Code of Ethics and Conduct

8. MANAGEMENT OF THE CODE OF ETHICS AND CONDUCT

In order to encourage living our values and to structure a means to solve the ethical dilemmas, this section establishes a mechanism to manage Rassini’s Code of Ethics and Conduct.

Any suggestion, doubt and/or clarification regarding the contents of this document shall be addressed by the Corporate Human Resources Management

8.1. Procedure for Queries, Suggestions or Complaints against Violations to the Code

Rassini’s Code of Ethics and Conduct is applicable to the company, and it is our responsibility to comply with it and to enforce it. To this end, a platform called Integrity has been created, where multiple communication channels have been established, which may be used by collaborators to evidence inappropriate behavior in the company.

It is not always easy to define and judge if a situation violates the law, ethics or the provisions of this document; therefore, any doubts about the legal and/or ethical nature of a situation should be immediately reported through the Integrity platform.

Rassini encourages its collaborators to report immediately any evidence they have about violations to this Code of Ethics and Conduct.

When issuing a complaint, it is necessary to have all the information on the case by answering the questions Who? When? Where? How? as well as the material evidence in case of having it.

The channels available for complaints are:

A specialist will contact you to provide assessment and/or support, he or she will ask a series of relevant questions in order to obtain appropriate information on the case.

The specialist provides alternatives to collect evidence should the complainant not have any evidence.

Upon filling the complaint, a follow-up number will be provided. By using the number, one can dial the telephone number at any time, or enter the website in the complaint follow-up field, to:

  • Know the status of the investigation.
  • Provide additional information.
  • Repeated complaints.
  • Attach files and evidence.

Rassini’s collaborators are committed to cooperate in the internal investigations on the subject matter.

Rassini will guarantee there shall not be any type of retaliation, threat or intimidation due to reports sent to the Ethics and Conduct Committee through the channels provided by Integrity. An open communication of situations and concerns by the collaborators, without fear of negative consequences, is vital for the proper implementation of this Code of Ethics and Conduct.

8.2. System of Consequences

Living our values intensely benefits us personally and those around us; Rassini encourages it and it publicly acknowledges exceptional cases.

When a person incurs in a breach to the Code of Ethics and Conduct and/or to the Internal Labor Regulations or to any applicable laws in force, the penalty will range from a warning to dismissal or the corresponding legal actions, depending on the seriousness of the fault.

In Rassini, the immediate superior must be an example in the practice and endorsement of the values promoted by this Code of Ethics and Conduct; he or she must recognize employees when they practice these values and impose penalties promptly in case the staff under his/her supervision has incurred in any defaulting behavior. Any omission by Rassini’s collaborators in reporting a violation to the Code of Ethics and Conduct constitutes by itself, a violation by omission or complicity.

8.3. Administrative Structure of the Code of Ethics and Conduct.

The administration of the Code of Ethics and Conduct is in charge of the following persons or entities:
  • Immediate Superior
  • Human Resource Areas of the corresponding Business Unit
  • Rassini’s Ethics and Conduct Committee

Rassini’s Ethics and Conduct Committee shall be considered an “Ombudsman” institution, that is to say, it will act as a representative and mediator of the collaborators’ interests. This committee will provide certainty to the procedure in processing complaints for violations to this Code of Ethics and Conduct.

The Ethics and Conduct Committee is responsible to ensure that this Code of Ethics and Conduct is dully disseminated and applied, this means:

  • Promoting the values and behavior set forth in this document.
  • Acting as an advisory body.
  • Channeling cases to the appropriate instance.
  • Approving corrective measures to guarantee consistency.
  • Generating statistics and reports.
  • Reviewing requests for clarification from the staff.
  • Reviewing investigations.

In addition to the aforesaid tasks, Rassini’s Ethics and Conduct Committee, has also the following duties:

  • To update and amend the Code of Ethics and Conduct.
  • To investigate and document cases selectively.
  • To promote consistency at worldwide level, in respect to the interpretation and application of this Code of Ethics and Conduct.

To adequately manage its duties, the Committee is constituted with five individuals of Rassini, from different areas, who stand out for their exemplary career, are highly recognized and honorable, have also a comprehensive business vision and are fully committed to their duties.

The members of Rassini’s Ethics and Conduct Committee are appointed by the General Management, which will chair said Committee. The Committee is governed by the Policies and Guidelines of the Ethics Committee (Políticas y Lineamientos del Comité de Ética).

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