13. Privacy, Trade Secrets & Company Information

The Right Turn 2.0

Our Code of Conduct


We respect the privacy of personal data – which includes any employee or third-party information that is either private (i.e., health information) or personally identifiable.[1] Records containing personal data about employees, customers, vendors, and suppliers must be kept confidential. We treat personal data with the same level of care that we treat other confidential information and trade secrets. Only persons who need to access personal data to perform their job responsibilities should access such data and only to the extent necessary to perform those responsibilities. We only collect, use, and disclose personal information for legitimate business purposes or when we are expressly required to do so by law. We ensure that all uses of personal data take place in accordance with all applicable laws and regulations. We implement reasonable organizational and security measures to protect personal data against voluntary or accidental disclosure and other privacy violations. Should such an incident occur, we will promptly report any loss of or unauthorized access to personal data as required by applicable law.

All information relating to a health or medical condition, or a personal family issue, is private and confidential. The disclosure of identifiable healthcare information without written authorization is prohibited except in limited cases where there is a legally required reason for doing so. Access to those records is limited to those who have a specific need to use the information in the performance of their duties. All use of such information must be in compliance with the privacy policy under which the information was collected.

If you are in doubt about how to protect personal data or information, always seek advice from the Legal Department.

In our competitive markets, it is important to protect the Company’s business information. Confidential information about plans for future bids, how we develop our bids, financials, pricing policies, technical information, inventions, know-how, potential acquisitions, products, employee data, customer information, and similar business activities should not be disclosed or even shared with others within the Company unless they have a business need to know. Employees may only use confidential information for its intended purpose and never for personal gain.

We also respect other individuals’ and organizations’ confidential information. You should not seek nor should you accept such information from others, unless it is provided lawfully under a non-disclosure agreement prepared by our Company’s legal counsel. Do not bring to Colas any proprietary records or information of a former employer.

Legitimate sources of competitive information include:

  • newspapers and press accounts
  • public filings
  • talking with customers – but not to obtain confidential information
  • information that is observable on the street
  • trade shows (but not information from competitors)
  • information publicly available on the internet
  • industry surveys by reputable consultants

Never use the following:

  • A competitor’s confidential information – any and all questions as to whether competitive information is confidential must be reviewed by the Legal Department
  • Papers or computer records brought by new hires from prior employers Information marked “confidential,” or something similar, belonging to anyone else – consult our Legal Department if you have such information Even if proprietary information just shows up on your desk, do not use it: get legal advice
  • Business information exchanged with competitors
  • Confidential information about a competitor’s bid if you are involved in bidding, especially on government contracts – if you come into possession of such information call the Legal Department
  • Information on a competitor that someone has offered to sell
  • Anything else that feels wrong