charlotte-chemical-international

Code of Business Ethics

Our mission at Charlotte Chemical Internacional, S.A. of C.V. is to create innovative solutions and strategic alliances for the development of our clients and represented companies. To achieve this mission, each of us must be responsible for acting ethically and protecting our reputation built since the founding of Charlotte Chemical International.

CCI's Vision since its inception establishes that we will be leaders in the creation of innovative solutions, supported by our knowledge and experience, committed to the development of our business partners, collaborators, shareholders and the community. We have the passion to grow and achieve what we set out to do.

For this reason, it is of utmost importance that there is a guide, which is presented in this code and that ensures the understanding and mastery of the behaviors expected at CCI, which allows us to possibly enforce this mission, vision, and what is considered correct.

Our code is based on values ​​of HONESTY, TRUST, CREATIVITY, COMMITMENT, PASSION AND LEADERSHIP, as well as responsibility and compliance with the laws applicable in our country, or the countries with which we have or may have a commercial relationship.

CCI recognizes that the loyalty it expects to receive must be earned, which is why it is committed to treating its commercial representatives, service providers and clients ethically and fairly, ensuring that legal requirements regarding labor matters are met, and safeguarding personal information. ; and promote the highest values ​​that allow working in a healthy and safe environment.
*All CCI commercial representatives must conduct all business with integrity and under the laws that are applicable in our country.
*Avoid situations in which there may be a conflict of interest.
*All CCI managers, commercial representatives and service providers must carry out their activities in the best interest of the company, without the desire to obtain personal benefits or advantages.

1. Compliance with local laws and regulations.
All CCI members will be committed to complying with all national and international laws to promote a sustainable and competitive value chain.
It is also important to comply with internal regulations that may be specific to the company.

2. Internal Conduct
We spend much of our time in the work environment. It would be a reason for discontent if fear of making mistakes, distrust and intimidation prevailed in such an environment.
For this reason, achieving expected results deserves an environment of dialogue, motivation and training to achieve the expected standards.
At CCI, people who are willing to learn from mistakes, recognize them and not repeat them are well regarded. And, no matter the hierarchical position, those who assume responsibility for what they say and do deserve to be highlighted.
In order for us to be trustworthy, others expect fair treatment from us. They expect us to be responsible and to evaluate the consequences of our actions on other people.
With mutual respect and good manners, the company helps to offer products that will be delivered with the agreed quality and time; and with a service beyond what was expected.
Directors, managers and coordinators play a leading role due to the example they set daily. If good manners are present, everyone will tend to act correctly; If they have trust in others, trust will become part of the organization's routine.
For this reason, at CCI we will disapprove of any conduct that does not adhere to the principles of respect and courtesy on which we will be governed.

3. Confidentiality
We will take care of our confidential information and also protect the information of third parties. The following information is considered, but not limited to, confidential or privileged.
- Accounting and Finance.
- Strategic Planning.
- Judicial or administrative disputes.
- Organizational changes.
- Personal information.
- Third party commercial information.
- New representations assigned.
- Intellectual and industrial property.
- Operational business policies and practices.
- Customer or supplier databases.
- Pricing structures and policies.
- Marketing of new product lines, market studies.
- Statistical information on product imports.
Confidential or privileged information may not be revealed or communicated to third parties except when required by negotiations, and with due authorization. Likewise, we are committed to following the guidelines that our clients and suppliers indicate to us for the care of their confidential information that we have obtained during our relationship.

4. Protection and use of CCI property.
Every CCI member is responsible for protecting the company's intellectual property, its tangible and intangible assets, as well as the exclusive information held by the company. The following actions are not permitted for commercial representatives, collaborators or service providers:
* Carry or leave laptop computers or objects containing company information in public places where there is a risk of them being stolen.
* Remove objects of your property from CCI facilities, except in cases of express authorization, this includes furniture, equipment, accessories, folders, books, documents.
* Waste Company resources, including computer systems.
* Whoever has received an internet connection has received such a connection to be used in work activity. You should not download any information that is not appropriate for work matters. Internet access should not be abused for personal purposes.
* Make sure your email and instant messaging messages are professional and appropriate to the circumstances.
* Specifically, the company will not accept texts via email or instant messaging programs that are offensive.
CCI reserves the right to control and inspect the way in which the resources granted by the company are used, including all information and email communications, instant messengers, and files maintained on the network or on the company's computers.

5. Transparency in accounting and contractual information.
All transactions must be executed under the guidelines and authorization of general management and be duly recorded.
It is prohibited to make false or fictitious records in the company's accounting.
Under no circumstances should funds or assets be held unregistered.
Contracts where CCI may be legally responsible must be authorized by the General Directorate.
For contracts where, in addition to legal responsibility, there is an occupational risk, Human Resources must give its approval.
The people responsible for the import or export of products must take care of the name of the company in all foreign trade transactions, and in the storage and distribution, they must take care of the introduction or exit of any type of product prohibited by Mexican laws. or the country or destination.
We must comply with the regulations, policies, procedures and controls related to the company's accounting. All accounts must clearly describe and accurately reflect the recorded transactions, their assets, payment obligations, income and expenses, and must be recorded and explained.

6. We act with integrity in business.
We earn the trust of our clients and keep it by treating them honestly, in a professional manner. In cases where our competitors or our suppliers acquire our products, we will serve them professionally like any other customer.
We must act with integrity in business with people inside and outside the company, including government officials, customers, suppliers and community members.
It is strictly prohibited to request, accept or offer, either directly or indirectly, gratuities, bribes or gifts of any kind. This includes the improper exchange of money, loans, special privileges, personal favors, benefits or services. Any commercial practice that causes any type of fraud, those that are not properly registered, will be avoided, and we will ensure that the funds from this commercial exchange have legitimate receipts accepted in the country.
We support healthy competition and comply with antitrust laws. We strive to always compete fairly. We do not change or add illusory features to our products, and we do not mislead our customers or engage in any other unfair practices.
The rules established in the country's Anti-Corruption Legislation must also be followed. Involving such practices may have internal sanctions as well as criminal charges that may result within the margin of the law.

7. Conflict of interest.
We will avoid any practice that endangers the interests of CCI.
To avoid conflicts of interest, the following sections are listed that are not allowed within the organization, which in case of non-compliance, will generate a serious misconduct and may be cause for termination of the contract:
- No one can represent the company in commercial relationships in which they could have any personal interest, direct or indirect, at the expense of the company.
- Work in any other company that goes against the interests of CCI or distracts from your activities at CCI. CCI members who carry out external work activities, of a personal nature, must ensure that they do not generate conflicts in relation to the interests of the company.
- If anyone considers that there are personal interests that may influence their performance at CCI, they must notify their immediate boss in writing.
- You cannot receive income or benefits from suppliers, competitors or clients for your personal benefit, that of your family or third parties.
- CCI commercial representatives who have any influence on the purchase of materials or services should not get involved in personal investments related to them.
- It is not permitted to report excessive personal or invented expenses to the company for your personal benefit. We do not use company funds for private purposes, under any circumstances.
- You cannot receive cash or deposits in personal accounts for the transaction or negotiation with a client or supplier, in which CCI is involved or related.
- We do not use the company's facilities or other resources for private purposes, unless expressly authorized by the company's general management.
- You must not use CCI's commercial relationship to distribute-sell products or services other than the products sold by the company.
- You may not improperly use the company's electronic means to download any type of unauthorized software and/or distribute music, pornography, religious chains, jokes, offer personal products or services or any other matter not related to CCI's business.
- It is prohibited to falsify and omit information that harms the interests of CCI.

8. Business favors, gifts, meals and entertainment.
CCI commercial representatives and collaborators may only receive and grant favors, gifts, meals or entertainment that are reasonable under the circumstances and do not exceed an amount of 30 USD.
Gifts, hospitality or other courtesies to current or potential distributors or customers must be justified by genuine business purposes.
CCI commercial representatives and collaborators must not, for any reason, receive money as a gift.
CCI commercial representatives and collaborators, only with authorization from Management, can offer gifts to clients and suppliers, in the following cases:
• It is consistent with usual business practices.
• It does not have excessive value nor can it be considered a payment or bribe.
• Does not violate any applicable Law or ethical standards.
• The expenses generated must be recorded exactly and specifically in the company's accounting.
• If the amount exceeds what is contemplated above, but is duly justified and complies with the previous points, an exception may be made and must be authorized by the General Directorate.
For no reason will clients or suppliers be asked for cash or deposited in personal accounts.
Any offer made to you of gifts or any other commercial favor that seems incompatible with common commercial practices must be immediately reported to your Direct Manager and Management. You must also be informed of any confidential offer of money, fees or commission.

9. Public communications
Effective public communications can increase company visibility and credibility and strengthen our reputation. However, at the same time we must ensure that our public communications do not damage that reputation, violate confidentiality, harm customer relationships or relationships with partners.

10. Safety and Hygiene / Environment.
Effectiveness in occupational health, safety and environmental standards are an essential part of obtaining efficiency.
CCI has the following principles:
- Establish mechanisms that guarantee staff safety, hygiene and allow working in a healthy environment.
- Comply with all the rules and regulations applicable to our country and according to our activity.
- Provide a prompt and effective response to environmental and safety risk issues.
- Acts that could be classified as violent are not allowed.
- Carrying weapons is not allowed.
- The consumption of alcohol or drugs is not permitted in the workplace or in the facilities of collaborators, clients or suppliers.
We are committed to operating and offering products in a sustainable and environmentally responsible manner. We follow the corresponding laws and regulations related to the environment in the country. We strive to follow best practices and minimize our environmental impact.

11. Politics/Religion
CCI will respect any political or religious inclination of its commercial representatives, collaborators, clients and suppliers, this being a right that cannot be affected.
It will maintain a secular and apolitical character.
No member of CCI may act as a representative of the company in political matters.
The company does not object to people appropriately participating in the political process that reflects their individual opinions and commitments, nor to their participation in religious or other groups as long as they are within the legal framework of the country. However, any of the aforementioned activities must be carried out during free time.
No CCI member shall exert any type of pressure, directly or indirectly, on others to make political contributions or to participate in support of a political party or candidate.

12. We will not allow discrimination of any kind.
We seek a healthy environment in all aspects, which is why we are committed to respecting the dignity of each individual and will not allow any action or attitude of discrimination or harassment of any kind.
CCI rejects any attitude that discriminates against people based on color, ethnicity, race, religion, religious beliefs, social class, age, sex, gender, sexual orientation, gender identity, gender expression, origin, ancestry, physical disability, mental disability, pregnancy, health condition, genetic information, marital status, citizenship, or any other characteristic protected by law.
CCI does not establish discriminatory differences, so the recruitment and selection processes of personnel, the selection of clients and suppliers will be only based on business requirements criteria. If at any time it is considered that the aforementioned is not complied with, you should express your concerns to the Human Resources area and ethics committee.

13. Prohibition of child labor.
At CCI we are committed to following all applicable laws in Mexico and together with this support the abolition of child labor, and thus guarantee that each girl and boy has the opportunity to fully develop their potential.
Likewise, business will not be conducted with suppliers or clients who use child labor or forms of forced labor that violate the rights of children.

14. Code Compliance.
It is the responsibility of management and any commercial representative or collaborator of CCI to ensure that the points of this code are complied with. Failure to comply with this guide to ethical conduct in business will be considered a serious offense and will be grounds for initiating disciplinary measures ranging from an action plan or regularization, termination of the contract in accordance with current laws, or even legal consequences if the case requires it.
All CCI members are required to report any fact or act that implies a breach of this code, or inappropriate action; any omission will be considered a serious offense.
All practices that go against the application of the code may be communicated to SUPERIORS, HUMAN RESOURCES, ETHICS COMMITTEE OR IN NECESSARY CASES TO MANAGERS. Which confidentially or through available means will be investigated and analyzed in a formal and appropriate manner.

15. We do not retaliate
CCI does not tolerate retaliation against those who seek advice, ask questions, or report potential violations.

Mexico City, August 2020.

Sincerely,
Charlotte Chemical Internacional, S.A. de C.V.

Code of Conduct for Suppliers

Aim:
At Charlotte Chemical International, S.A. de C.V., we are governed by high values ​​for the development of our economic and social activities such as a safe work environment, respect for people and human rights, non-discrimination and rejection of child labor, under strict adherence to the federal law of the current job in Mexico.

Range:
At Charlotte Chemical International, S.A. de C.V we want to develop long-term relationships with our suppliers under a business partner scheme where we invite them to join in complying with the guidelines under which we are governed.

Principles:
1. Work Environment
All our suppliers should treat their employees with dignity and respect and not discriminate.
2. Child labor
Charlotte will not use the services or products of Suppliers that use child labor. According to Art. 1 of the United Nations (UN) Convention on the Rights of the Child.
3. Diversity
At Charlotte we value cultural diversity and respect inclusion and our suppliers should be in line with this principle.
4. Environmental Responsibility.
Charlotte maintains a position in favor of the care and preservation of our environment, which is why it is respectful of environmental regulations and asks its Suppliers to join this effort through actions in their production processes that allow reducing the environmental impact.
5. Integrity and Legality of Negotiations.
Charlotte does not participate in unfair, deceptive or confusing practices, so the supplier must always present its products and information in a clear and objective manner.
6. Gifts and Handouts
Charlotte employees related to the acquisition of goods and services may not receive gifts greater than 20 US dollars, nor may they accept trips, tickets for events or trips.

Acceptance of the code of conduct by the supplier.
This code of conduct clearly expresses the commitment we have with Charlotte Chemical Internacional, S.A. de C.V., regarding the treatment of people, working conditions and the legality of our productive and/or commercial activities; accepting the principles contained in this code and joining the objective of applying them in our own organization. To ensure compliance with this code, Charlotte reserves the right to supervise compliance with it through third-party or own audits.

Mexico City, September 18, 2020.


Sincerely,
Charlotte Chemical Internacional, S.A. de C.V.,