Code of Conduct and Ethics

Preamble 

The purpose of this code is to establish standards on the conduct and ethics that workers, apprentices, interns and thesis students must observe in the performance of their duties. Likewise, it is intended to preserve the excellent image of Polinter before the Bolivarian Republic of Venezuela and the world.

Ethics is an ideal of human conduct, which guides each person on what is good, what is correct and what they should do, it is conceived as the executing arm of morality, which is the search for the commonwealth.

Work ethics guide both decision making (what I should do) and the process that follows once the decision is made (how I should do it).

Our Constitution of the Bolivarian Republic of Venezuela establishes the supreme goal of refunding the republic to establish a democratic, participatory, leading, multiethnic and pluricultural society in a State of justice, federal and decentralized, which consolidates the values ​​of freedom, independence, peace, solidarity, common good, territorial integrity, coexistence and the rule of law for this and future generations.

The preamble establishes the right to life, work, culture, education, social justice and equality without discrimination or subordination.

This normative instrument of Polinter incorporates some values ​​that the constitution of the Bolivarian Republic of Venezuela, in its Article 2, promulgates as superior values ​​of the legal system and its actions, among them: justice, equality, solidarity, social and general responsibility, preeminence of human rights and ethics.

The constitutional text mentions the values ​​of ethics, this implies that beyond legal norms there must be a set of ethical norms that guide officials, workers and the State itself in the transformation of the State.

In their actions, each individual has their own pattern of values, but every worker must make their behavior compatible with corporate values, Polinter’s code of Conduct and Ethics, strategic objectives, the company’s internal rules and the applicable legislation.

It should be noted that this code is mandatory for all of us who make up the Polinter family to comply with. It establishes the moral instructions that will guide the conduct and behavior of employees with the purpose of creating a corporate culture based on a system of values. This code aligns with Polinter’s vision, mission, motto and values ​​described below.

Vision: By the year 2036, Polinter will be a leader in the Venezuelan market and will be positioned among the leading countries in Latin America in the production and marketing of high-quality polyethylenes and polymer mixtures, contributing to turning Venezuela into a petrochemical power in promoting its development.

Mission: Sustainably produce and market high-quality polyethylenes and polymer blends to contribute to the success of our customers and promote the development of Venezuela.

Motto: Polyethylenes for the development of the country.

Organizational values ​​are elements that govern the behavior of the entire Polinter family, among them we have the following six values:

 Excellence: At Polinter, we permanently seek the excellence, with the aim of achieving superior quality in the development of our activities. Excellence drives us to be better every day, it is closely related to perfection and is expressed in the outstanding characteristics of our products and services, being the result of the effort of a motivated, committed, innovative and highly qualified team.

Security: At Polinter, safety is an attitude that translates into the behavior of our workers to internalize personal and professional protection, in accordance with current standards, in order to ensure health, the integrity of the facilities and the prevention of the environment.

Commitment: At Polinter, we assume the company’s objectives as our own and work enthusiastically to achieve them. Our efforts extend to the community, contributing in solidarity to satisfy the needs of our social environment. Respect: At Polinter, we treat others as we expect to be treated. We recognize, accept, appreciate and highly value the qualities, opinions and rights of others.

Responsibility: At Polinter, we efficiently fulfill our obligations and fully assume the consequences of our decisions.

Honesty: At Polinter, we act permanently attached to the truth and moral and ethical principles. We characterize ourselves for being fair and incorruptible.  The board of directors of Poliolefinas Internacionales, C.A (Polinter), in exercise of its powers conferred on them by the Corporate States, decrees the following Code of Conduct and Ethics of Polinter.

The board of directors of Poliolefinas Internacionales, C.A (Polinter), in exercise of its powers conferred on them by the Corporate States, decrees the following Code of Conduct and Ethics of Polinter.

Title I

General Dispositions

Article 1: The rules contained in this code will be mandatory for all Polinter’s workers regardless of the position or function they occupy, as well as for those who are carrying out tasks with the company for a specific period of time or a specific job. The provisions established here may not be relaxed by agreements of any kind.

Article 2: This code must be known by all Polinter’s workers, and it is expressly established that ignorance of it does not excuse its compliance. Every new worker (permanent, contracted, subcontracted, intern, thesis student and apprentice) will receive an induction on the rules of Ethics and Conduct at Polinter before carrying out any activity within the company.

Article 3: This narrative instrument has the following ethical objectives:

1.    Be a formal and institutional reference for personal and professional conduct.

2.    Enable ethical behavior based on corporate values.

3.    Reduce the subjectivities of personal interpretations of moral and ethical principles.

4.    Consolidate the identity and image of Polinter, in relation to its public of interest.

Title II

Conduct Guidelines

Article 4: In his conduct, the worker gives an example of his vocation for service and his commitment to Polinter’s guiding values.  Article 5: They constitute serious offenses, which entail disciplinary actions, including dismissal and civil and/or criminal sanctions for violations of the provisions of this code.

Chapter I  Relationship at Work

Article 6: The duties of every Polinter worker are:

1. Act with honesty, discretion, effectiveness, truthfulness, and loyalty.
2. Maintain respect for his dignity as a person and as a professional at all times.
3. Comply and unsure compliance with this code.
4. Strengthen the fraternity with your coworkers, through mutual respect, collaboration, transparent attitude, cordial treatment and rational tolerance.
5. Perform their role with an entrepreneurial spirit, overcoming challenges and protecting the interest of the company.
6. Develop tasks based on Polinter’s strategic objectives, without using the position, function, activity, assets or influence to obtain personal benefits or for third parties.
7. Respect the work carried out by each person.
8. Maintain the confidentially of all information accessed in tasks, in accordance with the company regulations.
9. Efficiently use assets and information, and ensure that records and reports are reliable and accurate in accordance with the legitimate purposes of the company, without altering or falsifying the content of a document, information or data.
10. Preserve the company’s assets, translated in terms of equipment, materials, technological and strategic information and operational facilities.
11. Promote actions that improve internal communication, integration and the development of teamwork.
12. Take responsibility for every document you sign and seal.

Article 7: The worker must act courteously, with availability and attention towards all the people with whom he interacts, respecting individual differences.

Article 8: The worker must be loyal to his coworkers, supervisors or managers. Likewise, he must recognize the merits of the work done by other people.

Article 9: No worker should harm the reputation of any member of the company through defamation, libel, preconceptions, false testimony, unsubstantiated information or in any other way. Note: Defamation and insult are subject to criminal sanctions provided in the Penal Code.

Article 10: The worker must not obtain favors in exchange for personal commitments or obligations.

Article 11: Every Manager, Superintendent or Supervisor will encourage his/her supervisees or personnel under his/her charge to generate ideas in accordance with the company’s objectives, even if they represent significant changes to the status quo. Such ideas must be channeled through formal meals.

Article 12: Ownership of the inventions or service or business improvements will correspond to Polinter, but the inventor will have the right to a participation in their enjoyment when the remuneration for the work provided by his is disproportionate to the magnitude of the result.

Article 13: Discrimination based on race, sex, creed, social condition, color, age, beliefs or any other form of discrimination is prohibited. If a worker suspects that he is being discriminated, he must immediately inform his supervisor or the company’s human resources.

Article 14: Pressure, threats or harassment of any kind are expressly prohibited.

Article 15: Moral harassment is prohibited, understood as the act of disqualifying through words, gestures or attitudes, the self-teem, security or image of the employee. Anyone who is victim of this type of action must formalize the complaint to their supervisor or the company’s Human Resources Management.

Article 16: Every worker must respect the company’s values, without giving in to pressures that promote obtaining undue advantages.

Article 17: Constructive criticism may be made, carried out in a transparent manner and through appropriate channels, as a demonstration of loyalty to the company and its members.

Article 18: The error must be tolerated, but the cause that generated it must be investigated and its repetition avoided.

Article 19: Every worker must request help from other members of the company when he does not consider himself capable of carrying out a task, in order to obtain the means to overcome these limitations.

Article 20: The corresponding management will systematically evaluate both errors and successes, with the aim of continually improving the quality of work.

Article 21: Workers will be guaranteed the right to know the results of the evaluation of their performance. To achieve this, a transparent performance management process is adopted, with individual guidance to the employee on matters that directly or indirectly influence the result of their work.

Article 22: Polinter will guarantee its workers the right to know the criteria for promotions and their evaluation according to those criteria.

Article 23:  The efforts of workers to improve the results of their work are valued and recognition for their performance is promoted.

Article 24: It will be guarantee that personal, administrative, medical and benefits information will be confidential and only the personal responsible for the custody, maintenance and treatment of that information will have access. The request, analysis and transfer of this information can only be carried out by someone who has the legitimacy to do so, according to the exact terms of the legislation and regulatory provisions, by virtue of being presented as evidence in a trial, in accordance with the guidance of the area. Every worker will be guaranteed access to his or her own information.

Article 25: The personal data of the workers will be kept permanently updated, and they will collaborate by providing information on any changes they may have.

Article 26: Workers will be guaranteed the right to request and receive the necessary clarifications about their rights and interests.

Article 27: Workers will be guaranteed an adequate work environment, characterized by safety, hygiene, health and well-being. In the event that there are situations where the life and/or physical integrity of one or more members of the company are at serious imminent risk, the carrying out of activities may be suspended by taking the necessary corrective measures and immediately communicating the fact to the immediate superior.

Article 28: Polinter promotes institutional communication through physical and electronic media, which expedite the exchange of information, facilitate knowledge management and allows people to get closer and participate. But the confidentiality of the information must be preserved responsibly, without disclosing messages that contain pornographic, racist, illegal, political or other similar content.

Article 29: All workers must attend their workplace with appropriate clothing and personal appearance. This implies that workers must take into account the type of activity they carry out and the public with whom they are in contact.

Chapter II

Relationship with Society

Article 30: Both Polinter and its workers undertake to faithfully and respectfully comply with all laws and regulations applicable in the Bolivarian Republic of Venezuela and with the legislation of the country where they must carry the activity.

Article 31: Any costumer, partner, supplier and even competition deserves respectful and cordial treatment. We must constantly strive to improve communication processes and interpersonal relationships.

Article 32: Any client or supplier waiting for a solution must be kept informed of actions being taken. The response issued to suppliers, clients, service providers and others must be truthful and deceptions that cause delays or harm in the exercise of their rights will not be used.

Article 33: All negotiations carried out on behalf of Polinter must be carried out through honest practices. Failure to comply with this provision will result in dismissal and/or criminal actions.

Article 34: The people responsible for providing information to clients, suppliers, competitors and shareholders can only inform and/or forward documents to the external public when they are duly authorized by the company, always identifying the authorship. The information provided must be true, making it equally available to all interested parties. If you are not authorized to answer a query, the applicant must be informed of this situation. Public information from the company may be retransmitted equitably to interest parties, in the case of well-founded procedures and analysis.

Article 35: The dissemination of strategic and confidential information that has not been published by Polinter is prohibited. This type of information can only be issued when the task requires it, with prior approval from the corresponding management, as long as a confidentially agreement is stipulated.

Article 36: No worker should get involved in activities or situations where his or her individual interest interfere with those of Polinter.

Article 37: Every worker must perform his or her function on behalf of the company, without providing technical assistance or consulting of any kind to suppliers, clients, current Polinter’s service providers or those who are in the process of entering or participating in tenders expect when authorized by the respective managements.

Article 38: The resources with which we work (information, technology, equipment) are used for work in accordance with the company’s purposes and not for particular interest.

Article 39: When engaged in the exercise of professional activity, it is prohibited to make comments regarding the competition or the quality performance of its products. If a formal statement from the company is necessary, it will be approved by a management meeting.

Article 40: If there are direct family members in the same company, the relationship must be expressed and it must be avoided that any of them are assigned to a position in which they have the opportunity to control, review and/or approve the work of the other, or may influence about a salary increase or promotion.

Article 41: Any situation that represents a potential conflict of interest must be communicated to the immediate superior or the respective management.

Article 42: All Polinter workers are expressly prohibited from:

1. Accept personal invitations for accommodations, trips or other attractions that may cause damage to the image and/or interest of the company.
2. Be influenced by personal relationships with clients, suppliers, partners or competitors in decision making.
3. Maintain private commercial relationships with clients, suppliers or competitors of the company in which personal privilege can be obtained, due to the position or function held.
4. Become a partner, manager, advisor or intermediary of any entity that carries out transactions or is a competitor of Polinter in the production of goods and services.
5. Receive, request or suggest any type of financial aid, gratuity, prize, commission, donation, present or benefit of any kind personally or intended for family members or another person, in the exercise of professional activities. Likewise, it is prohibited to influence another member of the company in decision making following the same purpose.
6. Use information to which you have access as result of the powers or functions, to obtain private benefits for relatives or third parties.
7. Accept gifts from clients, suppliers or competitors except gifts that are clearly identified or with a commercial value of no more than ten (10) tax units (TU). Those of significant value that for any reason cannot be returned will be compulsorily incorporated into the company’s assets.
8. Make suggestions to clients, suppliers or partners that lead to the hiring of consultants or personnel with a particular interest.

Article 43: Contacts with former Pointer’s employees, through business or personal relationships, will not influence any decision of the company or lead to access to privileged information.

Article 44: Gifts, entertainment and/or hospitality provided by the company to any person, organization or company with which institutional relations are maintained, may be made as long as they are not money (whatever the amount), that they do not have significant value and that they are not a condition or result of business. It must have the proper authorization and be recorded in the corresponding accounting books.

Article 45: Polinter management, with the support of workers, must seek increasing levels of competitiveness and profitability, in order to remunerate shareholders fairly and compatible with the capital invested. In every worker, the social interest of Polinter and the common interest of the shareholders must prevail over any other interest.

Article 46: To disseminate or provide strategic or confidential information about Polinter, including granting interviews, you must have specific authorization from the company’s General Manager. He will advise regarding the need and form of response, and will indicate the person who will act as spokesperson.

Article 47: In the event that interviews are granted in a personal capacity, articles that are published or any other form of public demonstration is used, the Polinter company should not be named, in favor of preserving its interests and image and avoiding any negative impact on the same.

Article 48: Polinter will seek to support the actions carried out for the exercise of citizenship and for local, regional and national development, especially those aimed at improving the living conditions of the communities where it operates. Also promotes corporate activities, to encourage participation behaviors and social commitment in the members of the company.

Chapter III

Ethical Behavior

Article 49: The guidelines developed in this code of Conduct and Ethics at Polinter allow us to improve the quality of relationships, for the exercise of citizenship and business success.

Article 50: Personnel who have questions regarding the application or interpretation of any provision of this code must immediately contact their Supervisor or Human Resources Management.

Article 51: Any attempted bribery, irregularity or possible irregular behavior, contrary to the interests of Polinter and that implies a breach of this code, legal rules and/or regulations; It will have to be communicated to the Internal Audit Administration, supported by reliable evidence. If it has been reported to the direct superior or the respective management, they will be the ones who will have to communicate it to the Internal Audit.

Article 52: The worker who knows of any fact that violates the prohibitions of this code has the duty to immediately communicate the information to his/her Supervisor. Polinter will not allow any retaliatory actions or harassment against the person who, in good faith, reports an activity that it suspects violates the law or the company’s regulations, including the regulations established in this code.

Article 53: An Ethics Commission will be created in charge of promoting this code of Conduct and Ethics at Polinter, preventing acts contrary to it, including resolving queries that may arise regarding the aforementioned code. Upon entry into force of this code, the Ethics Commission must promote training courses on the same. The Ethics Commission will be made up of seven (07) workers, who will be designated by each management of the company.

­Title III

Final Provisions

Article 54: The effective application and compliance of this code is the responsibility of the President, Directors, General Manager and functional managers within the company. The general responsibility for the implementation, control, and maintenance of this code corresponds to the company’s Human Resources Management.

Article 55: The rules of this code may only be modified by the Board of Directors of Poliolefinas Internacionales, C.A (Polinter).

Article 56: This code will come into force on the First (01) day of January of the year Two Thousand and Seven. Given, signed and sealed on the Seventeenth (17th) day of the month of July of the year Two Thousand and Six.