Code of ethics

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At Empacadora San Marcos, our principles bespeak of a sense of decorum, commitment, responsibility, honesty, tolerance, coherence, order, loyalty, punctuality and of working together well, basic and necessary values for complying with our daily work harmoniously. For Empacadora San Marcos it is very important to formalize these values by means of a Code of Ethics so as to unify criteria and direct every action of those who collaborate with us towards our common wellbeing. The Code of Ethics requires the personal commitment of each and every one of those collaborating at Empacadora San Marcos to comply personally with it and also invite the others to do it so as to cover each of the basic criteria that integrate it. As for unforeseen situations that do not appear in the present Code of Ethics, it is the Management´s duty to look after them.

The present Code of Ethics has the following goals:

a) Make the workers of Empacadora San Marcos know their ethical obligations to consumers, clients, directors, workmates, suppliers, community and the competition.
b) Establish basic criteria that standardize the ethical behavior of each and every one of the individuals working in our company.
c) Share our ethical values with our consumers, suppliers and the community.

At Empacadora San Marcos, each and every one of us who collaborates is committed to a sense of belonging and responsibility in each and every action because of our values. We are very much aware of the repercussion these values have within the Company as well as in society, thus we communicate them and make them known through the way we behave.
The Values we have at Empacadora San Marcos are:
1. Truthfulness
2. Commitment
3. Responsibility
4. Honesty
5. Tolerance
6. Respect
7. Order
8. Loyalty
9. Teamwork

1.- At Empacadora San Marcos we know that success depends on the quality or our coworkers, reason why we acknowledge the value and dignity of each and every one of them, and commit ourselves to respect their freedom and individuality, as well as to offer an adequate and favorable space for their personal and professional growth, as well as to foster the appreciation of moral values and ethical norms in them.
2.- At Empacadora San Marcos no person at all should be discriminated for reasons of gender, sexual preference, civil status, age, religion, political opinion, social and economic condition, pregnancy, language, dialect, ethnical origins, nationality, curriculum and physical disabilities.
3.- At Empacadora San Marcos we value and foster the active participation of each and every co-worker to achieve the Company’s objectives, respecting diversity in ideas and opinions.
4.- People collaborating at Empacadora San Marcos must follow a personal behavior that implies loyalty, respect, and honesty without touching at any moment and under no circumstance Empacadora San Marcos prestige.
5.- Those who have people under their orders, bear the moral obligation of respecting and protecting them, in addition to always acting with justice and fairness. They should also watch over individual and team tasks looking after the collaborators common interests as well as those of the Company. They must offer a work atmosphere where there is respect and naturalness, where learning is promoted, where motivation, good practices and experience are always shared. They should always bear in mind they have the duty to report any discrepancy with the principles in this Code stated.
6.- At Empacadora San Marcos sexual or labor harassment are forbidden and should immediately be denounced in an attempt to avoid moral damage suffered by those who underwent through it. (Telephone for anonymous complaints 01 8000 710 5555).
7.- Financial information must be truthful and should be dealt with confidentiality and discretion by co-workers handling it.
8.- People working at Empacadora San Marcos must avoid making comments at any moment or gathering (family, social, sportive) regarding any activities taking place within the company itself that may apply detrimentally to the company or any of its members.
9.- Each and everyone who is collaborating at Empacadora San Marcos has the moral and professional duty of reporting in a clear, timely, safe and honest manner all information generated as a result of their own work in relation to reports, processes and indicators; objectives, goals, responsibilities and they must also truthfully reflect reality.
10.- No collaborator may use the Empacadora San Marcos name, neither the equipment, material or company resources in any activity for his personal benefit.
11.- All contact with dishonest people who pretend to or have the possibility of causing damage to Empacadora San Marcos must be avoided. Any eventuality should be reported to the Company. (Call anonymously : 01 800 710 5555).
12.- People collaborating at Empacadora San Marcos must abstain from communicating confidential information related to processes, methods, strategies, plans, projects, technical data, market information, research data, equipment or any other type of information pertaining to the modus operandi of the company.
13.- People collaborating at Empacadora San Marcos have to avoid any activity alien to the Company, that demands an amount of time and effort that may in any way affect their commitment to the Company.
14.- No person working for the Company may have financial or any other sort of interests in a competitor or supplier business.
15.- Empacadora San Marcos encourages civilian collaboration, at the same time favoring a responsible exercise of political rights; nevertheless, collaborators taking part in political activities for any party must be particularly careful of not involving the Company, and must very clearly make known that they are intervening personally and do not represent the company in any way, given that the Company itself does not influence, support or intervene in any way in said activities.
16.- Empacadora San Marcos has committed itself to the ethical behavior of its collaborators so as to minimize the possibility of any risk, both for the company itself and third parties to it related. It is for this reason that it promotes and facilitates detection of illegal practices and/or inappropriate behaviors.
17.- At Empacadora San Marcos we are committed to comply with the outstanding normative requirements that refer to money laundering nationally and world-wide enforced.

a) Functions, Responsibilities and Transparency
1.- At Empacadora San Marcos we recognize the importance of communicating to our co-workers all the information required for complying with their activities, since that is the only way they can involve themselves with the Company’s priority objectives, goals and projects, and work towards achieving them professionally, since the procedures, methods and systems required for the functions to be performed have already been established in Empacadora San Marcos.
2.- Everyone who collaborates at Empacadora San Marcos, regardless of their hierarchical level, is committed to do their work professionally on a daily basis and assuming their responsibility at all moments.

b) Conflicts of Interest
1.- With the purpose of avoiding conflicts between personal interests and those of Empacadora San Marcos, and to propitiate a solution if it were required, each and every one working for the Company have the responsibility of openly declaring any factor or item that could be conflicting by its functioning inside the Company. If anyone considers that there are personal interests that may influence its working performance, they must be communicated in writing to the immediate boss.
2.- Any member of the workers family may also work at Empacadora San Marcos given that:
• There is no relation Boss-Coworker. Collaborators at Empacadora San Marcos must abstain from having relatives or members of their family working under them.
• The member of the family must not work at the same department.
• On the other hand, every worker at Empacadora San Marcos has the obligation of informing its immediate boss if there are any family relations they know of between co-workers.
3.- When a collaborator at Empacadora San Marcos feels himself unable to cover his responsibilities objectively because of being under pressure by third parties who may be using their position, authority or influence in the company, it must be reported to the immediate boss, to the responsible person in Human Resources or by means of the telephone line for denouncing irregularities.
4.- People collaborating at Empacadora San Marcos must abstain themselves from satisfying their superiors, subordinates, co-workers, members of the family or friends requirements if by that action the Company is damaged.
5.- People working at Empacadora San Marcos must abstain themselves of any buying and selling operations with companies owned by their close or once-removed consanguineous members of their family, or politically related to the company’s collaborators, excepting that such companies are competitive as to price, quality and service and are out of the area of responsibility of the relative-collaborator and this fact has been made known to Management.
6.- At Empacadora San Marcos every collaborator has the moral duty of reporting confidentially by phone to the anonymous complaints one (01 800 710 5555) any failure of performance to the Code of Ethics, given that by means of this phone Empacadora San Marcos protects and safeguards anonymity for the person who denounces the denouncement.

c) Relations with the Union
1.- Empacadora San Marcos is committed to respect the Independence of labor associations that represent the legitimate interests of the workers, always looking for the relation to be collaborative and mutually beneficial through formal, direct, clear, responsible and timely relations. People who work at Empacadora San Marcos acting as union representatives, must have as their main objective the individual and collective wellbeing, as well as the common welfare for all, over and above their personal interests.

d) Relations with Customers - Clients
1.- People who collaborate at Empacadora San Marcos who look after our customer’s needs, should offer an ethical and honest deal in each service, thus establishing a lasting relations and offering the products and services of his area with the greatest quality and timeliness attainable, never forgetting that these clients are strategic allies for the growth and development of Empacadora San Marcos.
2.- People who collaborate at Empacadora San Marcos must avoid voicing tricky or false comparisons with equivalent products or services to those offered by our competitors.
3.- Any person who collaborates at Empacadora San Marcos who carries out any business in different terms to those set up by the Company will be in violation of the present Code of Ethics, in which case the Company will proceed by delimitating responsibilities within the legal frame.
4.- At Empacadora San Marcos we take extreme care down to the most insignificant part of the process to guarantee our clients always to have select, accessible, affordable, and excellent quality products.

e) Relations with Suppliers
1.- At Empacadora San Marcos buying raw materials, supplies, or training for servicing the company, is accomplished through a transparent process, thus ensuring equal participation to suppliers, as well as an impartial choice resulting from the evaluation of their performance, based on the criteria of quality, ability and service.
2.- At Empacadora San Marcos we are committed to perform an honest choice, evaluation and re-evaluation of our suppliers. We grant the highest value to fair competition during this evaluation and choice process to find the best ones. We are also committed to build lasting business relations s, which are fair, without discrimination or impositions.
3.- At Empacadora San Marcos we try to obtain only the benefits that correspond to what is being negotiated at the moment from our suppliers, without any intention of getting any personal advantages.
4.- At Empacadora San Marcos we are committed to protecting our suppliers rights –including the rights of those who are not our suppliers- on what pertains to confidentiality of information supplied. No collaborator of the company is allowed to comment to a supplier, third parties or people of no interest, the problems or weaknesses detected in another supplier.
5.- If any collaborator at Empacadora San Marcos requests or receives any type of incentive from suppliers so that influences his choice, good marks, improvement in the company appreciation, or to open, increase and sustain a business relation, that will be considered as an illicit conduct. Those suppliers who consider that a collaborator at Empacadora San Marcos has participated in an illicit or inadequate conduct should communicate such conduct to the Company in a confidential manner by means of a denouncing telephone call to (01 800 710 5555), since it is the means through which Empacadora San Marcos protects and safeguards the anonymity of the person who denounces.
6.- People collaborating at Empacadora San Marcos as well as their relatives must reject money, gifts or services offered by those who are suppliers received at the company premises or in their personal addresses. Occasionally and for mere politeness in the relations (particularly during December festivities), gifts can be accepted which are worth no more than $500.00, which should be delivered to the Human Resources Department to be included in the raffle that takes place for the New Year’s employees toast. If the gift has a higher cost, it should be rejected.
7.- People collaborating at Empacadora San Marcos who have direct contact with suppliers are responsible of handing a photocopy of this Code of Ethics to the suppliers, as well as of making them know that, while working for Empacadora San Marcos, this code obliges all collaborators to adhere to it for any operation or service made by the company.

f) Relation with Competitors
1.- Empacadora San Marcos does not take part, and never will, in any agreement that pretends to limit the strength of the markets in which its operations take place and does not utilize improper means to improve its competitive position in said markets. At Empacadora San Marcos we are committed to share the market in an honest and loyal manner, based on our products and brand.
2.- Collaborators at Empacadora San Marcos who are in touch with people who represent our competitors, must keep a professional attitude, respecting the principles and values that prevail in the company and will take care of their personal image and that of Empacadora San Marcos.
3.- In every contact with competitors, whether with individuals, in forums or with company or professional associations, collaborators of Empacadora San Marcos must avoid mentioning topics that could generate risks or possible contingencies to the company.
4.- People collaborating at Empacadora San Marcos must avoid as much as possible to comment or make statements upon our competitors and, when necessary, they must be fair, objective, complete, precise, without adjectives or tricky information, avoiding depreciatory or offensive comments.
5.- In no case and under no circumstance, people collaborating with Empacadora San Marcos will try to obtain commercial secrets or any other confidential information from a competitor by improper means, and should reject or denounce any type or industrial espionage, as well as hiring a competitor’s employees or former collaborators so s to extract confidential information.

g) Publicity and Marketing
1.- Communication through publicity and marketing at Empacadora San Marcos must be:
a) Legal, based on honest and good faith principles; decent, honest, not tricky that could induce an erroneous interpretation of the characteristics of products made by Empacadora San Marcos.
b) Designed under a sense of moral responsibility.
c) Respectful of the moral values of our society, non-offensive to any gender, race, religion, social class or political preference.
d) Empacadora San Marcos refuses direct or indirect sponsorship of any promotion or publicity containing elements of vulgarity, violence or any other element that harms or affects personal, family or social values.
e) Collaborators at Empacadora San Marcos who are in touch with publicity consultants or other similar agencies should provide a copy of this Code of Ethics, and will communicate that they are fully aware of the need to comply with it in the design of any work made as company representatives.

h) Relation with authorities
1.- Collaborators at Empacadora San Marcos must perform their activities in compliance with the regulations in force that can be applied to the processes the company follows, as well as comply with the rulings in the countries where our products are sold and inasmuch as possible, respect local pratices and customs of the countries whenever there is conflict.
2.- Collaborators at Empacadora San Marcos are committed to comply in an honest and punctual manner with their taxpaying duties.
3.- Empacadora San Marcos collaborates and participates under any circumstance with the competent authorities so they can fully exert their functions.
4.- Collaborators at Empacadora San Marcos which relate with authorities must deal kindly and politely with them to ease the discussion of matters in contempt and the reaching of agreements.
5.- At Empacadora San Marcos each and every observation and requirement of law is attended thus complying with every law and regulation.
6.- Every deal, proceeding, relation, program that any member of the company has while representing the company with government departments or representatives, must be carried out according to applicable rules in course.
7.- At Empacadora San Marcos no undue payment is made to any type of authority and there is no participation in any corrupting activity.

i) Social Responsibility
1.- Empacadora San Marcos recognizes Environmental protection as part of its social responsibility, at the same time that it looks continuously for the actions to take for keeping its certification as Clean Industry, thus voluntarily securing satisfactory compliance with the legal requirements that contribute to the care and protection of our environment.
2.- At Empacadora San Marcos we develop our productive activities by increasing our efforts to prevent and minimize generating pollutants.
3.- At Empacadora San Marcos we implement procedures and/or programs for taking care of the air, water, and soil.
4.- At Empacadora San Marcos we have an operating Residual Water Treatment System that covers the requirements of water discharge according to rules in force, which requires a strong money investment and technological development. Its results have turned our plant a model to follow in the State of Puebla.
5.- Collaborators at Empacadora San Marcos perform each and everyone of the activities necessary to make sure that:
a) Significant changes in the productive processes are evaluated beforehand and as a preventive measure to avoid any adverse change in the environment.
b) To effectively respond to possible contingencies and to minimize the impact of unpredictable accidents, as well as environmental ones, the implemented procedures and effective working instructions are correctly implemented with due anticipation.
c) Air emissions, main sewage discharge and dangerous and non-dangerous residual handling have no unacceptable environmental impact.
d) Energy sources are efficiently and power consumption is monitored.
6.- Empacadora San Marcos was granted the C-TPAT Certificate, a voluntary program with the United States of North America to establish a relation in which both countries cooperate to strengthen security against terrorism that affect the chain of supply and security along frontiers.
7.- Empacadora San Marcos willingly receives collaborators children in its premises and contributes to enrich their integral education. The children are offered attractive and safe activities for them, in addition to becoming familiar with a general view of the production processes of Empacadora San Marcos. With this we promote and strengthen family union as well as the respect for universal children’s rights.
8.- At Empacadora San Marcos we are committed with the social and economic growth of the community where our company is located by supporting the creation and sustainment of productive employment sources.

j) The Principle of Austerity
1.- Collaborators at Empacadora San Marcos shall make efficient use of resources available within reach, trying to keep them in perfect functioning condition, making effort to maximize their yield and lengthening their useful life.
2.- Collaborators at Empacadora San Marcos will try to maximize resources in addition to simultaneously promoting savings in daily operations, and will also avoid unnecessary expenses.
3.- At Empacadora San Marcos permanent water-saving campaigns are already established, as well as for electricity, consumables and telephoning.
4.- At Empacadora San Marcos the buildings, equipment, furniture, tools, materials, reactive substances, are adequately utilized thus preventing their waste or malfunctioning. No collaborator is permitted the usage of these resources, owned by the company, for any activity not related to his position.

k) Protecting Information
1.- Collaborators at Empacadora San Marcos are committed to take the necessary steps to protect confidential information they may use, encounter or have access to as to avoid its becoming known by unauthorized for it. What is considered as confidential information and should be kept as private, is: personal and confidential information on each and every collaborator; plans, designs or drafts, blueprints; formulae, programs, technologies; specifications, drawings, procedures; financial registration, clients and suppliers portfolios. It is expected that collaborators inform immediately on situations that may lead to loss or malicious use of said information.
2.- At Empacadora San Marcos it is forbidden to alter any type of registration, accounting or financial information or objective evidence of activities, as well as altering operations, whether for pretending goals or objectives have been attained , or to obtain any personal benefit.
3.- At Empacadora San Marcos confidential information is handled, updated and protected by authorized personnel, who must safeguard its integrity to avoid filtering or disclosure to unauthorized third parties.
4.- Collaborators at Empacadora San Marcos must abstain from acting in a way that may influence, manipulate or deceive any external or internal auditor¸ any government representative or governmental authority met while performing their duties.

l) Systems
1.- Computing and communication systems must be used only for working purposes and it is forbidden to utilize them for personal reasons.
2.- On all information sent through computers or communications, Empacadora San Marcos has ownership rights.
3.- It is the responsibility of the user to safeguard the codes and access configurations that are given to him/her.
4.- Email accounts are personal and non-transferable. It is forbidden to use any non-assigned one.
5.- Electronic mail users must utilize it exclusively with working purposes. It is forbidden to display, download, transmit and obtain by means of Internet: obscene, pornographic, racist, offensive messages, chain messages, music, videos, multimedia messages, software or any other the company considers as inappropriate or that interferes with the user labor activities.
6.- It is forbidden to use and/or misuse internet Access to perform any activity not related to your job.
7.- It is forbidden to print any personal paper or anything alien to the interests of Empacadora San Marcos.

m) Occupational Health and Security
1.- At Empacadora San Marcos we are committed to the health and security or our collaborators, for which every necessary action to secure the following objectives is taken:
a) Activities pertaining to our different processes are performed in safe, healthy places, with adequate safety gear in good condition.
b) Arrange and keep an adequate work environment based on effectively updated studies for protecting people who work on our processes: lighting, noise, fire risks degree determination; potential risk to equipment; personal protection equipment, handling dangerous chemical substances, electricity, welding.
c) Develop a safety consciousness among our personnel by means of the company programmed health and safety talks, coordinated with the medical service and Health institutions.

n) Sanctions
1.- Any violation to any issue included in the present Code of Ethics will be submitted to sanctions determined according to fault incurred in.
2.- In case the offense or breach of code is very serious, sanction may go from being fired to criminal offense denounced to corresponding authorities.

General Management