Invexans has adopted the following Code of Ethics (“Code”) for its employees, understanding as employee as any person with which the Company has a labor contract. The norms under this Code apply specially to the managers of the company and in general to all employees whose work is similar to those of the aforementioned within the Company’s line of business, notwithstanding the denomination received. Understanding that no code or policy can anticipate each possible situation that can arise within a company, this code must serve as a set of principles to guide the employees’ actions, which must adhere to the main principles here indicated in order to avoid unpropper behaviors.
The CEO of the company has the responsibility to verify on an annual basis that (i) each employee receives a copy of the Code; (ii) the existence of standard procedures which facilitate the compliance of this Code; and (iii) that there are adequate formal communication channels established to inform conducts or behaviors that violate the principles established in the Code.
2. CONFLICT OF INTEREST
All employees must at all times be aware of situations that could comprise the trust deposited in them by the Company, and prevent all kinds of conflicts between their own interests and those of Invexans.
There is a conflict of interest when an employee (or members of his family or third parties related) owns interest interferes, or appears to interfere in any way with the Company’s interests.
In the eventuality of a conflict of interests, employees must reveal the problem conveniently to their immediate superior, and will abstain themselves to continue involved in such conflict of interests.
In matters related to this area, employees must guide themselves by the general rules and policies established within the Code, and by principles, moral and good faith.
3. PRIVILEDGED INFORMATION
Understood as privileged information is any information related to Invexans, its business or the securities issued by the Company, that has not been disclosed to the market, and whose knowledge given the nature of such information can affect the value of the securities issued, as well as all information which the Board of Directors has classified as confidential.
Employees must keep under strict confidentiality all privileged information, and cannot use it for own or third party related benefit, and will not purchase directly or indirectly, for them or related third parties, any securities over which they have privileged information. They cannot use such information to compete with the Company.
All information owned by Invexans which is not public and that has been trusted by the Company to the employee, and whose disclosure to third parties could be harmful to the interests of the Company, or to people who maintain commercial relationships or pending negotiations with the Company is considered confidential. Information delivered by third parties under confidentiality or similar agreements is also considered confidential.
Employees are forbidden to disclose confidential information to people that are not related to the Company, except when the disclosure is necessary due to normal course of business, and due measures have been taken, or when it is mandatory to inform the authorities in conformity with legal standards or other requirements.
5. FAIR COMPETITION
Invexans recognizes and values the importance of laws that encourage free trade, and that prohibit predatory economic activities as well as unfair and improper practices. Under this context, each employee must encourage fair play when dealing with clients, suppliers, competition and employees. They cannot take advantage of none of them by manipulating, hiding and abusing of privileged information, falsehood of material facts or any other unfair practice.
6. APPROPIATE USE AND PROTECTION OF THE COMPANY’S ASSETS
All employees must protect the assets of Invexans, and ensure the efficient use of them. Theft, carelessness, and losses have a direct impact in the Company’s profitability. All the Company’s assets must be used exclusively for the Company’s nature of business.
7. COMPLIANCE WITH LAWS, NORMS AND REGULATIONS
The employees at all times must comply with the legal dispositions related to the functions each employee has within the Company.
All employees must be in extreme careful to ensure themselves that any information prepared or delivered, specially information that is presented to the shareholders and disclosed or published to the market, as well as that delivered to regulatory entities in Chile and abroad, are trustworthy, reliable, precise and sufficient.
8. REVELATION OF ILLEGAL OR NON-ETHICAL BEHAVIORS
All employees must reveal on a timely basis any situation known by them that could be in conflict with the standards of this Code, related to them or a third party. Such revelation must be done through the formal communication channel established within the Company for such purposes.
Employees must discuss on a timely basis with their immediate superiors in case of doubt over any situation that could enter in conflict with the norms established within this Code.
It is the Company’s responsibility to maintain appropriate communication channels, so that any employee can inform any actions performed by third parties that violate the principles established within the Code, assuring anonymity in the presentation of adequate information, which sustain such accusation.