Introduction

Ethics and legality are conditions for competitiveness and permanence. They provide security to customers, suppliers, shareholders and the community at large.

This Code expresses the ethical guidelines that Carbotecnia’s collaborators assume in our decisions and actions.

It acknowledges compliance with the laws and regulations that apply to the company.

It frames the policies and guidelines of the organisation and represents a commitment to maintaining the highest ethical standards in its performance. We will prevent violations.

When we witness an occurrence, or when in doubt, we will bring it to the attention of our line manager, another superior or the HR department.

It is our responsibility to demand that the people and companies we do business with also comply with it.

On personal rights and obligations

Personal honesty and integrity

To be trusted by others, we must be accountable for our own decisions and actions. Righteousness and honesty are indispensable principles for community life. Non-compliance has consequences that we must accept.

Compliance with the law

All our activities must fully comply with applicable legislation (laws, regulations and standards). We are responsible for keeping ourselves informed about it, as ignorance of it is not an argument for non-compliance.

Where we are aware that a customer or supplier does not adhere to this, we will not continue the business relationship.

Dignified treatment and respect

Everyone deserves to be treated with dignity, regardless of age, gender, race, psycho-affective orientation, religion, socio-economic status, appearance, level of education, physical or intellectual abilities, skills, hierarchical level, political affiliation or any other personal characteristic or conviction. Therefore, we will treat each other with respect, kindness and a sense of fairness. All this, through explicit words and everything that makes up human language, such as gestures, body language, silences, tones of voice, illocutionary language and actions that carry a message.

Based on the above, at Carbotecnia we will not only not discriminate, but we will value the differences between employees.

When a person fails to comply with the responsibilities of his or her position or with the commitments he or she has made to the company, he or she will be notified and disciplined accordingly, but this will not be a reason for failing to treat him or her with dignity, respect and kindness.

Work environment

The working environment is everyone’s responsibility. It is essential that it is harmonious and that it favours joy and peace. Dignified treatment and respect are the basis for achieving this. Where this is not enough, we will seek dialogue and agreements that allow for it. Where necessary, the immediate superior, the Human Resources department or higher management will intervene until conciliation and a return to harmony is achieved.

Criteria for recruitment, remuneration and promotion of personnel

Decisions regarding hiring or rejection, remuneration and promotions will be made in accordance with internal policies and applicable labour laws, and will be based solely on objective and measurable criteria, such as qualifications, skills, abilities, achievements and performance. Doing so avoids discrimination and promotes equal treatment and equal opportunities.

Health and safety

We are responsible for maintaining a safe and clean workplace by strictly following safety rules and regulations. Likewise, the company will provide us with facilities that have hygienic toilets, drinking water and, if possible, adequate areas for food consumption. For our part, we will comply with the obligation to use protective equipment correctly, and we will attend training courses on its use.

We will report in a timely manner unsafe acts that put us at risk, as well as situations of risk to company assets.

The company shall provide personnel with information necessary for health care and occupational safety. Those of us who perform services for customers outside of Carbotecnia’s premises will ensure that our work adheres to the same health and safety provisions that we apply in-house. Occupational health and safety personnel are committed to compliance with applicable laws and regulations, and with company policies, practices, systems and procedures. Our cooperation is essential in order to avoid serious misconduct or recidivism that could endanger the health and life of staff or the company’s property.

Threats and violence in the workplace

Abusive, hostile or offensive behaviour is unacceptable, whether verbal, physical or visual. Examples include derogatory comments based on certain physical, racial or ethnic characteristics, socio-economic or cultural background, place of study or activities.

Offensive gestures, comments and communications will not be accepted.

Our company seeks to maintain a safe and secure work environment and will not tolerate threats, acts of violence or physical or emotional intimidation and prohibits the entry into the workplace of any type of weapon or tool that could be used to harm a person.

Sexual harassment

Under no circumstances may employees in higher management require a subordinate to carry out actions other than those for which he/she was hired, hence it is not permitted to exert pressure to force us to perform a particular act that does not correspond to our functions or job description. It is forbidden to harass any employee within the company in order to obtain a personal relationship or favour.

Child labour and forced labour

The company does not agree to employ staff under the age of 18, nor to force an employee to carry out activities against their will.

On the equity ownership of the company

Proprietary information, systems and procedures

The custody and preservation of company assets is the responsibility of all employees, so we must prevent damage, misuse, loss, sabotage and theft. Company assets are not only buildings, machinery, tools, vehicles, furniture or computer equipment, but also technical documents, procedures, technologies, data, systems, electronic or telephone communications, written or voice mail, business strategies, advertising campaigns, trademarks and patents, among others.

We will use the assets and resources assigned to each of us responsibly and exclusively for the performance of the activities entrusted to us by the company; we will do so respecting the guidelines established by the company, as well as the applicable policies and procedures.

Responsibility for recording information and preparing reports

Those of us responsible for information recording and reporting will follow internal control policies and guidelines to provide reasonable assurance to the company. All records and reports shall contain true, accurate and reliable data. This includes financial, commercial and cost data, as well as data related to quality control, safety and human resources. We will avoid altering information, recording false or false entries or omitting exits or dispositions, as we are aware of the seriousness of this.

All books, records and financial accounts by which the assets and performance of the enterprise are controlled will reflect each transaction and event accurately. The information shall be timely, complete, accurate, balanced, correct, understandable, and compliant with accounting criteria, as required for timely decision making. Use and management of information

We will keep proprietary and privileged information secure and limit access to it to those who need to know it to do their jobs, in accordance with established policies.

Privacy of information within the company

Mantendremos la confidencialidad de la información que nos da una ventaja sobre la competencia o que puede exponernos a daños y perjuicios si se revela prematura o inadecuadamente, como son métodos de fabricación, procedimientos de cálculo, marcas registradas, tecnología, costos unitarios, información interna sobre licitaciones, información financiera, estratégica, e información confidencial relativa a clientes y proveedores.

We will protect privileged information, such as strategic information, cost data, employee files, salaries, internal processes and procedures, product pricing, customer lists, new product development, and information that may be useful to competitors. On the other hand, information considered as confidential, non-public information of the company, to which we all have access as collaborators, must not be reproduced without the express authorisation of the area responsible for its generation and custody. Company managers should ensure that external personnel with access to this information comply with the policies and procedures through the necessary controls.

Privacy of customer and supplier information

This also includes information that suppliers or customers have entrusted to us. The obligation to preserve proprietary and privileged information continues even after the supplier’s or customer’s working relationship with Carbotecnia ends. Therefore, one of the measures we will take is not to discuss confidential information in public places, family circles and with third parties.

Policies on company assets

We will be responsible for protecting the assets entrusted to us by the organisation. They may only be used for business purposes, and shall be at the expense of the keeper or user.

Computer systems are essential to the daily operation of our company. It is essential that hardware, software, as well as data access, processing and storage, are properly secured and used exclusively for the authorised purposes. The company has several security systems in place to protect its computer systems. We will not use any software to circumvent these systems. We have an individual responsibility to safeguard the company’s computer systems and are responsible for knowing and understanding the specific policies and guidelines governing the use of networks, systems and electronic information. Today, electronic devices allow data to be easily moved from the office to the home. The elements for storing information and systems must be physically secured; access control to them must also be established. In addition, all documentation concerning the acquisition of software licences and the use of such licences must be kept up to date and available for verification. Any copying, appropriation or misuse of software is prohibited. Software, e-mail, internet and voice mail are company property and may only be used for company purposes.

No employee may install non-institutional software on their computers, or software for which the company does not have the corresponding licence.

No modifications shall be made to the contracted software, except where permitted in the respective agreements, and under the supervision of the IT area.

No development of systems or programs not authorised by the IT department shall be carried out.

The internal development of equipment, systems and software by employees for the planning and execution of the company’s activities are the property of the company.

Conduct that may constitute a property crime

Any act or omission that may constitute a financial crime against the company should be promptly reported, identified and investigated, with a view to taking appropriate legal action. This rule shall apply to conduct that may constitute related offences or means of preparation for the commission of a property crime, such as the formulation or receipt of apocryphal or false documents, theft of goods or documents, irregular handling of money and securities, among others.

On conflict of interest cases

It occurs when the personal or financial interests of one of the employees take precedence over the interests of the organisation. As members of the company, we should not get involved in situations that are or may be in conflict of interest, and at the start of the employment relationship we should sign the Letter of Commitment in this regard, in accordance with the existing format and policy. Should any of us find ourselves in a situation that involves or may involve a conflict of interest, we must notify our line manager (using the above-mentioned form), who in turn will inform management and the Human Resources Department. The latter will indicate how to proceed. Line managers will report in a timely manner any conflict of interest situations they identify, thus avoiding any assumption of co-responsibility.

A conflict of interest exists when any of the following situations arise:

Personal benefits or benefits to family and friends

If we participate in an administrative or negotiation decision of any kind that may directly or indirectly benefit us personally, a close family member or associate, financially or otherwise.

Development of other activities

When an outside work task, whether paid or unpaid, adversely affects the performance of our duties within the company, or is performed on behalf of the company for personal gain.

Personal investments

When there is an economic interest in any kind of company that is related to our business area, except in cases where our participation is exclusively in the capacity of an investor in public and exchange-traded securities. Also if there is any financial interest, through relatives or friends in companies that are competitors, customers, distributors or suppliers of Carbotecnia, and this may influence decision-making on behalf of the company.

Gifts and entertainment

Gifts, hospitality, entertainment and meals that we accept may constitute a conflict of interest, so we must refrain from soliciting or accepting favours, gifts, presents, gratuities or courtesies from current or prospective customers, officers, competitors, distributors and suppliers. Promotional gifts with a value of up to 15 general daily minimum wages. To keep gifts in excess of this amount, authorisation from the Directorate is required. If such authorisation is refused, the respective gift will be sent to the Human Resources Department to define its destination.

Family members and close personal relations

Working relationships with blood relatives in the ascending, descending or collateral line up to the second degree may also cause a conflict of interest, so the company will not accept relatives, except in specific cases where, in the opinion of management, they do not affect either the performance of our work or good relations with the company.

In the event that we are aware of a business owned or operated by a relative or friend who wishes to become a supplier of services or products to the company, we should not influence the negotiations in favour of that business. If the function we perform is directly related to the negotiations, we should excuse ourselves from participating in the negotiations by informing our line manager in writing about the relationship with the relative or friend. If we have family members or friends working for a competitor, we should refrain from providing information related to the organisation, as well as from receiving and passing on information from competitors within the company. We shall avoid associating with superiors, subordinates or friends to commit dishonest acts detrimental to the interests of the organisation.

On ethics in the performance of our work

Business opportunities

The employees of Carbotecnia consider it an improper practice to use the organisation’s information for personal benefit, or for the benefit of family or friends. We may not use the name of the company for our own benefit, the benefit of any other person or organisation, or the benefit of any potential negotiation or investment, taking advantage of the level or performance of our position.

Responsibility for authorising purchases, expenditures, payments and sales of company assets

All employees empowered to authorise transactions such as purchases, payment to suppliers, delivery and verification of travel expenses, will review what we authorise as part of our responsibilities and commitment to ensure that movements are correct and in accordance with established policies. Personnel who have access, authority, use or express authorisation to dispose of company property, records, merchandise, securities, cash and restricted materials are personally responsible for their safekeeping.

Ethics in supplier relations

We are directly or indirectly responsible for the purchasing process, as well as for the contracting of any type of service, which must be objective when selecting suppliers on the basis of the best conditions in terms of price, quality and characteristics of the goods or services and always in accordance with the company’s purchasing policies. We may not condition the purchase of products or the procurement of services from suppliers in exchange for a gift or the cessation of supplying products and services to competitors, unless there is a conflict of interest in procurement, confidential information or compliance with the terms of the contract.

Fair competition

With regard to our competitors, we will at all times conduct ourselves in accordance with the highest ethical standards. Our competitiveness must be based solely on the merit of our products and services, appropriate pricing, timely service and the added value we provide to the customer. We will never use illegal or unethical methods to obtain information about competitors.

Appropriating and disclosing proprietary and privileged information of other companies is prohibited. If we mistakenly obtain information that could constitute a trade secret or confidential information of another company, or if we have doubts about the legality of any information obtained, we will consult with management.

Others

On personal political and community activities

All employees are free to support community organisations, political, religious or charitable causes of our choice, as long as we make it clear that our views and actions are personal and not those of the company. As employees, we must ensure that external activities do not interfere with work performance. No member of our company may pressure another to express a point of view contrary to his or her personal belief or to contribute to or support political, religious or charitable causes. Nor is it permitted to use company assets for this purpose.

Carbotecnia supports a number of charities. It is therefore not permitted for us as employees to arrange, commit or agree to donations or financing in the name and on behalf of Carbotecnia. This process needs to be applied rationally, which is why it is limited to the indications of the management.

Consumption of alcoholic beverages, drugs and narcotic drugs

It is essential to come to work free from the influence of substances that could impede the safe and effective performance of activities. The use, possession, sale, attempted sale, transportation, distribution, or manufacture of drugs or any other controlled substance is not permitted while conducting business on company premises or in company vehicles.

Any employee found to be under the influence of drugs, alcohol or any other controlled substance will be subject to disciplinary action.

This also applies to external personnel on company premises.

Relations with authorities and public officials

Relations with public authorities and civil servants are handled by the management or the Directorate.

Environment

We will respect the environment, complying with the law. We are committed to protecting the environment and will seek to minimise the impact of our production and operational processes. In the performance of the company we will seek the rational and sustainable use of natural resources, the efficient use and saving of energy, the permanent reduction of polluting emissions and the safe containment and transport of materials derived from our operation.

Raising questions and suspicions, filing complaints

We will ask our line manager or a supervisor if we are in doubt about the interpretation of any policy, legal or ethical issue. We will also let you know if we believe that we are in violation of applicable laws that apply to company processes, internal policies, the Code of Ethics, or if we become aware of any situation of concern. Our open-door philosophy allows you the freedom to approach any hierarchical level with your concerns. Taking action to avoid problems must be part of the culture at Carbotecnia. If we observe possible unethical or illegal conduct, we are invited to report concerns. False incident reports or reports that deliberately, maliciously or maliciously attempt to harm the reputation, integrity or dignity of any member of our organisation will not be accepted or tolerated.

What is not provided for in this Code of Ethics

This Code does not include all rules or regulations that apply to every situation. Its content has to be considered in conjunction with the company’s policies, practices, instructions and procedures, and with the requirements of the law. However, even if a situation lacks a specific guideline, we expect our employees to apply the highest ethical principles in such a circumstance.

Availability of the Code of Ethics

In addition to each employee of the organisation being familiar with this Code of Ethics, as stated in the signed Letter of Adherence, this document will also be available on the company’s server, so that any updates to its content can be consulted, as well as inviting external personnel with whom they interact in the performance of their duties to become familiar with it and share the commitment it sets out.

Ethics Committee

This is the body appointed by the Directorate, responsible for:

  • Establish ethical and conduct policies and guidelines.
  • Monitor due compliance with this Code of Ethics and the policies referred to in it.
  • Take appropriate action when there is a violation of the provisions referred to above in terms of the corresponding internal work regulations.