Internal Standard for Responsible Practices

Introduction

Corporations are currently being encouraged to promote the good actions of all their factors to promote the good ethical values of their employees and thus cooperate in the prevention of corruption inside and outside the companies.

This “Internal Standard for Responsible Practices for Grupo Palval Personnel” (hereinafter the Standard), Grupo Palval promotes the search for professional, ethical and responsible behavior of its employees in the development of the company’s activities.

The following rule is not intended to oblige, but rather to guide, the standards of conduct that Grupo Palval expects of its employees.

The standard has been approved by the board of directors of Palval S.A.S. And it will be governed by the Grupo Palval as well as by all the Grupo Palval business units without having to be named.

Terminology

The terminology of the following standard will be understood as follows:

• Palval. – Palval S.A.S, a simplified joint stock company domiciled at Carrera 2 nº 20-22, Barrio San Nicolás, Santiago de Cali (Colombia). Registered in the Mercantile Registry of the Cali Chamber of Commerce, with Tax Identification Number (Nit): 900.572.032-4.

• Grupo Palval.- All companies with trademarks or commercial names that do not express the word “Palval” and / or the business units of the Palval Group of companies that do express the word “Palval”. Except where the contrary is established, the terms “company” or “society” are understood as including the companies or business units of the Grupo Palval.

• Staff or employees. – All those who are directly or indirectly working in functions corresponding to the activities of the Grupo Palval regardless of their fixed contracting method or for services and / or through a third party that serves as a subcontractor. 

Assumption of the code of conduct

The Internal Code of Conduct is the ethical commitment that deals with the basic principles for the development of relationships between the Grupo Palval and its main stakeholders: (employees, customers, shareholders, business partners, suppliers, and those companies in which developing its business model).

The standard summarizes the code of conduct and the main interests of Grupo Palval.

– All the activities of the Grupo Palval will be carried out under an ethical and responsible scheme.

– All individuals, natural and legal, who directly or indirectly sustain any labor, economic, social and / or industrial relationship with Grupo Palval, will receive fair and dignified treatment.

– All the activities of the Grupo Palval will be carried out in the best way in order to respect the environment.

Internal code of conduct

• Employees

The Grupo Palval guarantees the safety in which its employees carry out work activities.

In Grupo Palval no person will be discriminated against because of sex, physical disability, religion, age, race or / or nationality.

In the Grupo Palval, any form of physical, sexual, psychological or verbal harassment or abuse is not allowed.

The Palval Group will not create employment for minors.

The salaries that are determined for the employees of the Palval Group are in accordance with their function performed.

• Business partners

The Grupo Palval ensures that each of its business partners complies with all the points described in this code of conduct.

• Suppliers

All suppliers of any of the Grupo Palval business units are obliged to abide by this code, with respect to the codes of conduct for employees and customers. They are willing to be supervised by Palval or a third party that certifies their work.

• Customers

The Grupo Palval is committed to offering all its customers a standard of excellence in all its products.

• Society

The Grupo Palval is committed to working responsibly for the sustainability of the societies in which we work.

Magnitude of application

The standard will apply to all companies, companies and / or business units that make up the Palval Group. It will cover all its employees, the directors will be notified in writing and will accept compliance with signature and fingerprint to promote legal compliance with the standard. Its application, in full, may be extended to any natural and / or legal person related to the Palval Group when it is convenient for the fulfillment of this and it is possible according to the existing relationship.

The rule will not lead to any exemption from compliance with it for any reason.

Compliance with legislation

In order to comply with this Standard, the employees of the Palval Group shall comply with the legislation in force in each of the countries in which the company carries out its production, distribution and marketing activities and, in doing so, shall respect its essence.

Relations between employees and with clients

Labor relations between employees and with clients must be governed, according to criteria of respect, dignity and justice, taking into account the different cultural sensitivities of each individual. Any form of violence, harassment or abuse at work, nor discrimination based on sex, age, religion, nationality, race or any other personal or social condition prohibited by law will not be tolerable. Special consideration will be given to the care and labor integration of people with disabilities or handicapped people.

Communication with suppliers

Grupo Palval employees will interact with their suppliers of goods and services in a respectful, lawful and ethical manner.

Communication with authorities

Grupo Palval employees will interact with the authorities of public institutions in a respectful, ethical and lawful manner.

Respect for employee privacy

The Grupo Palval respects the private life of its staff and of course the integrity in making its decisions.

Freedom of democracy

The Grupo Palval is shown with a position based on the principles of legality and neutrality.

You consent to the right of employees to participate in legal political activities. The Grupo Palval allows the development of democracy as long as they do not interfere with the company’s activities.

Confidentiality of information

The employees of the Grupo Palval are obliged to refrain from using for their own benefit and from communicating in any way, any type of information or document obtained during the work carried out in the Grupo Palval.

The obligation of confidentiality will remain even after the work activity within the Grupo Palval has concluded and you must return any material related to the Grupo Palval that the employee has in their possession at the time of the termination of the employment relationship.

Operations log

The employees of the Grupo Palval have the obligation to record all the economic operations that they carry out on behalf of the company, that there is clarity and accuracy in appropriate accounting records that represent the legal image of the transactions carried out and are available to the auditors.

Compliance with the standard and publication

The standard will be sent to all employees in Spanish and English, it will always be published on the Grupo Palval web pages and will be put into practice throughout the organization.

In order to guarantee compliance with this standard.

The board of directors authorizes the power to the presidency and therefore the regular channel previously authorized under the minutes, to transmit the norm to all employees by different means; physical mail or by e-mail.

In the same way, the regular conduct governed under the standard has the power to correct the breaches in which the employees incur, under the seriousness of the case the pertinent decisions will be made for the continuous improvement of the company’s work activities and good performance of the formal communication of Grupo Palval.