Committed to social development
, sustainable economy and the environment

This document expresses our values, the expected behavior of the organization and our commitment to these values.

The purpose of this document, as an ethical commitment that includes the basic principles for the development of business activities in accordance with current legislation, is to regulate the actions of all members of the company and employees in the performance of their duties, thus establishing uniform behavior and responsible decision-making.

This Code is mandatory for all persons associated with Sacoel, regardless of their employment relationship, their position, or the geographical area in which they carry out their work, provided that the nature of their relationship so permits.

In particular, the conduct of Sacoel’s employees must always comply with this Code and must be communicated to all members of the organisation, external collaborators and other stakeholders through the channels established for this purpose.

A document of acceptance and acknowledgement of delivery and receipt of this document is available.

Employees and external collaborators who receive this document will sign a statement of responsibility as a commitment to comply with this document.

By signing this document, they confirm that they have read and understood it in its entirety and are therefore aware of the obligations, prohibitions and guidelines contained therein.

Declare that:

• In the exercise of his professional responsibilities, he acts in a manner aligned with this Code and complies with its provisions.

• Knows that Sacoel has established an Ethical Channel for the communication and/or reporting of non-compliance and that he/she is obliged to communicate the same through said channel.

• Will collaborate in the establishment of a culture of compliance, set an example and encourage the channeling and resolution of doubts about this Code.

These guidelines facilitate the knowledge and application of the corporate culture, based on human and social rights, as well as the integration of the entire group of employees in the company, always respecting their diversity.

The guidelines of conduct contained in this Code are:

• All Sacoel’s activities shall seek to be respectful of the environment and the sustainable management of natural resources.

• Legality and ethical values will be respected.

• Zero tolerance for bribery and corruption.

• Prevention of money laundering and terrorist financing.

• Respect for free competition and good market practices.

• Avoidance of any conflict of interest.

• Application of the utmost rigor, transparency, and reliability in our management.

• Protection of the company’s reputation and image.

• Efficiency in the use of the company’s means and assets.

• Always protecting intellectual property and confidentiality.

• Clients are at the center of our activity.

• The health and safety of people is our priority.

• Promote fair treatment and diversity.

• Maintain our commitment to our environment.

• Maintain a transparent relationship with the community.

The principle of criminal liability is accepted, and we reject the existence of behaviors affecting the company observed by legal representatives, administrators, and employees in any field of action.

Our priority is to respect human dignity and fundamental rights.

All employees of our organization and external collaborators must support this commitment and carry out their professional activities with the utmost respect for human rights and public freedoms.

Respect for applicable laws and company rules, as well as honesty in daily conduct, must be a constant for all employees, managers, and external collaborators.

Principles have been established for the prevention, detection, and eradication of any irregular conduct, analyzing, and defining responsibilities.

The constant monitoring of commercial and financial operations, imports and exports with sanctioned countries, entities and individuals must be subject to extreme vigilance. And, above all, those so-called dual-use products, such as software, components, and other so-called technological products, which may be destined for military and nuclear use.

An Ethics Channel has been set up to report, anonymously and with immediate effect, any activity or behavior that could be contrary to our Code of Conduct.

No employee of Sacoel will be subject to social discrimination (race, sex, religion, and others) and any form of harassment, physical, sexual, psychological abuse, etc. that could be generated in the development of its activity is prohibited.

Working hours and salaries shall always comply with current legislation.

All Sacoel employees work in a safe and hygienic environment. All our facilities meet the conditions of hygiene, habitability, and safety to ensure optimal working conditions, as well as for the storage and preservation of products.

The company has a system of occupational risk prevention and adequate training to avoid risk situations.

Sacoel’s employees may perform other work activities outside their working hours, if they do not involve a reduction in the development of their functions and activities covered by their contract. Nor may they carry out activities that are in competition with those of the company itself.

Sacoel acts on the market in a transparent and honest manner, without engaging in misleading, fraudulent or malicious practices.

Employees and external collaborators seek the necessary information on the market without using illegal channels and without infringing data protection regulations.

Sacoel forbids its employees and subcontractors to use information obtained from a competing company or from any other source, in breach of confidentiality.

Any false information from competitors will be always avoided and will not be disseminated under any circumstances.

Employees shall always avoid commercial operations and collections from companies coming from tax havens and those that do not allow the companies and their owners to be properly identified.

Training will be continuous for employees, and if necessary for third parties related to the company, formalizing procedures and channels for reporting irregularities detected.

Sacoel’s employees and external collaborators will use the company’s goods and services appropriately and efficiently, without using them for their own benefit or misusing them. The rational use of resources and the avoidance of waste is an obligation.

Under no circumstances shall they use computer equipment to install or download programs, applications or any other illegal use that could expose such equipment to contamination and jeopardize the Company’s reputation or block its activities.

Sacoel employees must always avoid any situation of conflict of interest arising from the development of their activities.

No employee may use his or her position in the company for personal gain.

No employee may provide services to collaborate with or advise another competing company without the authorization of management.

In the event of personal or family conflicts, no employee or external collaborator may compromise or associate Sacoel with them, except with the express authorization of the Management.

All potentially conflicting situations must be brought to the attention of the Management immediately.