Code of Ethics 2023
INDEX 1 1 Introduction 1 Vision 2 Mission 3 Values 4 1. Art. Anti-corruption practices 4 2. Art. Asset, nance and anti-fraud protection 4 3. Art. Fair competition 5 4. Art. Regular and free employment 5 5. Art. Contractual obligations and agreements 5 6. Art. Salaries 6 7. Art. Working hours 6 8. Art. Social Bene ts 7 9. Art. Con ict of Interest 7 10. Art. Fair hiring 8 11. Art. Work environment and labour relations 8 12. Art. Horizontal communication, consultation mechanisms, claims and/or complaints 9 13. Art. Safety and health at work 9 14. Art. Training and performance evaluation 9 15. Art. Training and evaluation in Human Rights 10 16. Art. Zero discrimination and equal opportunities 10 17. Art. Free association 10 18. Art. Child and forced labour 10 19. Art. Prohibition of harassment or sexual harassment 10 20. Art. Prohibition of severe and inhumane treatment 11 21. Art. Evaluation of suppliers 11 22. Art. Solid and sustainable relationships with the community 12 23. Art. Local development and indirect economic impact 12 24. Art. Products and services on offer 13 25. Art. Marketing and labelling 13 26. Art. Con dentially, information management and public communications 14 27. Art. Regulatory compliance and political neutrality 14 28. Art. Communication of illegal conduct or violation of this Code of Ethics 29. Art. Breach of the Code of Ethics
Introduction We believe in the potential of Peru and of our people to Vision contribute to the healthy lifestyle of more people. As a company, we are responsible for conducting ourselves in a transparent and honest manner, thus consolidating solid and lasting relationships based on respect and trust. To this end, we recognize that ethical behaviour will guarantee that relationships with our stakeholders1 are based on respect and thus can contribute to a better quality of life for more people, not only thanks to our products, but also to our team at Peruvian Nature. In this regard, this Code of Ethics represents a performance guide for the company, encompassing a vision, mission, values, and principles of ethical behaviour as part of its commitments. The methodology used is based on the 200 series (economic issues), 300 (environmental issues) and 400 (social issues) of the GRI Standards that we also use for the formulation of our Sustainability Reports. Hence, we strive to ensure that our various policies/procedures, such as this Code of Ethics, are in alignment with our performance, which is re ected and made transparent in our Sustainability Report. To become a relevant agent of change at a global level, inspiring people to nourish themselves and live in a more conscious way in harmony with the world and with themselves, dedicating special interest to the well-being of our employees and the Peruvian communities with which we work. Mission To increase awareness of and offer the world the richness of Peruvian Superfoods, based on work undertaken with passion, respect and care towards our employees, while at the same time ensuring their individual development. 1 An “interest group” is an entity or individual that could be signi cantly affected by the activities, products, and services of the reporting organization or whose actions could affect the organization’s ability to successfully implement its strategies and achieve its goals. Note 1: Interest groups include entities or individuals whose rights,in accordance with international law or conventions,provide them with legitimate rights vis-à-vis the organiza- tion. Note 2: Stakeholders may include those who have invested in the organization (such as employees and shareholders), as well as those who have other relationships with the organization (such as workers who are not employees, suppliers, vulnerable groups, local communities, NGOs, or other civil society organizations, among others). (GRI, 2016) 1
Values Respect Towards ourselves, nature, communities and our peers. 2 Commitment Understand the consequences of our actions so that we may commit to a job well done, that which brings us satisfaction and allows us to sleep soundly at night. Awareness We work as a team, always conscious of the changes in our environment. We are demanding of ourselves to build the trust of others. Warmth We believe in heartfelt treatment as a basis for good relationships within Peruvian Nature and with all our stakeholders.
Code of Ethics 1. Art. Anti-corruption practices As part of the process of preparing our Sustainability Reports, 1.1 At Peruvian Nature, as a business made up of individual it was possible to identify Peruvian Nature’s groups of interest, employees2, we are committed to complying with the which include the following: staff, suppliers, clients, shareholders, requirements of national regulations and international government, community, and international organizations. In this instruments3 regarding the strict prohibition of corrupt manner, the performance guidelines revolve around these actors practices towards its stakeholders (GRI, 2016) understood and the various speci c indicators speci ed in the GRI Sustainability as: bribery, facilitation payments, fraud, extortion, collusion, Report methodology: Standards. money laundering, embezzlement, in uence peddling, Peruvian Nature’s staff must adhere to the internal rules and abuse of power, illicit enrichment, cover-up and obstruction regulations speci c to the company and which may even go of justice, offering or accepting gifts, loans, fees, rewards beyond the requirements of the law. Similarly, the performance and or other advantages/incentives (loans, special privileges, participation of Peruvian Nature staff will be based on national and employment contracts, consultancies, personal favours, international laws and conventions. services provided by third parties4 and even authorities and political personalities, among others) to induce them to do something dishonest, illegal or that represents a breach of trust. 1.2 In addition, any offer of food, entertainment, or entertainment by third parties must be accepted by the organization’s employees only to address commercial or business issues. 1.3 We also have a mechanism for the identi cation, evaluation, and amendment of corruption, if one is indeed con rmed. 2 Staff is the term that signifies every “employee” within an organization according to the language of the GRI Standards. 3 Organisation for Economic Co-operation and Development (OECD): Good Practice Guide on Internal Controls, Ethics and Compliance, 2010; Organisation for Economic Co-operation and Development (OECD): OECD Guidelines for Multinational Enterprises, 2011; United Nations (UN) Convention “Convention against Corruption”, 2003. 4 As a “third party”, we refer to the contracting companies that provide services for the construction or remodeling of buildings, maintenance of equipment and facilities, transport of loading and unloading, suppliers of primary inputs or various services. 3
2. Art. Asset, finance and anti-fraud protection 4. Art. Regular and free employment 2.1 All employees are responsible for preserving, using responsibly, and keeping in custody the tangible and intangible assets of our organization, with the aim of 4.1 Every employees who forms part of our organization will maximizing their capacity, prolonging their life, and play his/her role based on labour relations recognized avoiding any inappropriate use that could represent by national regulations and international instruments. economic damage or deterioration of our reputation. 2.2 Any fraudulent action or dishonest conduct that involves the goods, assets, nancial and accounting data of our organization or of a third party, will give rise to the application of disciplinary sanctions and/or criminal charges. 3. Art. Fair competition 4.2 No employee been recruited through corrupt practices (See: Art. Anti-Corruption Practices) or will be forced 3.1 We prohibit any type of collusion with other companies to conduct such practices while performing his/her or organizations whose objective is to reduce, functions within our organizations. eliminate or create obstacles to current competition Every employee is also free to withdraw from work or to enter the respective market. This collusion refers situations that they consider risky or dangerous (e.g. to unfair competition and is represented by practices, contracting an injury, illness, or disease). Our “Policy such as: price xing, coordination of offers, creation Against Harassment” protects employees from of market or production restrictions, imposition of retaliation for said decision. geographical quotas or the allocation of clients, suppliers, geographical areas, or product lines. 4.3 3.2 In addition, all the company’s employees and those who are dedicated to marketing activities and are in direct contact with the competition, must update their knowledge regarding the applicable national regulations and international instruments5 vis-à-vis fair competition. 5 Organisation for Economic Co-operation and Development (OECD): OECD Guidelines for Multinational Enterprises, 2011. 4
5. Art. Contractual obligations and agreements 6. Art. Salaries 5.1 In accordance with national regulations and our “Hiring 6.1 In compliance with the national regulation7, which prohibits 5.2 Policy, we ful l all contractual commitments to our staff, for all remunerative discrimination, and considering the context 5.3 example: salaries, working hours and social bene ts6. of the current labour market, we have a new salary structure, 5.4 All employees are provided with written and easy-to- which is de ned transparently and fairly, with qualitative understand information about their working conditions and quantitative evaluation criteria for the creation and 6 The Law on Productivity and Labor Competitiveness (Legislative Decree No. 728). before accepting employment and during the respective characterization of jobs and their respective salaries (all work period. above the minimum wage), and salary increases. We have arbitration mechanisms (“Procedure for 7. Art. Working hours complaints and claims” and “Internal Labour Regulations”) in place with the aim of resolving disputes between the 7.1 In compliance with the national regulation, we contractually various employees or vis-à-vis the contracts or agreements 7.2 de ne the number of working hours, which do not exceed with third parties. 48 hours per week. Our relationships with our suppliers, represented by agro- 7.3 Overtime work is voluntary and in no case may it be industrial companies and producer organizations, are imposed, and it shall be conducted in a responsible manner, governed based on consultations and clear feedback that considering the following aspects: scope, frequency can result in commercial agreements and commitments and hours worked by each individual employee and the without creating dependency. In this way, we seek to ful l workforce as a whole. All hours of overtime work will be - in detail - all our commitments stipulated in the purchase paid in accordance with the provisions of existing national and sale agreements; payment agreements with our regulation. suppliers and third parties to build trustworthy and fair The total number of hours worked in any seven-day period long-term relationships; as well as de ne clear rules will not exceed 60 hours, except in the following situations: and procedures (“Sustainable Procurement Policy” and • National legislation allows it; “Sustainable Procurement Management Procedure”) vis-à- • When appropriate measures are taken to safeguard the vis business relations. health and safety of employees; and • When it is shown that there are exceptional circumstances, such as, for example, unexpected production peaks, personnel shortages, or technical emergencies. • Employees will have at least one day off for each seven- day period. 7 Law Nº 30709 from MINTRA. 5
8. Art. Social Benefits 9. Art. Conflict of Interest 9.1 A real or potential conflict of interest occurs when there is a “situation in which an individual faces a dichotomy between 8.1 We offer two types of social bene ts: mandatory the requirements of his/her role and his/her own private (national regulation) and voluntary. interests” (GRI, 2016). In other words, it exists if an employee is in a position to influence a decision that may result in personal and/or family gains, compromising the interests of the organization. In this regard, at Peruvian Nature, we are committed to prohibiting all types of conflicts of interest associated with our business management and in compliance with international instruments on the matter. The following cases represent a conflict of interest for our organization: 8.2 As for the former, they are made up of: vacations, 9.1.1 When a staff member represents our company in 8.3 compensation for length of service, bonuses in the commercial relations, uses the position or makes use of months of July and December, life insurance, health care, 9.1.2 funds, facilities, information, personnel, or other resources disability and invalidity coverage, retirement bene ts, 9.1.3 of the company for personal purposes or makes any shareholding or pro t distribution, parental leave, and decision not based on professional criteria, without the compensation for overtime) for staff hired for a “speci c prior authorization ofThe Management. period of time” and “stable” workers. When any external work activity of a staff member interferes with their work-related responsibilities or 9.1.4 compromises the interests and/or reputation of the company. As for volunteers, we offer medical assistance (under 9.2 When employees perform an action that is not an agreement with a local polyclinic), nursing services communicated, whether written or oral, to pursue a at the plant, fees above minimum wage, bonuses for personal interest. In addition, all information from our meeting objectives and coupons) to improve employee stakeholders is confidential and cannot be used for satisfaction. personal gain. When staff members receive gifts, benefits, favours, concessions, values, or goods, in any form, from our stakeholders, such as those mentioned in the Article entitled “Anti-corruption Practices” for personal benefit and/or that compromise the interests and reputation of our organization. Wehave mechanisminplacetoidentify,evaluateandamend, if con rmed, a case of con ict of interest. 6
10. Art. Fair hiring 11. Art. Work environment and labour relations 11.1 We implement activities to improve the work environment in our organization with the aim of improving the motivation 10.1 At Peruvian Nature, we make sure that every staff member of our employees and thus exert an impact on performance has been hired in compliance with the quali cations, skills as a comprehensive business unit. Among these activities, and experience required for the job, and veri ed as part of we have: informal staff get-togethers on commemorative the respective selection lter. dates (Christmas, Valentine’s Day, Labour Day, Mother’s Day, Father’s Day, etc.), virtual consultations with a psychologist, leadership training, among others. 11.2 We conduct annual “Work Climate” surveys to measure the relationship and interaction of employees within the different 10.2 The direct relatives and partners of employees will be areas of the company, as well as their satisfaction with their 10.3 recruited as staff or third parties, if they meet the criteria daily responsibilities and the company in general. In addition, described in the previous point. it helps us de ne improvements that can further integrate our employees within our organization, improving their job 11.3 satisfaction and thus positively impacting the performance of our comprehensive management. The conditions for de ning remuneration, promotions and job transfers will be based on our “Hiring Policy”, “Salary We conduct evaluations by “Competencies” and Policy” and “Performance Evaluation”. “Compliance with Objectives” to measure the work performance of employees and thus, in alignment with the 11.4 previous point, seek to create strategies to improve their motivation and personal satisfaction. The “competencies” evaluation is addressed to 100% of the staff, while the “compliance with objectives” evaluation is only addressed to the heads of units, since they are the ones who de ne the annual objectives for each area, respectively. We provide all the necessary tools and platforms so that our staff can ful l their duties and responsibilities fully and effectively. 7
12. Art. Horizontal Communication, consultation 13. Art. Safety and health at work mechanisms, claims and/or complaints 13.1 At Peruvian Nature we are committed to providing a safe and healthy work environment for all our employees. 12.1 At Peruvian Nature, we apply timely consultation 13.2 As part of our Occupational Health and Safety Management 12.2 mechanisms with our stakeholders to evaluate the System, we establish mechanisms to identify hazards8, assess management of the company and make informed and risks9 and investigate incidents10 related to occupational health consensual decisions. We seek to consider the opinions and safety. The mechanisms will help prevent and mitigate and expectations of these groups. accidents, illnesses, injuries, or any type of event associated with our work activity that may impact the health and safety As well, we promote a horizontal dialogue scheme of our employees. In addition, constant relevant training is between our management and our staff with the aim of provided as part of these mechanisms and available to all our generating uid, transparent communication, reducing employees. bias and fostering rapport with our employees, capturing their expectations and perceptions vis-à-vis our management and/or their responsibilities. 13.3 We express our concern for any accident, unsafe practice or situation or potential risk in our work environment; therefore, 12.3 Likewise, we have our “Complaints Resolution” we encourage and request our employees to immediately 12.4 procedure in place, which is a transparent and inform their manager and/or area supervisor or the Human con dential system to present claims or denounce Resources area of any such event. violations of Human Rights, which are re ected The health and safety conditions implemented in our work throughout this Code. environment will be aligned with compliance with all national regulations and international instruments on the subject. 13.4 We provide our employees and other stakeholders with reasonable notice concerning signi cant operational changes. 8 We de ne a “hazard” in Occupational Health and Safety as the intrinsic characteristic of a situation with the capacity to cause damage to employees, equipment, processes and environment. 9 We de ne a “risk” in health and safety at work is any probability that a “danger” materializes under certain conditions and is a generator of damage to employees, company property and the environment. 10 We de ne “incident” as a situation that may or may not generate damage to employees or material at the level of the company’s operations. 8
14. Training and performance evaluation 14.1 At Peruvian Nature, we promote the training of our staff 15.4 As part of our comprehensive management, we want to be to upgrade their skills with the aim of improving their aligned with ethical criteria and that third parties are likewise personal/professional satisfaction. This, in turn, leads to better aligned. Therefore, we periodically request the competent performance all-round in the company. authorities (e.g. PROMPERU & Ministry of Environment), the evaluation in terms of Principles & Criteria of Biotrade 14.2 In addition to the training provided, we evaluate all our staff to guarantee that our management and main suppliers of in their professional performance, which contributes to their raw material (in volume and strategic importance) comply personal and individual development. We also seek to with ethical business criteria, as well as obtain feedback for contribute to the management of skills and the development continuous improvement in this eld. of human capital within our organization. 16. Art. Zero discrimination and equal 15. Art. Training and evaluation in Human Rights opportunities 16.1 In accordance with national regulations and international instruments, at Peruvian Nature, we promote diversity in all our 15.1 All staff are trained on the contents of this Code of Ethics, as spaces, prohibiting any and all types of discrimination and bias 15.2 well as on policies and various mechanisms that guarantee based on race, colour, sex, sexual orientation, religion, political 15.3 compliance with this Code, thus achieving that the Human opinion, national origin, social origin, age, disability, health Rights of all people within our organization and within all condition,immigrationstatus,religion,age,geneticpredisposition, stages of the various value chains11 that we serve, are valued lifestyles or belonging to a minority group. and respected. Likewise, we involve our security personnel in said training 16.2 If necessary, we have mechanisms to identify, evaluate and to guarantee proper conduct with third parties, especially remedy cases of discrimination12. regarding the use of force. We ensure that our suppliers are aligned with our Human 16.3 We strictly eliminate all types of discrimination or bias in Rights approach, and that they apply practices or comply 16.4 the selection of employees, promotion opportunities and with the relevant commitments in this area. In this regard, we remuneration policies whereby all employees have the right to have developed a “Sustainable Acquisitions Policy”, which receive training free of discrimination. encompasses ethical criteria that helps us to evaluate our Likewise, we provide social benefits, occupational health and current and potential suppliers in terms of Human Rights in safety conditions, and remuneration in accordance with national their actions. regulations and international instruments, for all our employees and members of our governing bodies. 11 The value chain of an organization encompasses the activities that turn an input into a product by adding value to it. It includes entities with which the organization has a direct or indirect business relationship and which (a) 12 “Case” refers to a legal action or complaint registered with the company through a formal process or a case of non-compliance identi ed by the organization through established procedures (GRI 406). provide products or services that add value to the organization’s own products or services or (b) receive products or services from the organization. (GRI, 2016) 9
17. Art. Free association 20. Art. Prohibition of severe and inhumane treatment 17.1 Aligning ourselves with national regulations and international 20.1 Any act of resorting to force, abuse, threat (explicit or covert), instruments, we respect free association and collective hostile or offensive behaviour, functional attributions without bargaining, without retaliation or hostile and discriminatory reason for judgment, whether verbal or physical, that may action, assuming a tolerant attitude towards the activities of involve physical, moral and psychological damage, are strictly unions, as well as their organizational activities inside and/or prohibited for all staff (among these, towards third parties and outside our work environment. even towards their relatives) of Peruvian Nature both inside and outside our facilities.These acts are unacceptable and can trigger the immediate separation of the staff from the company. 17.2 In cases in which the law restricts the right to free association and collective bargaining, the development of parallel means to associate and negotiate freely and independently will be 21. Art. Evaluation of suppliers facilitated and not hindered. 18. Art. Child and forced labour 18.1 At Peruvian Nature, we prohibit all forms of “child labour”13 and 21.1 At Peruvian Nature, we only collaborate with suppliers that “forcedlabour”14 withinourworkspaceandthatofoursuppliers, have passed the corresponding selection filters, based on aligning ourselves with national regulations and international criteria, such as: quality of the product or service, price, capacity, instruments on “child labour” y “forced labour”. delivery terms, social and environmental impact. To this end, as part of the “Sustainable Procurement Policy”, a procedure has 18.2 We do not employ young people under 18 years of age and been developed that includes the aforementioned criteria. In to guarantee it,we request the identi cation document of every this regard, those suppliers that respect ethical principles will person within the selection and hiring process. be contracted, guaranteeing the prohibition of any violation of Human Rights (e.g. child exploitation, forced labour, etc.) and in compliance with national regulations on this matter. 19. Art. Prohibition of harassment or sexual harassment 19.1 In addition to sexual harassment,requests for sexual favours,and 21.2 In addition to these evaluations, we will send each current and any verbal or physical conduct of a sexual nature both inside and potential supplier a Code of Ethics to become aware of and outside the facilities of Peruvian Nature, are unacceptable and implement this Code, which we will guarantee, with periodic represent an immediate disassociation from the company of any evaluations. staff who engages in this sort of activity to the detriment of other staff members and/or third parties of our organization. 13 By“childlabour”,wemeanabuse.Thisshouldnotbeconfusedwith“workingchildren”or“youngworkingpersons”,astheymaynotbeabusedinaccordancewiththeprovisionsofILOConventionNo.138andtheminimumageforworkdiffersfromcountrytocountry. Convention No. 138 stipulates that“national legislation and other provisions may permit the employment or work of persons between the ages of 13 and 15 in light labour,provided that these (a) are not likely to impair their health or development; and (b) are not of such a nature as to prejudice their attendance at school, their participation in vocational guidance or vocational training programmes approved by the competent authority or the attainment of the education they receive.”Although child labour comes in many different forms, one of the priorities is to eliminate the worst forms of child labour, as defined in Article 3 of ILO Convention No. 182. This includes all forms of slavery or practices analogous to slavery (such as selling, trafficking, forced or compulsory labour, debt bondage or recruitment for armed conflict); the use,recruitment or offering of children for prostitution,the production of pornography or illicit activities and any work that may harm the health,safety or morals of children. ILO Convention No. 182 aims to set a number of priorities for states. However,it is hoped that organizations will not use this Convention to justify any type of child labor. (GRI 408,2016a seguridad o la moralidad de los niños. El Convenio n.º 182 de la OIT pretende establecer una serie de prioridades para los estados. Sin embargo,se espera que las organizaciones no usen este convenio para justificar cualquier tipo de trabajo infantil.(GRI408,2016) 14 Themostextremeexamplesareslaveryandservitude.Debtscanalsobeusedtokeepemployeesinasituationofforcedlabour.Someoftheindicatorsofforcedlabouraretheretentionofidentitydocuments,theobligationtomakedepositsandtheobligation,under threat of dismissal,to work additional hoursthathave notbeen previouslyagreed.(GRI409,2016) 10
22. Art. Solid and sustainable relationships with the community 22.1 At Peruvian Nature, we care about building long-lasting 23.4 As part of the processes for the implementation relationships with our neighbours from headquarters, of these programs and/or projects, we seek the based on mutual respect and, if applicable, collective involvement and participation of local communities association and long-term commitments to pursue to understand their vulnerability and assess how they common goals and bene t the local community. could be affected by project activities. Likewise, we seek to form a working relationship with our interest 23. Art. Local development and indirect economic groups within the scope of intervention of the project impact to form feedback mechanisms and make timely decisions that can help avoid, minimize, mitigate, or 23.1 As part of the intrinsic nature of our management compensate negative impacts on local communities modus operandi, we contribute to local development, or vulnerable groups or disadvantaged within the together with other companies, generating employment scope of the project. opportunities for people from districts surrounding the We are interested in knowing how our management headquarters of our operations. also generates indirect economic impacts15 in other links of the value chains that we serve, hence, we 23.5 seek to identify such impacts and their evaluation to know how we can optimize them, generate others, or 23.2 Likewise, we are aware that by collaborating with various mitigate them, if they are negative. suppliers in the country, represented by agro-industrial companies and producer organizations that include various economic agents at the beginning of the links of the various value chains of our business, we are - in turn - contributing to economic development of the regions from where these suppliers come. 23.3 We are observant of opportunities for programs and/or 23.6 In terms of our relationships with Indigenous development projects that can improve our commercial peoples, at Peruvian Nature, we are committed to the and management performance but that, in turn, generate application of policies and/or mechanisms, as part bene ts for the economic agents of the value chains of our compliance with national regulations and/or that we serve and thus have a social impact on the local international instruments with the aim of establishing communities associated with these chains. In this way, we relations with them that guarantee respect for their apply mechanisms to measure the expected impact on rights within the framework of the company’s existing these communities and thus become aware of the actions or planned activities. that we must implement to optimize said impact. 15 Examples of indirect impacts: adoption of information technologies, the number of jobs supported in the supply or distribution chain (e.g. the impact of employment on suppliers as a result of increased sourcing), the improvement of skills and knowledge in a professional community or a geographical location, among others. (GRI 203, 2016) 11
24. Art. Products and services on offer 25. Art. Marketing and labelling 24.1 At Peruvian Nature, we offer safe products and service that meet 25.1 Aligning ourselves with national regulations, international 24.2 the requirements of our clients, guaranteed by quality standards instruments, and voluntary standards, at Peruvian Nature, we 24.3 and at a price aligned with the market. are committed to providing truthful, clear, useful, and precise 24.4 information about our products and/or services, which will We conduct evaluations of our products and services to 25.2 comply with the technical specifications committed and guarantee that they do not impact the health and safety of socialized. If there is any non-conforming product and/or service, our clients in accordance with the established national and procedures are in place to process said claims. international regulations. At Peruvian Nature, we have mechanisms in place to explain the characteristics of our products and/or services. Thus, our clients In the event that the health and safety parameters of our expected 25.3 and end users obtain accessible and adequate information on products and services have been violated, in accordance such characteristics and can make informed purchase decisions with national and international regulations, the mechanisms/ in constant alignment with national regulations and international procedures will be applied to register, analyse, and amend said instruments. case. In such cases where there is a conflict between the information 25.4 communicated about our products and/or services through our various communication tools (e.g. website,social networks,email We are also committed to providing mechanisms to measure the marketing, participation in fairs, brochures and labels) regarding level of satisfaction of our customers to meet their expectations the product and/or service that we offer and/or have offered,the and perceptions in the development of the products or services mechanisms/procedures to register, analyse and amend said we offer. case will be applied. At Peruvian Nature, we are aware that marketing is a means of 25.5 communication between the company and our clients, which is why we seek to manage it in a fair and responsible manner, avoiding misleading, false or biased statements about our products and/or services,and making all information transparent. In case of events where the national regulation, international instruments,orvoluntarystandardsonmarketingcommunications of our products and/or services have been violated, the mechanisms/procedures to record, analyse and amend said case will be applied. 12
26. Art. Confidentiality, information management 27. Art. Regulatory compliance and political and public communications neutrality 26.1 The success of Peruvian Nature depends on the proper use 27.1 At Peruvian Nature, we are committed to respecting 26.1.1 of con dential information and its adequate disclosure to 27.2 national regulations and international instruments17 26.1.2 third parties; therefore, improper, and unauthorized use could 27.3 associated with the proper functioning and 26.1.3 generate negative results in the performance and image of 27.4 performance of our organization in legal, economic, our organization. Therefore, as a means of aligning ourselves social, and environmental matters. 26.1.4 with national regulations and international instruments16 , the In addition, we promote any act of complaint or 26.1.5 following scenarios are of the utmost importance: expression of disagreement with illegal acts before the competent authorities, as well as respect for the All information generated by our organization is private, rule of law and public institutions. except for that which has been considered public In case of violating the national regulation, international information. In addition, the protection of the restricted instruments or voluntary standards, the mechanisms/ personal records of the staff will remain crucial unless the procedures will be applied to register, analyse, and staff member authorizes it to be shared. amend said case. We prohibit any transfer/dissemination of technologies, We refrain from offering gifts and rewards, bribing, or brands, sanitary registries, methodologies, and any extorting public of cials and employees to bene t type of information that belongs to the management the company (Art. Anti-Corruption Practices). Peruvian of Peruvian Nature (even if it has been developed or Nature also undertakes to maintain a neutral political managed by the staff member him-/herself), since it position. could put the intellectual property or the competitive advantage of our company at risk. For Peruvian Nature,the information of our interest groups that we collect, store or process (such as partners of a commercial alliance or joint venture,suppliers,clients,staff, third parties, etc.) will receive the same due care as the internal information of the company. Its accessibility will depend on the evaluation mechanisms to guarantee the security of said information. In this manner, we undertake not to reveal/disseminate or use any data of our interest groups for any purpose whatsoever unless it is agreed and communicated with them a priori. All staff undertake to ensure that their communications (market share,brand,sales volumes,etc.) do not harm the reputation of our organization,damage relations with our stakeholders or violate principles of con dentiality, unless expressly authorized by the general management,which is also responsible for ensuring its con dential nature. We are committed to respecting the copyright of computer programs, as well as complying with all laws and regulations on the use and copying of these programs. Therefore, third party copies can only be provided if it is an authorized substitute copy or if the license allows the copy to be made. In addition, the use of Internet access by employees will only be oriented to work activity, which prohibits the downloading of information in the public domain and demands caution and formality when sending a message via email or in writing. 16 Organisation for Economic Co-operation and Development (OECD): OECD Guidelines for Multinational Enterprises, 2011. 17 Organisation for Economic Co-operation and Development (OECD): OECD Guidelines for Multinational Enterprises, 2011. 13
28. Art. Communication of illegal conduct or violation of this Code of Ethics 28.1 We will make all staff aware of the procedures for reporting and,if applicable,managing all types of conduct that violates this Code. 28.2 The staff will communicate, directly and/or confidentially, to the person in charge of the area responsible for the issue, any action that is inappropriate and illegal that violates this Code. Claims/ complaints will be strictly confidential and evaluated, rigorously committing ourselves to the prohibition of retaliation against any staff who communicates such claims in compliance with our“Anti- Harassment Policy”. 29. Art. Breach of the Code of Ethics 29.1 Each Peruvian Nature staff member is responsible for complying with all the articles of this Code of Ethics and, if applicable, will seek support from the Human Resources area or from the person in charge of the respective area. Failure to comply with this Code could lead to the application of disciplinary sanctions, including dismissal or legal or criminal action,if applicable. 14
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