This is how we make a difference: with transparency and legality.

This Code of Conduct, Ethics and Dignified Treatment in the workplace and for business is a frame of reference that aligns the personal and professional behavior of all employees and contractors with the corporate values and principles projected by the Company, to promote and maintain harmonious and respectful relationships, and guarantee the transparency and legality of our activities, fulfilling our commitments to our customers, vendors and the Government regarding sustainability, human rights and environmental protections.

This is who we are: there are our values.

We are passionate about what we do: We like challenges and we put our heart and all our enthusiasm into achieving the goals we give ourselves.

We are inclusive: We value people’s essence, their ideas and opinions, because we know we all contribute to achieving the best results.

We are dynamic: We are always open to finding different ways of doing things, to adapt to our surroundings and offer quick and effective solutions.

This is how we act: these are our principles.

All our company’s activities must be framed within applicable laws and regulations. This covers, among others:

· Employment and labor laws established in the Substantive Labor Code regarding contracts, social security affiliations, disciplinary regulations and procedures, employee and employer obligations and prohibitions, and both the former and the latter must act under the conditions contained in the Internal Work Regulations.

· Hours, overtime hours and weekly days worked must not surpass the limits established by the law, except when there are urgent production needs due to unpredictable, infrequent and uncontrollable circumstances including earthquakes, flooding, road closures due to public order considerations, fire or damaged machinery.

· The employees’ right to free association, as well as their active participation in the Community Committee and the Peer Committee for Workplace Health and Safety, through open voting to select representatives to these Committees.

· Strict compliance with obligations and duties deriving from obligations acquired under different customs, tax and parafiscal regimes.

We don’t force people to work nor do we make them perform tasks outside their job descriptions. We reject any situation that could mean our employees are coerced or threatened for this purpose. 

We make sure our employees have the competencies and skills required for performing the tasks assigned to them and the minimum means and protections they require for doing their work.

If the company requires its employees to work extra hours, this will only happen if employees agree to it, because they cannot be forced to work more than the established work hours.

At no time may our activities be carried out or supported by persons outside the law or with restricted rights or freedoms due to decisions made by the competent authorities.

All our workers are over eighteen (18) years old.

Minors that enter the company as apprentices during an elective stage will receive sponsorship for their studies but may not perform any tasks inside the company.

Access by minors to the company’s installations will only be permitted in the event of guided tours.

We work to maintain our working environment free from any kind of harassment, abuse or emotional or physical punishment.

The company ensures the freedom of movement of all its employees within its installations, per regulations contained in work schedules and maintaining required access restrictions for critical security zones, demarcated by doors that open using sensors activated by employees’ IDs. As part of this freedom of movement, the company has an easy-open system on all its emergency doors, which will not be locked using padlocks or otherwise for any reason whatsoever.

Employee searches may only be performed by security staff. Respect for dignity and intimacy are of paramount importance during these, as during their execution there should be no physical contact with or verbal disrespect towards the employees.

All our employees, both those hired directly by each Strategic Business Unit and those hired using temporary work services, will be paid no less than the legal minimum wage, and will receive all corporate benefits and other surcharges or compensation they are entitled to.

Operating charges that can be measured by level of efficiency have incentive systems that allow our employees to increase their earnings depending on their performance.

All employees are hired, promoted and removed from the company based on their abilities and aptitudes for carrying out their work efficiently, and never on their personal conditions, gender, race or personal beliefs.

For this reason, in the case of women and in accordance with Colombian law, we do not perform pregnancy tests, providing all women with the possibility to access and remain at our company independently of whether they are pregnant or not.

We are committed to protecting and promoting the health of our workers, pursuing their physical integrity through risk control, continuous process improvement and environmental protection.

We must all promote a healthy and safe work environment, meeting all applicable legal requirements, involving interested persons with the Workplace Health and Safety Management System and allocating the human, physical and financial resources required for health and safety management.

The programs we develop focus on promoting a culture of prevention and self-care, on intervening working conditions that could cause accidents or occupational illnesses, reducing absenteeism and emergency preparedness and response.

All employees, contractors and workers hired through temporary service companies are obliged to comply with safety rules and procedures to carry out their work safely and productively. We will also be responsible for notifying any conditions that could have consequences or create contingencies for the organization and its employees in a timely manner.

Our production processes meet applicable environmental standards defined by both our clients and by Colombian law. We also comply with best practices for chemical product storage, handling and disposal.

We promote awareness of and commitment to environmental protection amongst all employees, and their active participation in all comprehensive waste, discharge and emissions management programs is an extremely important part of the role they play at the company.

We are not exempt from the possibility of falling victim to criminal activities that could affect the company’s assets or its reputation, or that could place our employees, shareholders, or customer image at risk. For this reason, preventing criminal activity is a rule of conduct for all people participating in supply chain activities, as we do not tolerate any actions carried out for personal gain or business that is against the law or runs counter to the company’s image or financial stability.

This is how we comply: with coherence and good deeds.

Legal obligations: all employees must have knowledge of the internal and external regulations that apply to the activities we perform, and we are responsible for being aware of any amendments or updates to the law we need to put into practice in a timely and precise manner.

We enforce the obligations and prohibitions contained in the regulatory framework applicable to us, ensuring that others that work with us comply with it too. We also put into practice the internal policies and controls established by the company, and don’t issue or apply policies that haven’t been approved beforehand by legal counsel.

Fraud: a fundamental premise of our company is zero tolerance to all forms of fraud. Once any fraud is identified immediate action will be taken, including reporting it to the relevant authorities when appropriate.

Fraud is understood as any event or action that affects or involves the company, our customers and vendors and that privileges individual interests, including:

· Improper resource appropriation or use: understood as the theft or improper use of company resources, such as money or any other asset (including raw materials, inputs, machinery or finished product).

· Corruption: defined as the act of offering or accepting any object, money, perk, favor or benefit on one’s own or on another’s behalf, for influencing a decision. This conduct includes, without limitation, the following actions: (i) Receive, give, promise or request lavish objects, understood as those that are worth more than one legal minimum monthly wage; (ii) promise, offer, receive or give a privilege within the country not corresponding to approved company policy, including for example the adjudication of a contract, the supply, purchase or sale of any item, even done free of charge; (iii) use the influence inherent to a corporate position or role to procure a benefit or privilege to benefit the employee or any third party recommended by the employee, including tickets to a concert or social, athletic or recreational event, special discounts, travel, etc.

· False reporting: seeking to distort the reality of the employee’s own or of third party performance, by supplying false or manipulated information.

· Illegal activities inside the company: including selling, buying or using psychoactive substances, or making illegal “payday” loans. Selling goods or services inside the company for personal or third-party gain is also considered fraud.

· Illegal activities inside the company: including selling, buying or using psychoactive substances, or making illegal “payday” loans. Selling goods or services inside the company for personal or third-party gain is also considered fraud.

Money Laundering and Terrorist Financing: employees that perform commercial activities with clients and vendors are responsible for protecting the company, avoiding any operations that could be used as instruments for money laundering and/or terrorist financing and reporting to the General Management or their immediate superior anything that could lead them to suspect that a transaction hides a desire to use the company to legitimize illegal operations.

Use of Positions: employees with personnel under them respect their peers and work teams, do not use their position in the company to get special treatment and always act according to internal policies and procedures.

All company employees take care to have the competencies required so we can respond to the processes we perform with the highest quality and efficiency.

We work to care for ourselves and others, avoiding situations that could affect or endanger health, life, the environment, and the company’s operations.

Conflicts of Interest: we favor the common good over individual interests. We do not compromise the integrity of our actions to obtain benefit for ourselves, thus avoiding situations that would represent conflicts of interest in our commercial and labor relations. Employees will report to their immediate superior or to General Management any offer, promise, business project or business deal that could compromise our impartiality and transparency.

Use of company resources, assets and information: we use the resources assigned for performing our activities, and the company’s installations and other assets, in an austere and efficient manner.

Employees will not use, either for the company or within its installations, any third-party asset, right, brand, patent, software, etc., without prior authorization from the company and paying any applicable rights to the legitimate owner.

We will protect the company’s information and are aware of our responsibilities regarding confidentiality and non-dissemination, because we understand that the company is the sole owner of its tangible or intangible assets or rights, whether they are its own creation or the result of being entrusted to us or to services provided by us.

This is how we provide solutions: with everybody´s help: the Board of Directors, employees, vendors, clients, contractors, public entities, or any third parties may make inquiries or report situations related to the conduct, ethics, transparency or personal treatment of and by employees, contractors or workers contracted through temporary services company, using our ethical hotline or our website

For employees, we also have the Creativity Mailbox located physically at the production plants, or virtually on-line, where they can anonymously report both ethical situations and any kind of complaint or grievance due to any type of abuse or non-performance.

All inquiries and reports are analyzed by the Ethical Committee, made up by the CEO, the Human Resources Subdirectorate, and the Director of Organizational Management, who must provide solutions under the strictest:

Confidentiality: Maintaining the identity of the persons reporting the situation and the persons involved in the ethical dilemma in strictest confidence.

Objectivity: Exhaustively analyzing ethical inquiries, complaints or dilemmas, to determine non-compliance based always on the company’s established principles, policies and processes. 

Respect:Guaranteeing the highest respect for the rights of the persons allegedly involved in possible breaches. The Committee will also make sure that, prior to issuing any value judgment, they may, without any kind coercion, provide all relevant justifications and explanations in defense of their actions.

No reprisals:No reprisals may be taken against workers that report non-compliance. Anyone found taking reprisals against these collaborators must be subject to corresponding disciplinary action.

This code is issued on November 28, 2016, after approval from the Board of Directors in its meeting on November 16, 2016, and is to be made an integral part of the labor contract for all employees, and be published on the company’s website to favor consultation by its recipients and guarantee its dissemination and mandatory enforcement.

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