MANAGEMENT OF THE CODE OF ETHICS AND CONDUCT

In order to encourage living our values and to structure a means to solve the ethical dilemmas, this section establishes a mechanism to manage Rassini’s CE&C.

Any suggestion, doubt and/or clarification regarding the contents of this document shall be addressed by the Corporate Human Resources Management and/or by the Legal Department.

Procedure for Queries, Suggestions or Complaints against Violations to the Code of Ethics and Conduct

Rassini’s CE&C is applicable to the company, and it is our responsibility to comply with it and to enforce it. To this purpose, a platform called Integrity has been created, where multiple communication channels have been established, which may be used by collaborators to evidence inappropriate behavior in the company.

It is not always easy to define and judge if a situation violates the law, ethics, or the provisions of this document; therefore, any doubts about the legal and/or ethical nature of a situation should be immediately reported through the Integrity platform.

Rassini encourages its collaborators and stakeholders to report immediately any evidence they have about violations to this CE&C.

When issuing a complaint, it is necessary to have all the information on the case by answering the questions Who? When? Where? How? as well as the material evidence in case of having it.

The channels available for complaints are:

Web Assistant or chat: www.integrity-rassini.com

Telephone: 800-002-INTEGRITY (468347)

Email: etica@integrity-rassini.com

Mobile App: “EthicsGlobal”
An external specialist will contact you to provide assessment and/or support, he or she will ask a series of relevant questions in order to obtain appropriate information on the case, which in all cases will be confidential.

This external specialist provides alternatives to collect evidence should the complainant not have any evidence.

Upon filling the complaint, a follow-up number will be provided. By using the number, one can dial the telephone number at any time, or enter the website in the complaint follow-up field, to:

Know the status of the investigation.
Repeated complaints.
Provide additional information.

Attach files and evidence.

Rassini’s collaborators are committed to cooperate in the internal investigations on the subject matter. Likewise, Rassini is committed to having internal investigators trained and updated for the management and followow-up of the filed complaints.

Rassini will guarantee the confidentiality and there shall not be any type of retaliation, threat, or intimidation due to reports sent to the Ethics and Conduct Committee through the channels provided by Integrity platform.

System of Consequences

Living our values intensely benefits us personally and those around us; Rassini encourages it, and it publicly acknowledges exceptional cases.

When a person incurs in a breach to the CE&C and/or to the Internal Labor Regulations or to any applicable laws in force, the penalty will range from a warning to dismissal or the corresponding legal actions, depending on the seriousness of the fault.

In Rassini, the immediate superior must be an example in the practice and endorsement of the values promoted by this CE&C; he or she must recognize employees when they practice these values and impose penalties promptly in case the staff under his/her supervision has incurred in any defaulting behavior. Any omission by Rassini’s collaborators in reporting a violation to the CE&C constitutes by itself, a violation by omission or complicity.

Administrative Structure of the Code of Ethics and Conduct.

The administration of the CE&C is in charge of the following persons or entities:

Immediate Superior
Human Resource Areas of the corresponding Business Unit
Rassini’s Ethics and Conduct Committee
Rassini’s Ethics and Conduct Committee shall be considered an “Ombudsman” institution, that is to say, it will act as a representative and mediator of the collaborators’ interests. This committee will provide certainty to the procedure in processing complaints for violations to this CE&C.

The Ethics and Conduct Committee is responsible to ensure that this CE&C is dully disseminated and applied, this means:

  • Promoting the values and behavior set forth in this document.
  • Acting as an advisory body.
  • Channeling cases to the appropriate instance.
  • Approving corrective measures to guarantee consistency.
  • Generating statistics and reports.
  • Reviewing requests for clarification from the staff.
  • Reviewing investigations.

In addition to the aforesaid tasks, Rassini’s Ethics and Conduct Committee, has also the following duties:

• To update and amend the CE&C.
• To investigate and document cases selectively.
• To promote consistency at worldwide level, in respect to the interpretation and application of this CE&C.

To adequately manage its duties, the Committee is constituted with five individuals of Rassini, from different areas, who stand out for their exemplary career, are highly recognized and honorable, have also a comprehensive business vision and are fully committed to their duties.

The members of Rassini’s Ethics and Conduct Committee are appointed by the Chairman and or General Management, which will chair said Committee. The Committee is governed by the policies of this code.

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