data ethics policy

INTRODUCTION AND BACKGROUND

In COWI, we commit to using and processing data in an ethically acceptable way in all aspects of our business.

COWI uses software, algorithms and artificial intelligence in analysis and evaluations aimed at optimising our own decision-making processes and to create valuable, better and more sustainable solutions for our customers.

The purpose of this policy is to formalise COWI’s data ethics principles and describe how we wish to use and process data, making it clear to our customers, employees and other stakeholders that we are dedicated to these efforts.

OUR DATA EThICS PRINCIPLES

COWI's data ethics principles derive from our corporate values centred around 'doing the right thing, always'.

In COWI, we always comply with statutory regulations regarding data and privacy protection; however, we also recognise that continuous technological change and development, alongside increasing risks and benefits from utilisation of big data, require thoughtful and responsible decision-making where existing laws and regulations do not necessarily suffice.

Thus, we have identified four main principles which, together with COWI's corporate values, work as COWI's data ethical compass:

TRUST

In any professional relationship, trust is important – for COWI, it is essential.

We consider a trustful relationship with our customers, employees and other stakeholders as one of the greatest successes of a company and we strive for building and maintaining the trust of the people and companies whose data we use and process by adhering strictly to our commitments in this policy.

INTEGRITY

Integrity in data use and processing for COWI is about prioritising the safety and caretaking of those people whom our solutions and internal processes affect.

Thus, our use and processing of data may never compromise the fundamental rights, freedom and safety of an individual.

TRANSPARENCY

COWI will provide transparency around the principles of storage, use, and processing of data to our employees, customers, and other stakeholders to ensure their continuing confidence in COWI.

COWI will cooperate with and openly disclose our data, including access to and check of COWI-applied algorithms, to authorities if there is an obligation to do so according to legislation or any court or authority decision.

SECURITY

COWI follows the underlying principles of international standard on information security ISO/ICE 27001. These principles are a fundamental part of COWI's business and internal audit controls and are continuously adhered to, securing compliance with both information security and data protection requirements.

Data in COWI's possession is processed and stored in a secure manner, ensuring a minimal risk of data breach.

COWI has adopted and implemented a number of policies of relevance to support this data ethics policy in line with applicable legislation, including a personal data protection policy, a business integrity policy and an IT security policy.

INTERNAL GOVERNANCE

The Executive Board of COWI Holding A/S has approved this policy and, based on input received from COWI's Digital Transformation Team, assesses at least once a year its content and sufficiency.

The administration of this policy is anchored with COWI's Digital Transformation Team to facilitate and ensure implementation in COWI's business units of the data ethics efforts as set out herein.

The Digital Transformation Team is headed by COWI's Chief Business Development Officer, and its mandate to administrate this policy is specified in terms of reference issued by COWI's Executive Board.

This policy applies to all COWI Group companies.

This Data Ethics Policy was approved and adopted by the Executive Board of COWI Holding A/S on 20 January 2022.