protect the Personal Information that we store, transmit, or otherwise process against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. We regularly consider appropriate new security technology and methods as we maintain and develop our software and systems.

Contact Information

If you would like to contact us with questions or inquiries about this Employee Privacy Notice, exercise your privacy rights, or raise any concerns, you may contact us via any of the following methods:

In-person: Speak directly with your line manager or your local HR representative

Email: privacy@ofi.com

Website: https://www.ofi.com/contact-us.html

Toll-free number (USA): (833) 718-1023

Mailing Address:

Attn: Human Resources Department

Olam Americas, LLC

205 East River Park Circle

Suite 310

Fresno, CA 93720