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Responsible: SABSEG GROUP S.L. (B-04.975.017) - Passatge de Josep Llovera, no. 4 (08021 Barcelona), Barcelona - Email: DO NOT SEND - Phone: 93 272 3440 // Main purpose: Manage potential business/professional relationships, address inquiries, and provide the information requested // Rights: Access, rectification, deletion, and portability of your data, limitation and opposition to its processing, as well as not being subject to decisions based solely on the automated processing of your data, where applicable // Additional information: You can consult the detailed information about our Privacy Policy on our website or by requesting it from us via email.

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Digital disconnection policy

Regulatory framework

At SABSEG GROUP, we are committed to the right to digital disconnection for all

our workers, as well as to the flexibility measures that facilitate the reconciliation of personal and professional life as a basic benefit of our Company. This is why, although the demands of insurance mediation activities and our commitment to providing excellent service to our clients sometimes make it difficult, we are also committed to the continuous improvement of the organization, which is manifested in the willingness to make our company the best place to work.

Therefore, to promote the reconciliation of personal, family, and work life and to comply with what is established in art. 88 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights, the rest of workers is guaranteed and their right to digital disconnection is expressly recognized once their working day is over.

At Sabseg Group we have developed this protocol of measures regarding the exercise of the right to disconnection that expressly involves the disconnection of digital devices, not being obliged under any circumstances to respond to emails, messages, and professional calls outside of their working hours, or during any type of leave, days off, and/or vacations of the worker.

The laws on which this protocol is based are:

  • Article 88 of the LOPDGDD (Ley Orgánica 3/2018, de 5 de diciembre, de Protección de DatosPersonales y Garantía de los Derechos Digitales ).

  • Workers’ Statute (Real Decreto Legislativo 2/2015, of October 23, approving the consolidated text of the Ley del Estatuto de los Trabajadores).

  • Telework Law (Law 10/2021, of July 9, on Remote Work).

Scope of application

This protocol will apply to all persons working at SABSEG GROUP (Brokers Alliance, S.L., Banasegur, SAU, ASESORIA INTEGRAL DE SEGURO AGROPECUARIOS SLU, Ores & Bryan, S.L., BROKERS CONSULTORES DE SEGUROS CORREDURIA DE SEGUROS SA, POOLSEGUR, S.L., GUILLERMO ADELL CORREDURIA DE SEGUROS SL, CARANTIA TRES SL CORREDURIA DE SEGUROS, ICBA IBERICA, CORREDURIA DE SEGUROS S.L., ARRENTA QUARTO PILAR CORREDURIA DE SEGUROS, S.L.), regardless of whether they develop their tasks in person or remotely.

Implementation/training/awareness raising actions

FIRST.-The company guarantees workers the right to digital disconnection once the working day is over.

For these purposes, all devices and tools susceptible to extending the working day beyond legal limits will be taken into account, particularly: laptops, mobile applications specific to the company, emails, company chat, or any other that may be used.

SECOND.- Workers commit to the proper use of the IT and technological means provided by the company, avoiding, as far as possible, their use outside of the ordinary working hours stipulated in the employment contract. Those responsible for managing teams must particularly observe digital disconnection policies, as they are a key position concerning the teams they coordinate. Therefore, individuals with teams under their charge - weighing the concurrent circumstances reasonably and responsibly concerning the activity and business - will refrain from requiring a response in communications sent to workers outside of working hours, as long as they could imply an effective job for the recipients during rest time. For this reason, workers who receive the communication will have the right not to respond to it until the start of the following working day.

In this sense, in case of having to send a communication that may require a response outside the established hours, the sender will expressly assume that the response can wait until the next business day.

THIRD.- In order to guarantee the right to disconnection concerning the effective reconciliation of personal, family, and work life, the convocation and attendance to meetings, both internal and external, will occur within the limits of the working hours, respecting the rest time and the vacations corresponding to the localities where services are provided.

FOURTH.- Sabseg Group will guarantee workers the right to digital disconnection during the period of their breaks, vacations, leaves, incapacity or unpaid leave, under the same terms, including workers who hold managerial positions. Workers will be obliged to leave a warning message in the email with the mention of 'absent', indicating the contact details of the persons designated to replace them, as well as the dates of duration of the periods.

FIFTH.- The measures that guarantee the right to digital disconnection will not apply in cases where exceptional circumstances, special needs, force majeure, or those that imply serious or evident/imminent business harm occur, whose temporal urgency requires an immediate response. In the same manner, these measures will not apply when situations/incidents/accidents of our customers occur that require an immediate response from us for a proper underwriting, renewal, or claims management service.

In such cases, the company requiring a response from the worker, once their working day is over, will preferably contact them by phone to communicate the urgent situation that motivates this situation.

Thus, the work time so required could be classified as exceptional, and will be treated as such. The application of the right to digital disconnection is excluded for those workers in high-responsibility positions or trusted roles who remain available to the company and receive, therefore, a 'availability' complement or another of similar nature, understanding that, during the continued attention time in a location regime, the worker will have the obligation to respond to communications, in accordance with the rules that regulate the corresponding availability regime.

SIXTH.- Sabseg Group will implement awareness measures on which the right to digital disconnection is based. Therefore, staff will be informed and/or trained about the necessary protection of this right, taking into account both the labor and personal circumstances of all workers, and for this, all the information and/or training necessary for understanding and subsequent application of the aforementioned protective measures of the right to digital disconnection will be made available to them.

SEVENTH.- Workers may not be discriminated against in their professional development nor punished for exercising the right to digital disconnection. Therefore, it is guaranteed that the exercise of this right by workers cannot lead to sanctioning measures, nor can it negatively influence promotion, evaluation, and assessment processes.

EIGHTH.- Sabseg Group recognizes and formalizes the right to digital disconnection as a right, although not as an obligation, applicable to all workers. This expressly implies that workers who communicate outside the hours established in this policy may do so with full freedom; however, they must assume that they will not receive a response until the next business day.

Measures to adopt

Sabseg Group has established a series of measures to ensure that all workers carry out the recommendations set forth in this policy:

  • All work communication will be done through the tools and devices provided to the worker by the company.

  • As a good practice and to avoid sending communications outside of working hours, the sending of such communications will be scheduled in Schedule sending email in Outlook - Microsoft Support

  • Department of People, responsible for occupational risk prevention, can always be consulted regarding possible risks and/or cases of techno-stress, and analyze the impact of digital disconnection policies from the perspective of psychosocial risks.

  • To carry out a proper review and follow-up of compliance with this digital disconnection protocol, it will be supervised that the actions indicated in this agreement are fulfilled by the People team, responsible for managing and ensuring the well-being of all workers.

  • In case a worker considers that adequate measures are not being implemented to ensure digital disconnection, they can notify the People department through the email personas@sabseggroup.com

Entry into force and validity

This policy will come into force with its signature and will be renewed annually tacitly. This policy is a living document that will be reviewed periodically to include any modifications and updates deemed necessary for its proper functioning.

Publicity

This Internal Policy for the Right to Digital Disconnection will be available as documented information and will be communicated to all workers.

Signed. Blanca Piédrola Báez

Director of People & ESG

SABSEG GROUP