Ethics Procedure

Ethics Procedure

The Ethics Procedure defines the basic standards of business behavior and ethics that Company’s employees engaged or not in relations with third parties have to comply with. Third parties are considered: Company customers, Company suppliers, other Company business partners, Company shareholders, other stakeholders, competitors.

This procedure provides the requirements for disclosing potential conflict of interest and the process for obtaining a conflict of interest review. The purpose of this procedure is to protect employees from any conflict of interest that might arise.

To assist employees in identifying conflicts of interest, this procedure defines the requirements for a process to review issues regarding conflicts of interest, to determine whether a conflict of interest exists, and to interpret, manage and resolve matters pertaining to this procedure. The process will be administered by designated Fraud & Ethics Committee.

CONTENT

1. OVERVIEW
1.1 PROCEDURE OWNER
1.2 CLASSIFICATION
1.3 APPLICABLE REGULATIONS
1.4 RELATED [COMPANY] NORMS AND PROCEDURES
1.5 OBJECTIVES
1.6 AUDIENCE AND SCOPE
1.7 DOCUMENT SUPPORT
2. DEFINITIONS & ABBREVIATIONS
3. GENERAL RULES
3.1 GIFTS
3.2 CONFLICT OF INTERESTS
3.3 PROTOCOL
3.4 IMPROPER PAYMENTS (BRIBERY)
3.5 PUBLIC DONATIONS
3.6 CONFIDENTIAL INFORMATION
3.7 FAIR PLAY
4. RESPONSIBILITIES
4.1 EMPLOYEES
4.2 FRAUD & ETHICS COMMITTEE
4.3 ETHICS ADVISOR
4.4 ETHICS COORDINATOR
4.5 SECURITY DEPARTMENT
4.6 FRAUD & ETHICS COMMITTEE SECRETARY
4.7 DEPARTMENT DIRECTOR
4.8 SUB DEPARTMENT MANAGER
5. REPORTING AN ETHICAL ISSUE
6. WHISTLEBLOWING
6.1 INVESTIGATION
6.2 FEEDBACK
7. EXCEPTIONS
8. FINAL CONSIDERATIONS
8.1 DISCIPLINARY ACTIONS AGAINST PROCEDURE VIOLATION
8.2 DOCUMENT REVISION

Pages: 17

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This Internal Disciplinary Action Policy provides guidance with respect to determining internal disciplinary action only.

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