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FMC Corporation
Privacy Statement—Human Resources Data

Translated copy

FMC Corporation (“FMC”) complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union (“EU”) member countries and Switzerland. This Privacy Statement applies solely to human resources Personal Data maintained, processed, or controlled by FMC regarding individuals in the context of their engagement with FMC as employees or contractors. Specifically, this Privacy Statement applies to the collection and use of Personal Data obtained from FMC and FMC affiliate and subsidiary employees or contractors located in the European Union or Switzerland that may be transferred to the United States.

    For the purposes of this Privacy Statement, “Personal Data” is information:

  • about a specific employee or contractor of FMC Corporation or employee or contractor of an FMC affiliate or subsidiary company with regard to his or her engagement with FMC who is employed in the EU or Switzerland,
  • that identifies that employee or contractor, and
  • is transferred from the EU or Switzerland to the United States.

For example, Personal Data may include, but is not limited to, date of hire, date of birth, start/end date, compensation and benefits information, and information collected through company-issued technology accounts.

Notice of Collection and Use of Personal Data

FMC creates and receives Personal Data in connection with the management and administration of pre-employment, employment, and post-employment matters. FMC will use such information for business operations, employee development, and administrative purposes, or when required in the course of judicial or administrative proceedings or otherwise by applicable law to protect the interests of FMC and third parties. From time to time, FMC may provide information about employees or contractors to third parties for purposes related to employment or the administration of FMC’s compensation, benefits, and human resources programs. For example, FMC may disclose Personal Data to compensation and benefits consultants, internal and external auditors, and legal or tax professionals retained by the company.

FMC will only share Personal Data in connection with an individual’s status as a current or former employee or contractor. Personal Data will not be rented, sold, or leased to any third party for any purposes unrelated to that individual’s status as a current or former employee or contractor.

This Privacy Statement does not apply to aggregate information collected or developed by FMC concerning employees or contractors. Aggregate information may include statistics, such as the number of people employed in a certain country, demographic information or any other information which does not identify a specific individual.

Choice

Where required by law, FMC will offer employees and contractors the opportunity to opt out of having their Personal Data collected, used, and disclosed.

Any withdrawal of consent to the collection, use, and disclosure of Personal Data, where allowed by law, may affect certain aspects of the employment relationship or result in the employee or contractor being no longer eligible for certain benefits and services provided by FMC, to the extent the Personal Data affected by the withdrawal of consent was necessary to process such benefits.

FMC does not intend to use or share any “sensitive” information (for example, personal information specifying medical or health conditions, racial or ethnic origin, political opinions, and religious or philosophical beliefs) about employees or contractors with third parties. Employees or contractors may, however, opt-in prior to any potential uses of sensitive information, as required by applicable law, if the information is to be disclosed to a third party that is not an affiliate or agent of FMC or used for a purpose other than the original purpose at the time of collection, or any purpose authorized subsequently by the employee or contractor.

Data Security

FMC takes reasonable measures to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. These measures include, but are not limited to: training and communication of appropriate policies and practices; restricted access and monitoring of buildings, systems, and files; appropriate technical measures including firewalls, etc.; personal password and authentication protection; and authorization requirements to access Personal Data on a “need to know” basis either for job requirements or specific business purposes. FMC will store Personal Data for as long as it is deemed reasonably necessary. This may extend beyond the term of an individual’s employment or engagement.

Onward Transfer

Prior to the disclosure of Personal Data to any third party, FMC will confirm that the third party subscribes to the Safe Harbor Principles or, alternatively, that the third party agrees to provide at least the same level of privacy protection required by the Safe Harbor principles.

Many of the servers that store Personal Data are maintained in the United States of America. Therefore, your Personal Data may be exported to, and stored and processed in, the United States. By becoming an employee or contractor, you freely and specifically give FMC your consent to export and store your Personal Data in the United States. You understand that Personal Data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States.

Data Integrity

FMC processes Personal Data only in ways compatible with the purposes for which it was collected or subsequently authorized by the employee or contractor. To the extent necessary for such purposes, FMC takes reasonable steps to make sure Personal Data is accurate, complete current, and otherwise reliable with regard to its intended use.

Access

FMC provides individuals with reasonable access to the Personal Data they provided to FMC. FMC also provides the ability to review and correct Personal Data, as applicable, by contacting the Human Resources Service Center.

Enforcement

If a complaint regarding FMC’s use of Personal Data is raised by an EU or Swiss employee or contractor, FMC will investigate and try to resolve any dispute. Any questions or concerns regarding this Privacy Statement or the handling of employee or contractor Personal Data should be directed to the Manager of the Human Resources Service Center by using the information below:

FMC Human Resources Service Center
801 Princeton South Corporate Center
Ewing, NJ 08628
HRSC@FMC.com
1 (888) 362 – 4448

If the dispute cannot be resolved, the employee or contractor may have certain rights under the local laws of the country in which he or she is located. FMC will participate in the dispute resolution procedures of European data protection authorities.

Amendment

This Privacy Statement may be amended from time to time in a manner consistent with the requirements of the Safe Harbor Principles. Appropriate notice will be given concerning any amendments.