Privacy Shield Policy

POLICY HIGHLIGHTS

Atkore has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce (“Privacy Shield”).

This Policy supplements our Website Privacy Policy located at www.atkore.com/privacy

Atkore will only process Personal Data in ways that are compatible with the purpose that we collected it for, or for purposes the individual later authorizes. When collecting sensitive Personal Data, the Company will obtain any necessary opt-in consents as required by law or the Privacy Shield, including if the Company will disclose sensitive Personal Data to third parties, or before the Company uses sensitive Personal Data for a different purpose than it was collected for or later authorized.

Atkore maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

INTENT

This Privacy Shield Policy (“Policy”) describes how Atkore International Group Inc. and its subsidiaries and affiliates (“Atkore” or the “Company”) collect, use, and disclose certain personally identifiable information, relating to all forms of data subjects, that may be transferred between the US and the European Economic Area (“EEA”) or the United Kingdom (“Personal Data”).

Atkore recognizes that the EEA and the UK have established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EEA and the UK. To provide adequate protection for certain Personal Data about corporate customers, suppliers, business partners, job applicants and employees received in the US from the EEA or the UK, Atkore has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce (“Privacy Shield”). Atkore adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.

SCOPE

This Policy applies to all Atkore employees, including full-time, part-time, salaried, hourly, union and nonunion, officers and executives (“Employees”), the members of the Board of Directors (“Directors”), and to any other entities or individuals about whom the Company collects Personal Data. This Policy supplements our Website Privacy Policy located at www.atkore.com/privacy, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website Privacy Policy.

For purposes of enforcing compliance with the Privacy Shield, Atkore is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov.

POLICY AND PROCEDURES

Personal Data Collection and Use

Our Website Privacy Policy describes the categories of Personal Data that we may receive in the US relating to data gathered from our websites. We process Personal Data gathered from our websites for the following purposes: customer service, order processing and fulfillment, website analysis, disclosure to distributors or agents, analytical purposes (such as developing and improving our products), disclosure in conjunction with a corporate merger, acquisition or divestiture, to protect our rights or property or to comply with a law or regulation, court order or other legal process.

The Company will also collect Personal Data, which may include sensitive personal data, regarding our current and former employees for human resources management and payroll processing. This collection and usage of the human resources Personal Data is necessary to maintain the employment relationship, process employee’s salary or other payroll related processes, carry out our employment law related obligations, to protect our rights, and to comply with a law or regulation, court order or other legal process.

Data Transfers to Third Parties

Third-Party Agents or Service Providers.We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf, including payroll processing and human resources data management. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.

Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security

Access Rights

Individuals may have the right to access the Personal Data that the Company holds and to request that the Company correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If an individual would like to request access to, correction, amendment, or deletion of Personal Data, that person can submit a written request to the contact information provided below. Atkore may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

Binding Arbitration

You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with Atkore and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).

Questions or Complaints

Employees can direct any questions or complaints about the use or disclosure of Personal Data to the Company by contacting their Human Resource Business Partner, the Legal Department or calling Atkore’s AlertLine:

US & Canada web address: atkoreinternational.alertline.com

International web address: atkoreeu.alertline.com

US & Canada: 888-503-5397

Australia: 1-800-20-8932 or 1-800-14-1924

New Zealand: 0800-450464

United Kingdom: 0808-234-7051

China: 10-800-711-0631 or 10-800-110-0577

Other non-employees should direct any questions or complaints about the use or disclosure of Personal Data by contacting the Company’s Data Controllers via email at legal@atkore.com.

The Company will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with the EU data protection authorities, or the UK Information Commissioner. If you are unsatisfied with the resolution of your complaint, you may contact the EU data protection authorities, or the UK Information Commissioner for further information and assistance.