Letter from the Board

In Process Technologies we are devoted to helping our clients in projects that improve their organization processes, the control of their operations and the management of the business.

As the company we are and as the people committed to it, we declare the following Values inalienable:

• Honesty: So that the decisions that are taken and the actions that are carried out are not at odds with the customs of decency.
• Transparency: So that every act carried out by the company and its staff always shows a deep respect towards direct deals, without concealment or perks.
• Business Ethics: So that the respect for the undertaken commitments continues with the ethical behavior of the intervening people both in business or commercial operations.
• Efficiency: So that the company and its staff strive to become a better version of themselves at all times, constantly perfecting our productive order.
• Compromise: With our staff, clients, partners and friends in making a duty of the effort of improving, day by day, on the path of progress.
• Creativity: To give our biggest effort to productive innovation.

We serve our clients, we generate sustainable value for our investors and we contribute to the sustainability of the community. All this is possible thanks to our commitment with said values, which are our guide to reach the objectives, face our challenges and their risks, as well as to find answers to the ethical dilemmas we might face in a company which manages its businesses in a complex and dynamic world.

Our reputation and sustainability depend on each and every one of us living our values and having an ethical and responsible behavior in compliance with the law.

We have established a Code of Conduct, which will help us take the right decisions as a company, under a strict ethical conduct in every action that we undertake. We must foster diversity and equality. We have zero tolerance for corruption. We respect the environment in all that we do, and our services, our technology and our staff should positively contribute to encourage human rights.

Our Code of Ethics represents the culture and compromise we have to continue with the quality services that our clients value and with the way to do business in our Company.

Introduction

Process Technologies knows the importance and the impact that their management and that of their chain of value has in the Company. Therefore, it encourages, establishes and keeps high levels of liability requirements, based on the universal ethical principles inspired in Transparency, Integrity and Honesty when doing Business, encouraging compliance, not only in the quality standards of product and/or services, but also in ethical, social and environmental standards. All this is reflected in the compliance of the ISO Standard 9001-2015 which governs all business processes of Process Technologies since 2006.

This Code seeks to obtain sustainable relationships and of mutual benefit with clients, providers, and further acting bodies of the Company, and to establish elevated standards regarding an ethical and transparent behavior, not only on behalf of the Company itself and its collaborators, but also, on behalf of its business partners.

Ethical principlesPrincipios éticos

2.1.  We carry out our activities in accordance with the values and principles found in this Code of Ethics and Conduct, keeping the highest level of professional norms in the way to do business.

2.2.  The activity is carried out pursuant the applicable law and ethical principles of universal acceptance, inspired in transparency, integrity and honesty.

2.3.  We reject and condemn the use of illicit or dishonest behavior and we avoid every action that promotes, shares or tolerates any form of fraud, irregularity or corruption.

2.4.   We guide our actions with the guidelines of the Global Pact of the United Nations, and their principles when it comes to human rights, labor standards, protection of the environment and fight against corruption. In this way, we guarantee full compliance with our institutional commitment and encourage Third Parties to adopt the same practices.

2.5.  Services to the Clients must be of excellence, with the creation of value for the shareholder and the community in which we operate, respecting the rights and the good treatment that assists them.

2.6.  We believe in fair Competition, which we consider a functional tool for the interest of every acting body of the market, the clients and the Company in General.

2.7.  We assure the fulfillment of the Antitrust Laws and we do not allow for Third Parties, on our behalf or representation, to execute an agreement with other Companies in matters such as prices, selling conditions for clients and granting markets to clients, thus, ensuring the antitrust laws.

Anti-corruption

3.1.  We have an anti-corruption Policy and we commit to respecting the laws of conduct which are established in the Criminal Liability of Legal Persons Act [Ley de Responsabilidad Penal de las Personas Jurídicas] in Argentina, the anti-corruption acts and the acts against money laundering.

3.2.  We forbid any attempt to corrupt Public Officials and the payment of bribes or illicit commissions, whether its favors to Public Officials or Private Persons.

3.3.  Third Parties will be governed by a conduct based on high ethical standards and shall comply with all applicable anti-corruption laws. It’s specifically prohibited to offer, promise, pay, deliver or authorize the delivery, accept, expect or ask, directly or indirectly, compensation, presents, personal economic benefits or of any nature to/from Public Officials, Private Persons, or the entity which you directly or indirectly represent, to influence a decision or to obtain or retain business or any other undue advantage.

3.4.  We shall not make contributions of any nature, nor grant any other kind of benefit, directly or indirectly, to political parties or movements, nor to their representatives or candidates, on behalf or representation of the Company.

3.5.  This code of Ethics and Conduct adheres to the rules of the Foreign Corrupt Practices Act (FCPA) of the United States and the United Kingdom Bribery Act (UKBA).

3.6.   The members of Process Technologies should reach out to their supervisor and give notice to the email “etica@protech.com.ar” in the following cases:

• If they find irregularities in the invoices such as in the description or amounts which they believe do not correspond to the formal agreements
• Any reimbursement request which has no receipt
• Any reimbursement request with amounts which seem high with regards to the services that were offered
• Records which indicate that the items were classified wrongly or were valued at a lower selling price than those items imported to other countries
• Records which are not kept correctly
• Comments from the person who sends the invoice which indicates that improper payments were made
• Insistence on invoices being paid or reimbursements being issued, even after you have raised concerns regarding their validity
• Items which have happened too fast in comparison to former experiences

Fraud and irregularities

4.1.  We have zero tolerance for acts of fraud or irregularities and the cover-up of these, and the same is expected of Third Parties. We also have mechanisms to help prevent, detect and treat these risks.

4.2.  Fraud: it is any conduct, by intentional action or omission, aimed at obtaining, though trickery, deception or breach of trust, an undue benefit, causing damage to the Company.

4.3.  Irregularities: include the actions which intentionally violate the current legislation, internal rules of the Company and/or this Code, if they are carried out with the purpose of harming the Company, the Company’s employees, a Third Party and/or in order to procure an undue benefit for the author of the action, a member of the Company and/or a Third Party. Likewise, it might be considered an Irregularity when the conduct stems from recklessness, negligence, inexperience in all serious cases, or from the non-observance of regulations or duties, when due to the action or omission derives an undue benefit for the perpetrator or for Third Parties and/or causes or could cause damage to the Company.

Conflicts of interest

5.1.  Every business operation must be carried out with the Company’s best interests in mind. Directors, Executive Officers and all Employees, whichever their hiring modality, are obliged to declare any possible conflict of interest before the selection and/or hiring process begins.

5.2.  The conflict occurs when interests of the Employee or Third Party are opposed to or interfere, in any way, with the interests of the Company, causing damage to the latter. The main risk of a conflict of interest is that it might hinder the decision making or it might interfere with doing the job in an objective and efficient way.

5.3.   The Employee or Third Party shall not behave in ways that might represent a damage, although potential, to the image of the Company.

Entertainments (Gifts, events, trips and representation expenses)

6.1.  The Company’s Personnel cannot accept gifts, invitations to events or trips when these are offered in order to influence any act or decision to carry out or omit any action in violation of their legitimate duty, or to obtain any undue advantage.

6.2.  The Company’s Personnel can only receive gifts or entertainments, when these are reasonable, of modest value and made in good faith. The invitations offered must be exclusively linked to business purposes.

6.3.  Under no circumstances can the entertainments be sums of money in cash and/or luxury goods.

6.4.  To entertain the relatives of the Company’s Personnel, or Public Officials on behalf of and/or in representation of the Company is not allowed.

6.5.  Third Parties may not offer gifts or invitations which are not of modest value to the Employees of the Company, and they are forbidden from offering them to Public Officials, Private Persons acting on behalf of and/or in representation of the Company. Offering gifts or entertainment during public bidding or contract negotiations is prohibited.

Information confidentialityConfidencialidad de la información

7.1.  Directors, Executive Officers and all Employees and Third Parties, shall protect and maintain in strict confidentiality the information owned by the Company and the personal data of the clients to which they have access due to the business relationship. Employees and Third Parties understand that it is illegal to use privileged information (i.e. information which is not of public knowledge) related to the Company, its operations, its financial situation, its results or relevant events that involve them.

Workers rights

8.1.   We value the Human Workforce. We are aware that the main key to success in any company is the professional contribution of the people who work in it, and we promote fundamental human and labor rights recognized internationally, and we comply with the obligations arising from labor laws, pension, social security, salary, union and any other laws related to labor and business relations.

8.2.  We value the people we work with, respecting differences, in an environment of loyalty and observance of ethical values and trust.

8.3.  Child labor is prohibited. We do not hire children for the development of our activities and we will not allow our Third Parties to do so. Our suppliers must adhere to the local and national laws and regulations regarding minimum working age and not use child labor.

8.4.   We, directly or indirectly through Third Parties who act in its behalf or in its representation, reject any kind of discriminatory practices, guaranteeing equal opportunities in the workplace by disapproving and sanctioning all forms of discrimination or harassment caused due to gender, sexual identity or orientation, ethnic or social origin, nationality, language, marital status, pregnancy, religion, political opinions or of any other nature, belonging to national minorities, special abilities or age. An offensive or intimidating work environment, threats, punishment or any bullying/harassment practice will not be tolerated.

Health, safety and the environment

9.1.  We are bound to comply with all the applicable laws regarding health, safety and the environment. We ensure the implementation of appropriate measures to protect the safety and health of our employees, as well as to mitigate the environmental impact of our business operations to the extent possible.

9.2.  We shall preserve safety and health in the workplace, ensuring respect towards physical and moral integrity and towards the rights and dignity of the workers.

9.3.   We shall take investment and business decisions which are compatible with a responsible use of the resources, respecting the environment and the rights of future generations, pursuant the applicable law in said matter. For that, we will consider the whole circle of life, always avoiding environmental contamination.

Complaints

10.1.  We promote that any act which violates the applicable laws, norms or regulations or any of the provisions established in this Code, shall be denounced, for which we make available the email “etica@protech.com.ar” so that our collaborators or third parties might file a complaint there, knowing that the confidentiality of the information received will be guaranteed.

10.2.  We do not tolerate any kind of retaliation due to claims or complaints made in good faith regarding misconduct, questionable behavior or possible violations of this Code. We shall encourage open communication to discuss any kind of doubts and concerns without fear of negative reactions or retaliation.

10.3.  All cases shall be duly investigated and appropriate measures will be taken when violations are detected.

Implementation/Sanctions

11.1.  Violation of this Policy, Internal Procedures or the applicable regulations, makes the Personnel of the Company personally liable for the direct or indirect damages that such violations cause the Company. These violations will be considered a very serious breach of labor obligations, which according to the circumstances might lead to dismissal. Likewise, they will give rise to the application of sanctions to those responsible, according to the modalities provided by the legislation and collective agreements.

11.2. Compliance with the provisions of this Code by Third Parties is an essential condition for the maintenance of the business relationship with the Company (the Third Party may provide equivalent principles/rules, the Company does not intend to substitute or replace any policy or contractual obligation of the Third Party).

11.3.  Failure to comply with the undertaken obligations shall be considered a serious offense and shall enable the Company to decide: (a) not to hire the Third Party, and/or; (b) to terminate any contract by force of law due to the fault of the Third Party, with the sole obligation to notify said decision in writing, with the Company being empowered to decide to initiate actions for non-compliance and for damages that may have been caused, without prejudice to the enforcement of the corresponding penalties and/or; (c) to eliminate the Third Party from the “Registry of Suppliers”.