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BUSINESS ETHICS POLICY

 

PINTURAS FIERRO S.L.

1. Purpose

The purpose of this policy is to establish the ethical principles and standards ofconduct that should guide the actions of all employees, executives, contractors, andbusiness partners of Pinturas FIERRO, S.L. This policy reinforces our commitment tointegrity, transparency, and responsibility in all our business operations.

2. Scope

This policy applies to all employees, executives, contractors, and business partners ofPinturas FIERRO, S.L., regardless of their location.

3. Ethical Principles

3.1 Integrity

  • Act with honesty and transparency in all business interactions.
  • Comply with all applicable laws, regulations, and internal policies.
  • Avoid any form of corruption, bribery, or fraud.

3.2 Responsibility

  • Take responsibility for our actions and decisions.
  • Recognize and correct mistakes in a timely manner.
  • Promote a culture of accountability at all levels of the company.

3.3 Respect

  • Treat all employees, customers, suppliers, and partners with respect and dignity.
  • Foster an inclusive and diverse work environment.
  • Prohibit any form of discrimination, harassment, or abuse.

3.4 Confidentiality

  • Protect confidential and sensitive company and customer information.
  • Use information only for authorized purposes.
  • Comply with all data protection and privacy laws and regulations.

3.5 Loyalty

  • Act in the best interest of Pinturas FIERRO, S.L.
  • Avoid conflicts of interest and disclose any situation that may appear as a conflict.
  • Do not use one’s position within the company for undue personal gain.

3.6 Financial Responsibility

  • Maintain accurate and complete financial records.
  • Comply with all applicable accounting and tax laws and regulations.
  • Provide accurate and truthful financial information to stakeholders.
  • Use company resources efficiently and responsibly.

4. Business Conduct

4.1 Legal Compliance

  • Comply with all applicable laws, regulations, and standards in all jurisdictions wherewe operate.
  • Maintain accurate and complete records of all business transactions.

4.2 Fair Business Practices

  • Compete fairly and ethically in the marketplace.
  • Refrain from engaging in unfair, deceptive, or fraudulent business practices.
  • Respect third-party intellectual property rights.

4.3 Relationships with Customers and Suppliers

  • Treat customers and suppliers fairly and equitably.
  • Comply with the terms and conditions of contracts and agreements.
  • Do not accept or offer gifts, favors, or entertainment that could influence businessdecisions.

4.4 Corporate Social Responsibility

  • Contribute positively to the communities where we operate.
  • Minimize the environmental impact of our operations and promote sustainablepractices.
  • Participate in initiatives that support social and economic development.

4.5 Exports and Economic Sanctions

  • Comply with all applicable export and economic sanctions laws and regulations.
  • Do not engage in transactions with countries, entities, or individuals subject toeconomic sanctions imposed by international organizations or national governments.
  • Conduct due diligence to ensure that our export activities comply with all relevantregulations.

 

5. IImplementation and Compliance

5.1 Communication and Training

  • Communicate this policy to all employees, executives, contractors, and businesspartners.
  • Provide regular training on business ethics and compliance to ensure understandingand adherence to this policy.

5.2 Reporting and Whistleblowing

  • Provide secure and confidential mechanisms for employees and other stakeholdersto report violations of this policy.
  • Protect whistleblowers from any form of retaliation.

5.3 Investigation and Sanctions

  • Investigate all reported violations of this policy promptly and thoroughly.
  • Take appropriate corrective and disciplinary actions against those who violate thispolicy.

6. Policy Review

This policy will be regularly reviewed and updated to ensure its relevance andeffectiveness. Any updates will be communicated to all employees, contractors, andother stakeholders.

Aprobado por

Ataulfo Fierro González

CEO

Pinturas FIERRO, S.L.

- March 2023 -