1. INTRODUCTION
Simetrik INC., its affiliates, and subsidiaries (hereinafter, "The Company") have developed this Code of Ethics to foster strong and ethical relationships with all individuals and entities with whom it interacts, including partners, suppliers, independent contractors, subcontractors, customers, business partners, agents, and others.
This Code aims to ensure that all activities of The Company are carried out under the principles of transparency, integrity, respect, and honesty, promoting exemplary behavior aligned with ourfundamental ethical values.
2. SCOPE
The Code of Ethics applies to individuals or legal entities providing professional, autonomous, and independent services to The Company, as well as to all third parties engaged in a contractual relationship with The Company.
For the purposes of this Code, "Third Parties" shall include independent contractors, suppliers, business partners, subcontractors, customers, investors, and those acting as partners or intermediaries of The Company. All Third Parties are required to comply with the provisions of this Code concerning their operations conducted with, for, or on behalf of The Company. Consequently,
Third Parties commit to implementing effective systems and controls that promote compliance with applicable laws and a culture based on ethics, transparency, and honesty in their activities.
3. OBJECTIVES
The Code of Ethics establishes guidelines that Third Parties must uphold to reflect ethical behavior, allowing them to build legitimate and productive relationships with The Company, always acting with honesty and integrity in all business dealings and relationships.
4. RESPONSIBILITY
The application of the Code of Ethics is the responsibility of all Third Parties, who must acknowledge, accept, and always adhere to this document
5. FUNDAMENTAL PRINCIPLES
5.1 Legal and Regulatory Compliance
Third Parties must comply with all applicable laws, rules, regulations, and international trade, intellectual property, data protection, and information security laws. They must also adhere to anti- corruption regulations such as the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.
Transparency and Integrity
Third Parties must act honestly in all business interactions and provide accurate and truthful information in all transactions and processes involving The Company.
Third Parties shall not engage in the misappropriation of confidential information, price-fixing, bid-rigging, or collusive conduct in transactions affecting The Company or any other individual or legal entity.
The Company does not tolerate unfair competitive practices to gain business. All purchasing decisions and sales actions are made objectively based on price, quality, and other factors, and we expect our customers and suppliers to do the same.
Conflicts of Interest
All Third Parties must disclose any actual or potential conflicts of interest to mitigate risks in their business relationship with The Company.
Bribery, Corruption, and Fraud
The Company has zero tolerance for any form of corruption, bribery, extortion, or embezzlement and will not conduct business with any Third Party engaged in such activities. Third Parties must implement an anti-corruption policy or an equivalent framework that prohibits any form of bribery and/or corruption within their organization and with third parties, including facilitation payments.
The Company has established controls to ensure accurate record-keeping and prevent fraud, corruption, and bribery, as well as reporting mechanisms, such as an ethics hotline, to detect and address potential violations.
Money Laundering
Third Parties must comply with all applicable laws and regulations against money laundering and terrorism financing and must ensure they do not participate in or facilitate such illicit activities.
Gifts and Hospitality
The Company prohibits promising, giving, requesting or accepting gifts other than promotional or branded items of nominal value. Third Parties: i) Shall not offer gifts in connection with their business dealings with customers or government officials. ii) Shall not provide any hospitality to government officials or to private persons with the intent to improperly influence them or where the hospitality could be perceived to improperly influence or create an obligation.
Books and Internal Controls
Third Parties must maintain their books and accounting records so that, with sufficient detail, they accurately reflect transactions with The Company and can provide access to such records upon request. They must also have internal and accounting control systems that provide adequate tracking.
5.2. Human Rights, Labor Standards and Environmental Responsibility
Third Parties shall uphold fundamental labor and human rights, as defined in the Universal Declaration of Human Rights and the United Nations Global Compact’s ten principles.
Labor Standards:
- Respect for freedom of association and recognition of collective bargaining rights.
- Elimination of all forms of forced labor.
- Prohibition of child labor and discriminatory employment practices.
Equal Opportunities, Diversity and Inclusion
Third Parties shall provide equal employment opportunities and promote professional advancement without discrimination based on gender, race, ethnicity, national origin, age, disability, marital status, sexual orientation, or any other protected characteristic protected under applicable law.
Environmental Protection
Third Parties shall actively and responsibly contribute to environmental conservation by complying with legal requirements and minimizing the environmental impact of their activities. They should strive to reduce adverse environmental effects throughout the product/service lifecycle and comply with relevant legislation and international standards.
5.3. Company Protection, Information Security, and Confidentiality
The Company considers its brand, reputation, and public image among its most valuable assets. Public disclosure of information may only be made by authorized personnel through approved channels.
Third Parties shall not misuse The Company’s name or brand for unauthorized purposes. They must comply with applicable intellectual property laws and ensure protection against copyright, trademark, and other intellectual property infringements
Confidential Information
Confidential and/or privileged information includes any unpublished data, actions, events, or documents related to The Company or its business ecosystem that must not be publicly disclosed or shared with unauthorized individuals.
Third Parties shall protect confidential information about The Company, stakeholders, operations, customers, and suppliers, even after the contractual or corporate relationship ends. They must not use The Company's assets or information for personal gain.
Whistleblowing Channels: Simetrik Ethics Hotline
5.4. Third Parties must report any illegal, unethical behavior or any violations of this Code, anonymously
through Simetrik’s Ethics Hotline, operated by Ethics Global:
Toll-free phone line:
- Colombia: +57 1 800 518 9191
- Argentina: 0800 345 5478
- Brazil: 0800 900 0510
- Mexico: 800 043 8422
Website : https://simetrik.lineadeconfianza.com/
Ethics Global Mobile App using the code V22-7259-SIM
All reports will be kept confidential, and the whistleblower’s anonymity will be strictly preserved. Failure to report a violation of the Code of Ethics is considered a violation of the Code itself.
6. CONSEQUENCES AND CORRECTIVE ACTIONS
If a Third Party engages in conduct harmful to The Company in violation of this Code of Ethics, they will be sanctioned in accordance with the applicable laws, contractual provisions, and the commercial relationship, which may result in termination of the contract or relationship, in addition to any legal actions required.
Third Parties commit to cooperating with The Company in any investigation of violations or irregularities that could lead to administrative or judicial inquiries.
7. UPDATES AND DISCLOSURE
This Code will be reviewed and updated as necessary to reflect new legal or internal regulations. Any changes will be communicated to Third Parties.
8. EFFECTIVE DATE
This Code shall enter into force upon its publication and formal approval by the Board of Directors of Simetrik INC.