1. General provisions

These Talent Pool Regulations (hereinafter referred to as the “Regulations”) are an internal regulatory document of Antal Talent JSC and its subsidiary Antal Business Solutions LLC (hereinafter referred to as the “Company”), governing the conditions for maintaining the Talent Pool, the procedure for its formation, and the procedure for excluding External or Internal Applicants of the Company from the Talent Pool.

These Regulations apply to the Company and are mandatory for all employees of the Company, including employees who process the personal data of Applicants for vacant positions within the Company and its Clients who are included in the Talent Pool.

The personal data of Internal and External Applicants are processed on the basis of these Regulations and taking into account the “Personal Data Processing Policy” of Antal Talent JSC and Antal Business Solutions LLC.

2. Terms and definitions

External Applicant means a person who is not an employee of the Company and who has given their consent to inclusion in the Talent Pool and to the processing of their personal data for the purpose of inclusion in the Talent Pool;

Internal Applicant means a person who is an employee of the Company and who has given their consent to inclusion in the Talent Pool and to the processing of their personal data for the purpose of inclusion in the Talent Pool;

Talent Pool means a database containing information about Applicants for open vacancies within the Company or its Clients for which a recruitment process is underway;

Processing of personal data means any action (operation) or set of actions (operations) performed with personal data, whether by automated means or without such means, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), blocking, deletion and destruction of personal data;

Personal data (PD) means any information relating directly or indirectly to an individual (personal data subject);

Applicant means a person who may apply for vacant positions within the Company or with the Company’s clients (Internal or External Applicant).

3. Procedure for forming the Talent Pool

3.1. The Company’s Talent Pool is created for the purpose of ensuring the timely filling of open vacancies both within the Company and with the Company’s clients, improving recruitment activities, and creating conditions for the professional development of persons included in the Talent Pool.

3.2. The Company’s Talent Pool consists of Applicants for vacant positions within the Company and vacant positions with the Company’s clients who have provided consent to the processing of their personal data for the purpose of inclusion in the Talent Pool and who are considering employment opportunities for open vacancies within the Company or with the Company’s clients.

3.3. The Talent Pool is formed without reference to specific positions on the basis of the Applicant providing the relevant consent to the processing of personal data for the purpose of inclusion in the Talent Pool and becoming familiar with the conditions governing the Talent Pool. An Applicant is added to the Talent Pool automatically during the recruitment process upon receipt of the Applicant’s consent to the processing of personal data for the purpose of inclusion in the Talent Pool. Once included in the Talent Pool, Internal and External Applicants are entitled to participate in selection processes for vacant positions open within the Company.

3.4. Applicants’ personal data are stored and processed in the Company’s Talent Pool for 15 (fifteen) years unless the Applicant withdraws the relevant consent.

3.5. The Company’s Talent Pool may include Applicants who have consented to being added to the Talent Pool or who have completed the form on the website (the application form is available at antaltalent.ru in the “For Applicants – Submit a CV” section). Information from this form is used when assessing the Applicant during the period in which they remain in the Talent Pool.

4. Conditions for working with the Talent Pool

4.1. The Company’s work with the Talent Pool is based on compliance with the legislation of the Russian Federation, consideration of current and future requirements for filling open vacancies, the creation of conditions for professional growth, and a comprehensive and objective assessment of the professional and personal qualities of Applicants included in the Talent Pool.

4.2. During the period in which an Applicant is included in the Talent Pool, the Applicant may receive information about any vacancies within the Company and with its Clients for which a recruitment process is underway. Such information may be provided from the moment the Applicant is included in the Talent Pool. Information about open vacancies is available at antaltalent.ru.

4.3. Information about Applicants included in the Talent Pool is confidential. Employees of the Company who have access to such information are required to ensure its confidentiality and security.

4.4. Communication with candidates included in the Talent Pool is carried out by the Company via the email address and other communication channels specified by the Applicant in their CV. Communication may also take place through alternative communication channels agreed with the Applicant.

4.5. Inclusion of an Applicant in the Talent Pool does not entail a mandatory appointment of the Applicant to an open vacancy.

4.6. Employees of the HR Department and business units are entitled to use an Applicant’s contact information when sending information about open vacancies both within the Company and with the Company’s clients, as well as to contact the Applicant for interviews and to update the information contained in the Applicant’s CV.

4.7. Internal Applicants are entitled to participate in the selection process for an open vacancy within the Company if they submit an application for the relevant vacancy.

5. Procedure for exclusion from the Talent Pool

5.1. An Applicant may at any time request to be removed from the Company’s Talent Pool by sending a request to withdraw their consent to the processing of personal data by email to: crm@antaltalent.com.

5.2. An Applicant shall be excluded from the Talent Pool in the following cases:

a) submission of a personal request for exclusion from the Talent Pool;

b) expiry of the 15-year personal data processing period.