Our Policies
Privacy Policy
Last updated: 23.04.2023
SKY Mobility (Malta) Ltd. (hereinafter referred to as ‘SM’ and/or ‘Service Provider’) operate and provides professional services.
These include:
• Affiliate partners
Together, these firms form the SM network. ‘SM’ is often used to refer either to individual firms within the ‘SM’ network or to several or all of them collectively.
Kindly note that for other services, such as Consulting related services, Audit and Training, SM works collaboratively with the following companies:
• Refer to mentioned partner when the respective service is offered or/and provided.
Kindly note that partnering firms of the Company have a data-sharing agreement in place and data will be processed in line with your engagement depending on the scope of the engagement letter.
SM is the Data Controller for the purposes of applicable data protection law.
The Company respects your privacy and is committed to protecting your personal data which it processes.
This Privacy Notice explains how the Company will comply with the applicable data protection legislation, including, the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as the ‘GDPR’), the Data Protection Act (Chapter 586 of the Laws of Malta, any subsidiary legislation and any other applicable laws relating to privacy and electronic communications, as may be amended from time to time.
It is important that you read this Privacy Notice so that you are aware of how and why we are using your information.
1.DATA CONTROLLER
As the Data Controller, STT is responsible for deciding how it holds and uses the personal information collected from you. The Company may, in certain circumstances, deliver services in partnership with another entity whereby the Company will be a Joint Controller with that entity.
SKY Mobility (Malta) Ltd.’s contact details:
Registered Office Address:
Level 3B, The Brokerage, Santa Marta Street,
Victoria VCT 2551, Gozo, Malta
M: +356 27895115
For general contact, please send us an email on welcome@skymobility.eu
The Company has a GDPR Compliance Team (hereinafter referred to as ‘the Team’) who is responsible for matters relating to privacy and data protection. The Team may be reached on welcome@skythinktank.com or by calling on +356 27895115.
2.DATA PROTECTION PRINCIPLES
STT is committed towards compliance. If we need to collect, use or store your Personal Data, we will abide by the following data protection principles:
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Lawfulness, fairness and transparency – the processing of personal data shall take place in a lawful, fair and transparent manner;
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Purpose limitation – the collection of personal data shall only be performed for specified, explicit and legitimate purposes and shall not be further processed in a manner that renders it incompatible with those purposes;
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Data minimization – the collection of personal data shall be adequate, relevant and limited to what is necessary in relation to the purpose(s) for which they are processed;
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Accuracy – the personal data shall be accurate and where necessary kept up to date. Having regard to the purpose(s) for which personal data is processed, the Company shall take every reasonable step to ensure that inaccurate personal data are erased or rectified without undue delay;
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Storage limitation – personal data shall be kept in a form which permits identification of the data subject, for no longer than is necessary for the purpose(s) for which the personal data is processed;
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Integrity & Confidentiality – personal data shall be kept confidential and stored in a manner which ensures appropriate security. Personal data shall not be shared with third parties except when necessary and with a justifiable legal basis.
3.PERSONAL DATA
Personal Data is any information relating to an identified or identifiable natural living person, also known as a ‘data subject’. A data subject can be described as an individual who can be directly or indirectly identified through the information collected and processed by the Company. Such information may include name, surname, identification number, location data, online identifier or any other data relating to their physical, physiological, genetic, mental, economic, cultural or social identity.
The definition of Personal Data excludes any data which has been rendered anonymous in such a manner that the data subject is no longer identifiable (‘anonymous data’).
Special category data includes data on racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, health data, data concerning a natural person’s sex life or sexual orientation. The Company will only process special category data, also known as ‘sensitive data’, under strict conditions and with an appropriate legal basis.
We process personal data about the following categories of data subjects.
4.THE PERSONAL DATA WE COLLECT AND HOW WE USE IT
We collect and process personal data relating to you in connection with your use of this website and our relationship with you. This personal data may include:
• Personal Data
• Purpose for Processing
• Lawfulness
• First Name
• Last Name
• Contact Number
• E-mail Address
• Response of Queries Provision of Feedback
• Commentary & Newsletter Subscriptions
• Online Meetings via Microsoft Teams*
• Consultation Purposes
• Invoicing
• To Take part in online discussions, surveys or promotions.
• Legitimate Interest
• Passport
• ID Card
• Bank Reference Letter
• Professional Reference Letter
• Proof of Address
• CV
• Shareholder’s List
• Screenshots of a Person
• Identification and Compliance Purposes
• Bookkeeping Purposes
• Auditing Purposes
• Banking Purposes
• Legal Obligation Contractual Obligation
• Proof of Authorisation to act on someone’s behalf such as Power of Attorney
• Identification Purposes
• Legal Obligation Contractual Obligation
• Job Applicants Details
• Recruitment Purposes
• Contractual Obligation
• Employee Details
• Employment Purposes Payroll Purposes Performance Reviews
• Compliance with the applicable employment legislation
• Social Security Number
• Tax Identification Number
• Payroll Purposes
• Legal Obligation
• Passport
• ID Card
• Bank Reference Letter, Professional Reference Letter,
• Proof of Address
• CV
• Police Conduct
• Previous Employer Reference
• Copies of Qualifications
• Identification Services
• Conduct of Fit & Proper Assessment
• Freelance Services
• Contracted Partner Services
• Employment
• Contractual Obligation Legal Obligation
• Personal Data relating to external consultants
• To take steps to enter into a contract of Service
• Contractual Obligation
• Server Logfiles
• Statistical Evaluation
• Legitimate Interest
*Microsoft. Privacy Policy contains information about collecting Customers, Visitors and other data subjects (like Agents or End-users) Personal Data and other information, products and Services offered or performed by Microsoft. and the manner of its processing. For more information, please visit Microsoft website.
5.FAILURE TO PROVIDE THE INFORMATION
In most cases, the provision of personal data arises either from statutory requirements or contractual provisions. Where applicable, failure of the provision of personal data will prevent the Company from complying with its legal or regulatory obligation, concluding contracts, and delivering the services requested.
6.CHANGES TO YOUR PERSONAL DATA
It is important that the personal information we hold about you is current and accurate. Therefore, it is your responsibility to keep us informed should any of your personal information change.
Due to STT’s obligations at law, you bind yourself to furnish us with recent suitable documentation for confirmation, on a regular basis, upon a merely verbal request to this effect from us. These may be required for KYC and due diligence purposes as well as to allow us to correctly perform the terms of our engagement, as per the internal operating procedures currently in force at the time.
7.COOKIES
Cookies are small text files placed on your computer by the websites you visit. They are widely used to make websites work more efficiently, as well as to provide information to the owners of the website.
For more information about how we use cookies and to change your cookie preferences kindly read our Cookie Policy.
8.DISCLOSURE OF YOUR PERSONAL DATA
Except as described in this Privacy Notice, we will not intentionally disclose the personal data we collect or store to third parties unless it is an imposed legal obligation on us to do so.
We will not share your information with any third parties for the purposes of direct marketing.
We use data processors who are third parties who provide elements of services for us. We have agreements in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will hold it securely and retain it for the period we instruct.
In some circumstances, we are legally obliged to share information. For example, under a court order or where we cooperate with other authorities. We might also share information with other regulatory bodies in order to further their, or our, objectives. In any scenario, we will ensure that we have a lawful basis on which to share the information.
We may disclose information to third parties in connection with the above-mentioned purposes, in the following circumstances:
• Recipients of Personal Data
• Purpose
• Legal Basis for Disclosure
• Malta Business Registry
• Company Service Provider
• Contractual Obligations
• Banks/ EMIs
• Bank Account Openings
• Contractual Obligations
• AVSec Malta
• Background checks
• Contractual Obligations
• Identity Malta
• Working Permits
• Contractual Obligations
• PayPal
• Subscription and Payment Purposes
• Contractual Obligations
• HubSpot
• Consultation Booking
• Contractual Obligations
All our third-party service providers are required to take appropriate security measures to protect your personal data in line with our policies. Moreover, we only permit third parties to process your personal data for specified purposes and in accordance with our legally binding agreements.
9. INTERNATIONAL TRANSFERS
The information provided to us may be shared with third parties situated in other European Economic Area (‘EEA’) Member States or in countries outside the EEA.
The Company will only transfer personal data outside the EEA after taking the necessary steps to ensure that your privacy rights continue to be protected, as outlined in this Privacy Notice and in accordance with applicable data protection laws.
For instance, we will transfer your personal data outside the EEA with your consent, to fulfill a legal obligation or to fulfill our contractual obligations.
10.RETENTION OF PERSONAL DATA
The personal data that we process shall not be kept longer than is necessary. We retain your personal data for as long as we need it to comply with our obligations under applicable law, to enforce our contractual agreements, and if relevant, for the establishment, exercise and defense of legal claims.
We will actively review the personal data we handle, process, and store, and will delete or anonymise it in a secure manner where there is no longer a legal, business or customer need for it to be retained.
For more information on the retention of your personal data, kindly contact us on welcome@skymobility.eu or on +356 27895115.
In circumstances where it is impossible for us to specify in advance the periods for which your personal data will be retained, we will determine the retention period on the following criteria:
• the purpose(s) for which your personal data was collected;
• whether there are any statutory obligations, obliging us to continue to process your information;
• whether we have a legal basis in place to continue to process your information, including but not limited to consent;
• the value attached to your information;
• whether there are any industry practices stipulating how long the information should be retained;
• the risk, cost, and liability attached to such retention; and
• any other relevant circumstances.
11.DATA SUBJECT RIGHTS
As a data subject, you have a number of rights in relation to your personal data. The Company respects your privacy rights and will endeavor to uphold such rights to the extent that they apply to the way in which we process your personal data.
Your principal rights are:
• the right to be informed;
• the right to access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to object to processing;
• the right to data portability;
• the right to know of the existence of automated decision-making;
• the right to lodge a complaint with the supervisory authority (IDPC) and/or seek judicial remedy in those cases where you believe that your data protection rights have been infringed following the processing of your personal data by a data controller; and
• the right to withdraw consent.
If you wish to exercise any of the above-mentioned rights, please send your request on compliance@skymobility.eu
Any request made will be given appropriate consideration within the timescales required by data protection legislation. Generally, the Company will respond to such requests within one (1) month, with the possibility to extend this period to three (3) months for particularly complex requests, in accordance with applicable law. In any such event, we will inform you accordingly.
Prior to processing your request and where deemed reasonably necessary, you will be required to provide us with proof of your identity. This is intended to ensure that the personal data is not disclosed to unauthorised third parties. The Company may require additional information in relation to such requests in order to speed up our response procedure. We reserve the right to withhold your personal data if disclosing it would adversely affect the rights and freedoms of others.
Generally, when exercising your rights, no fees are applicable. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee.
12.SECURITY
SKY ThinkTank takes appropriate security measures to protect your personal data against loss, misuse, unauthorised access, alteration, disclosure or destruction of your information.
We have taken steps to ensure the ongoing confidentiality, integrity, availability and resilience of systems and services processing personal information and will restore the availability and access to information in a timely manner in the event of a physical or technical incident.
No method of electronic storage and no method of transmission over the internet, is 100% secure. SKY Mobility cannot warrant or ensure the security of any information transmitted to us, but this is done at your own risk. Moreover, we cannot guarantee that such information will not be accessed, disclosed, altered or destroyed by any breach of our physical, technical and/or organisational safeguards.
Regular training on information security practices is provided to all members of staff who process personal data.
SKY Mobility has put in place procedures to deal with any suspected personal data security breach and will notify the Regulator of any such breach where we are required to do so. We will also inform you, as the data subject, of the occurrence of a breach and the steps to take to safeguard your rights.
If you feel that your personal data has been compromised, please contact our Data Protection Officer on compliance@skymobility.eu or on +356 27895115.
13.PRIVACY BY DESIGN AND BY DEFAULT
When introducing new technologies, policies or processes, we will ensure that your privacy is considered at the ‘design’ stage. Where applicable and in line with Articles 35-36 of the GDPR, we will carry out a Data Protection Impact Assessment (‘DPIA’).
A DPIA will also be carried out where new technologies are used or where we consider there is a high risk to your rights and freedoms. Where an assessment identifies risks, which cannot be satisfactorily reduced, avoided or eliminated, we will seek advice from the Supervisory Authority (i.e. the Office of the Information and Data Protection Commissioner) prior to initiating the processing.
14.LINKS TO OTHER WEBSITES
Where the SKY ThinkTank provides links to websites belonging to other entities, this Privacy Notice does not in any way cover how that entity processes your personal data.
We encourage you to read the Privacy Notices on the other websites you visit.
15.CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice may change from time to time. If this Notice is changed in ways that affect how we use your personal information, we will advise you of the choices you may have as a result of such changes.
We will also post a notice that this Notice has changed.
Our Policies
Quality and Environment Policy
Last updated: 29.01.2024
SKY Mobility (Malta) Ltd. is committed to operating its business with integrity, supporting environmental and social responsibility, and building a diverse and inclusive workplace where our employees can thrive. We are committed to integrating sustainability into our overall business strategy, primarily in areas where the SKY Mobility has the most influence, such as our operations and value chain.
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We define Environmental, Social, and Governance criteria as follows:
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The environmental component of ESG refers to how our business practices affect the environment and vice versa. The scope of environment includes energy use, consumption of resources, waste disposal, water management, and climate risk. Our policies and programs strive to achieve sustainable operations and minimize impact on the planet.
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The social component of ESG refers to how our organization’s operations affect our people, our customers, and the communities where we live and work. Our social policies and practices strive to build a healthy corporate culture and positive relationships with our stakeholders.
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The governance component of ESG refers to how we operate, govern, and manage risk in a way that promotes sustainability and the longevity of the organization. Our governance policies and practices outline the way in which we make decisions, set business strategy and goals, comply with applicable laws and regulations, and communicate our progress.
This Sustainability Policy outlines our company-wide activities and commitments for each ESG focus area. We see sustainability leadership as a business opportunity, a risk mitigant and an essential aspect of our core values.
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Scope
The Sustainability Policy applies across the Corporation and applies to all relevant stakeholders outlined in section IV. Different business units within the Corporation are expected to use this policy as guidance to assess ESG and sustainability considerations in their respective decision-making processes. This document outlines our commitments but will not include metrics of progress. ESG metrics will be reported in other forms of disclosure (i.e., ESG Report).
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Governance
Sustainability starts with our Board. Our Board sets the tone at the top for responsible business practices and our commitment to ESG. The following five committees of the Board, which meet regularly and report back to the full Board, play a role in ESG oversight:
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The Corporate Governance and Nominating Committee has direct oversight of ESG policies, practices, and disclosure, in addition to oversight of corporate governance and operational risks related to human capital.
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Safety department (acting as Risk Committee) is responsible for the oversight of the Corporation’s enterprise risk framework and is responsible for establishing the Corporation’s risk tolerance and risk profile. This includes oversight of certain key company risks, including emerging risks.
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HR department (acting as Compensation and Benefits Committee) has oversight of compensation structure for the executive leadership team and Board.
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OPS department has oversight of the Corporation’s policies related to all aspects of the respective function and operational risk management; and
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Accounting department (acting as the Asset/Liability Committee) has oversight of policies and practices relating to asset and liability management, including the Corporation’s investment portfolio management.
The responsibility and management of our ESG framework and strategy is implemented in the organisational department structure to operationalize the Corporation’s ESG policies and strategy. The ESG Committee is composed of leaders from corporate, marketing, human resources, finance, safety & risk management, and compliance. The ESG Committee aligns ESG priorities and initiatives for the year for Board’s Corporate Governance and Nominating Committee approval, sets long-term objectives and goals, and leads the annual reporting process on ESG related topics. The purpose of the ESG Committee is to guide advancement of the Corporation ESG disclosure along the disclosure spectrum, starting with qualitative disclosures, followed by establishment of metrics and goals to support qualitative disclosures. The ESG Committee is also responsible for prioritizing initiatives, develop internal capabilities, and drive/monitor implementation. The ESG Committee meets on a quarterly basis and reports to the Chief Executive Officer. The ESG Committee also periodically reports to the Corporate Governance and Nominating Committee of the Board.
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Principles and Philosophy
The Corporation is committed to incorporating ESG into how we manage our business. The Corporation is committed to assessing the environmental, social, and governance factors that impact our business, managing the risks associated with such factors, and striving to improve the way the Corporation operates its business in accordance with these factors. This includes identifying opportunities to reduce the Corporation’s environmental footprint, enhancing the diversity of the organization, deepening our employee’s engagement and development, and increasing transparency in our supply chain, having a positive impact on the communities in which the Corporation operates, and operating with a strong culture of compliance. However, the Corporation recognizes that there is not a one-size-fits-all approach to ESG integration; rather, the Corporation strives to employ best practices and evaluate ESG factors in our decision-making. The following topics are considered ESG areas of focus for the Corporation. ESG is continuously evolving, therefore the list below is subject to change.
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Environmental
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Energy Management
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Climate change risk
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Ecological conservation
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Recycling and waste management
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Water management
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Social
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Customer experience
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Access and affordability
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Responsible selling practices
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Customer privacy
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Community engagement
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Diversity, equity and inclusion
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Training and development
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Health and safety
Governance
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Governance of ESG
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Board composition, accountability, and executive compensation
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Business ethics and compliance
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Government relations and partnerships
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Cyber security
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Systemic risk management and business continuity
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Vendor management
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Incorporation of ESG in credit analysis
Relevant Stakeholders
We recognize that our commitment to managing ESG risks and opportunities is essential to long-term value creation for our shareholders, employees, customers, communities, and other stakeholders. To that end, the Corporation integrates sustainability and ESG into our activities, focusing on certain aspects among the different stakeholders as detailed below.
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Employees
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Respect for diversity, and non-discrimination because of gender, race, age, sexual orientation, or any other condition.
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Promotion of employment stability, work flexibility and work-life balance, as well as a safe and healthy workplace for employees.
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Encourage equal opportunities among its employees, aspiring to have a balanced representation between men and women in all functions and responsibilities.
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Ensure employees behave in accordance with certain ethical and responsible conduct principles and rules in accordance with our Code of Ethical Conduct.
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Promote programs to make employees aware of social and environmental issues, including measures for good environmental management practices, social and environmental risks, and business opportunities.
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Encourage corporate volunteering to help the communities we serve prosper and increase our employees’ pride in belonging to the Corporation.
Customers
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Offer products and services that are accessible to our customers and provide them with accurate, sufficient and appropriate information.
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Monitor exceptional situations or settings that may influence certain customers in order to offer them alternative solutions, in particular, among those groups in a situation of vulnerability or risk of social exclusion.
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Consider ethical, social and environmental matters and financial and risk criteria pursuant to this Sustainability Policy.
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Prevent and avoid the funding of illegal activity in compliance with the Anti-Money Laundering by taking any additional measures deemed necessary.
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Promote specialized financial education with the objective of providing information to current and potential clients about products and financial services, as well as the expertise needed for decision-making.
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Protect customer privacy and personal information by instilling proper security safeguards.
Shareholders
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Offer thorough, clear, and accurate information to all shareholders through various communication channels annually.
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Listen and incorporate advice and recommendations about ESG trends and disclosures.
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Include ESG information and metrics in our annual financial disclosures and incorporate updates, where relevant, in shareholder communication.
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Engage rating agencies that evaluate and rate the Corporation’s performance on ESG matters.
Contracted activities - Suppliers and Vendors
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Ensure suppliers, consultants, and independent contractors conduct their business ethically, responsibly, in full compliance with the law, and as detailed in the Corporation’s Service Provider Code of Conduct, which service providers are required to acknowledge.
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Identify, prioritize, monitor, and control vendor risks that may impact the Corporation as further detailed in chapter Error! Reference source not found. Error! Reference source not found..
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Procure materials for the Corporation’s activities that have ESG benefits, such as upcycled furniture, recyclable utensils and energy efficient appliances and technology.
Communities
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Improve the social and economic well-being of our communities, including the continuation of sponsorships and collaborative projects directly impact economic development, entrepreneurship, social services, education, health, affordable transportation/housing, and environmental conservation.
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Support community development, including progress towards our established lending goals, investment goals, donations budget, and CRA activities goals defined for each region we operate in.
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Provide relief for our communities experiencing natural disasters and other events impacting the geographical regions in which we operate through charitable donations, employee volunteering, CRA Program initiatives, and other efforts from the Corporation.
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Foster volunteer opportunities for employees and create a company culture focused on giving and empathy.
Sustainability Commitments
A. Internal Management
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Comply with applicable environmental laws and regulations.
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Operate our facilities with cross-functional leadership driving continuous improvement and pollution prevention throughout our operations.
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Reduce our carbon footprint through focused system optimization, energy conservation, renewable energy when feasible, and innovation for energy efficiency - within our direct operations and our supplier and customer collaborations.
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Mitigate and prepare for the physical risks of climate change and emergency preparedness.
B. Aviation, Maritime and Real Estate Activity
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Manage environmental risks in corporates activities, including real estate originated by the Corporation and its participations purchased from other organisations or institutions.
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Conduct environmental risk assessments for relevant corporate activities to determine risks related to operational departments, compliance with environmental laws, presence of hazardous substances, and management of waste.
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Provide guidelines for commercial activities, including unacceptable activities.
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Align with investments that may have social and environmental benefits.
Training
The Corporation provides face-to-face, online, and virtual training, development activities, and workshops on various topics pertinent to our employee base. Upon onboarding and every year thereafter, every employee must acknowledge the Code of Ethical Conduct. Every employee also undergoes annual cybersecurity training. The Corporation also offers diversity and unconscious bias online training. In addition, our hiring managers receive training on sexual harassment, recruitment process and best practices to promote fair competition. The ESG Committee is required to upkeep knowledge on external ESG factors and regulations influencing the Corporation.
Our Continuing Commitment
We strive to advance the principles outlined in this Sustainability Policy and continue to mitigate and manage relevant ESG risks, including the implementation of monitoring and due diligence protocols to ensure progress and adherence to our values. The Corporation is committed to issue an ESG Report on an annual basis which aligns to leading standards and frameworks, including the Sustainability Accounting Standard Board, and the United Nations Sustainable Development Goals.
Oversight and Maintenance of Policy
We are committed to updating the Sustainability Policy periodically, but in no event less than every two (2) years, to reflect current commitments and relevant practices at the Corporation. The Sustainability Policy has been reviewed and approved by our management team and the Board.
We do good for people, the planet and prosperity.
Our Policies
Code of conduct & Ethics
Last updated: 29.01.2024
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1. Sustainability and Innovation:
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Example: Instead of printing documents for every meeting, consider use digital tools for sharing information, reducing paper waste and promoting sustainability.
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Behavioral Application: Regularly assess your workflow for opportunities to minimize environmental impact, such as using energy-efficient equipment or sourcing eco-friendly office supplies.
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2. Customer Satisfaction:
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Example: When handling a customer complaint, consider actively listen to the customer's concerns, empathize with their situation, and offer a prompt and satisfactory resolution.
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Behavioral Application: Prioritize active listening and empathy in all customer interactions, seeking to understand their needs and preferences to provide personalized and effective solutions.
3. Respect and Inclusivity:
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Example: During team meetings, consider actively encourage input from all team members, ensuring that everyone's perspectives are valued and heard.
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Behavioral Application: Foster a culture of inclusivity by actively seeking out diverse viewpoints and respecting the opinions and contributions of all colleagues, regardless of background or position.
4. Integrity in Business:
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Example: When faced with a decision that could compromise ethical standards, consider to choose the option that aligns with the company's values, even if it means sacrificing personal gain.
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Behavioral Application: Consistently uphold honesty and integrity in all business dealings, even when faced with challenges or pressures to act otherwise.
5. Environmental Consciousness
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Example: Instead of driving to work alone, consider carpool, bike, or use public transportation to reduce carbon emissions and promote sustainable transportation options.
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Behavioral Application: Integrate sustainable practices into your daily routine, such as turning off lights and electronic devices when not in use, and recycling or composting waste materials.
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6. Continuous Learning and Improvement:
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Example: An employee could proactively seek out training opportunities related to sustainability practices, such as attending workshops or online courses.
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Behavioral Application: Stay informed about the latest developments in sustainability and ethical practices, and actively share knowledge and insights with colleagues to promote continuous improvement.
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7. Accountability and Reporting:
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Example: If an employee observes behavior that violates the company's code of conduct, such as harassment or discrimination, they could report it to HR or management following the established reporting procedures.
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Behavioral Application: Take responsibility for maintaining a safe and ethical work environment by promptly reporting any concerns or violations and cooperating with investigations as needed.
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Our Policies
Cookie Policy
Last updated: 23.04.2023
SKY Mobility (Malta) Ltd. (hereinafter referred to as ‘SM’ and/or ‘Service Provider’) operate and provide professional services.
These include:
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• Affiliate partners
Together, these firms form the SM network. ‘SM’ is often used to refer either to individual firms within the ‘SM’ network or to several or all of them collectively.
Kindly note that for other services, such as Consulting related services, Audit and Training, SM works collaboratively with the following companies:
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• Refer to mentioned partner when respective service is offered or/and provided.
SM uses cookies on the https://www.zero.aero website (hereinafter referred to as the ‘Website’), and the server location is in USA.
This Policy explains what cookies are, why and how we use cookies, how third parties may use cookies on our website, your choices in relation to cookies and any other information about cookies.
1.COOKIES – WHAT ARE THEY
Cookies are small text files (mainly numbers and letters) placed or downloaded on your device when you visit or access a website. On each subsequent visit cookies are sent back to the originating website.
Cookies are useful since they allow a website to recognise a user’s device and to store information about your preferences or past actions.
Certain cookies are required for the sole purpose of carrying out the transmission of a communication over an electronic communications network – others may be required for the provision of service over the internet.
Cookies may also be desirable to improve the user’s experience, in which case we will ask for your consent to use such cookies.
2.HOW WE USE COOKIES
SM uses cookies for a variety of purposes, mainly:
• to improve the user’s experience;
• to distinguish between visitors and their location;
• to improve the use and functionality of the website;
• to enable certain functions of the website (e.g. navigation, access to secure areas, aggregate statistics about the number of visitors)
• to obtain data about how the website is being used.
Furthermore, the collection of such data enables us to develop, optimise and facilitate the use of our website.
Cookies may either be deleted automatically when the user closes the website browser (also known as ‘session cookies’) or are stored on the user’s device to facilitate future visits (also known as ‘permanent cookies’). The latter cookies will also be deleted automatically after a specified period of time.
3.WHAT COOKIES WE USE
The Domain uses 13 cookies in total.
The following table lists:
• the type of cookies placed on the website;
• their function;
• the purpose(s) for which the data is collected and for how long it is retained.
Please note that the name of the cookies may change over time.
Preference Cookies: Preference cookies enable the website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
• Provider
• Cookie Name
• Expiration
• Purpose and Description
• Type
• ads.linkedin.com
• lang
• Session
• Remembers the user’s selected language version of a website
• HTTP
• linkedin.com
• Lang
• Session
• Set by Linked In when a webpage contains an embedded “Follow Us” Panel.
• HTTP
Statistic Cookies: Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
• Provider
• Cookie Name
• Expiration
• Purpose and Description
• Type
• zero.aero
• _ga
• 2 Years
• Registers a unique ID that is used to generate statistical data on how the visitor uses the w eb site.
• HTTP
• zero.aero
• _gat
• 1 day
• Used by Google Analytics to throttle request rate
• HTTP
• zero.aero
• _gid
• 1 day
• Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
• HTTP
Marketing Cookies: Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
• Provider
• Cookie Name
• Expiration
• Purpose and Description
• Type
• zero.aero
• _fbp
• 3 Months
• Used by Facebook to deliver a series of advertisement products such as real time bidding from third-party
• advertisers.
• HTTP
• Google.com
• ads/ga-audiences
• Session
• Used by Google Ad Words to re-engage visitors that are likely to convert to customers based on the visitor’s online behaviour across websites.
• Pixel
• Linkedin.com
• Bcookie
• 2 Years
Used by the social networking service, Linked In, for tracking the use of embedded services.
• HTTP
• Linkedin.com
• Bscookie
• 2 years
• Used by the social networking service, Linked In, for tracking the use of embedded services.
• HTTP
• Facebook.com
• Fr
• 3 months
Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.
• HTTP
• Linkedin.com
• Lidc
• 1 day
Used by the social networking Service. Linked In, for tracking the use of embedded services.
• HTTP
• Facebook.com
• Tr
• Session
• Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers
• Pixel
• Linkedin.com
• UserMatchHistory
• 29 days
Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor’s preferences.
• HTTP
4.YOUR CHOICES
When visiting our website, you will be requested to accept and/or manage your cookie settings.
We can store cookies on your device if they are strictly necessary for the operation of the website. However, your consent is required for all other types of cookies.
You may change your mind and may refuse to accept, delete or block cookies at any point in time. Please note that if you do so, you might not be able to make use of the full functionality and the features of the website, you may not be able to store your preferences and some of our pages might not display properly.
5.HOW TO CONTROL COOKIES
You can control and/or delete cookies. For more information, please refer to: https://www.aboutcookies.org.
All cookies on your computer can be deleted and you can set most browsers to prevent cookies from being placed. If you do this, you may manually have to adjust some preferences every time you visit a site, and some services and functionalities may not work.
6.CHANGES TO THIS POLICY
This Policy may be updated from time to time. If we make significant changes to this Policy, we will upload a notice regarding the same on the website. However, it is advisable to regularly check this Policy so as to ensure that you are aware of the most updated version of this Policy.