1. AIM
Communicating and explaining the conduct and standards of behavior expected of all of us at Axionlog, and adhering to them, is an integral part of our obligations as employees. It is Axionlog’s policy to comply with all laws, rules, and government regulations applicable to its business. The Company is concerned with how results are achieved, not just with achieving them. Directors, officers, and employees must conduct themselves fairly with each other and with the Company’s suppliers, customers, competitors, and other third parties. The Company expects adherence to its standard of integrity throughout the organization and will not tolerate employees who achieve results by violating laws or conducting business unscrupulously. All business transactions must be accurately reflected in its books and records.
The “Business Practices Policy” is an instrument that reinforces our firm commitment to the highest standards of business and personal conduct in all our actions related to the company where we work.
It is Axionlog’s policy that all employees demonstrate and maintain the highest level of integrity, responsibility, and professional conduct in all industrial, administrative, and commercial activities, and in their relationships with our customers, suppliers, employees, advisors, and the communities in which we operate. We value and safeguard the integrity of our employees and other individuals who represent and assist us in our work.
Our Company gives ethics the priority it deserves as an essential competency for all managers and employees and values it as a key factor in Axionlog’s growth and consolidation.
Your commitment to the principles and best practices outlined in this policy will allow us all to continue enjoying the reputation we have earned for our personal integrity, ethical conduct, and business excellence.
This policy includes a commitment to general responsibility, confidentiality of information, and electronic banking practices; as well as a description of questionable actions toward competitors, customers, and suppliers, and a non-exhaustive list of expressly prohibited practices.
2. SCOPE
These Business Conduct Standards apply to Axionlog and its subsidiaries and affiliates (collectively, “Axionlog” or “the Company”). The Standards apply to all Axionlog employees (including temporary employees) and to the Company’s Board of Directors. The Standards do not apply to our suppliers or their employees. However, they will be made aware of these Business Conduct Standards, and we therefore expect them to develop their own policies and procedures consistent with the spirit of these Standards and to fully support our employees in complying with them.
The relationship between Axionlog and each of its employees is governed by the national law of the jurisdiction where they are employed. Subject to applicable national law, nothing in the Business Conduct Standards changes the nature of that relationship. The current version of the Standards will be published and maintained on the Axionlog website. The amendments will also be posted on the website, as required by applicable laws, and will be communicated to employees in a timely manner.
3. DEFINITIONS
We understand our Standards of Business Conduct to be those behaviors that demonstrate the company’s values, such as ethics, loyalty, fairness, respect, and reliability, which ensure Axionlog’s reputation as a company that conducts all its activities transparently. These standards include those related to best practices in warehousing, distribution, transportation, and quality, as well as others related to the company’s purpose and, in general, all activities inherent to business administration (labor relations, financial management, etc.).
In general, these standards are a non-exhaustive guide and should not replace sound judgment. They aim to help in making the right decisions and will always be subject to committee review for updates and modifications.
4. REFERENCES
This Policy refers to the Corporate Acceptable Conduct Policy, Corporate Equal Opportunities and Anti-Harassment Policy, and Corporate Confidentiality Policy.
5. RESPONSIBILITIES
5.1 MANAGEMENT COMMITMENT
Axionlog’s management is committed to upholding high ethical standards. The Axionlog Board of Directors oversees the Company’s adherence to ethical principles and compliance with legal regulations.
5.2 ADDITIONAL RESPONSIBILITIES OF EMPLOYEES WITH SUPERVISORY FUNCTIONS
Employees with supervisory authority over others hold positions of trust and influence. Therefore, they have a special responsibility under the Business Conduct Standards to maintain an ethical work environment and set a good example. They must ensure that employees under their supervision understand and adhere to the Standards and complete all required compliance and ethics training. Furthermore, they must communicate relevant Axionlog policies to employees and help them understand these policies.
Supervisors must maintain open and honest two-way communication with employees. This means encouraging employees to ask questions, offer suggestions, and report any misconduct. Finally, supervisors must follow up on reports of alleged misconduct and take appropriate corrective or disciplinary action.
In all cases, they must notify the Human Resources Department in writing.
5.3 PERSONAL RESPONSIBILITY
Each of our actions represents Axionlog, and we must do our best to maintain our Company’s good reputation. Each of us accepts personal responsibility to do what is right; our success depends on it.
We accept the obligation to stop or prevent actions that could harm customers, the Company, or our reputation and to report such actions as soon as they occur. Employees who violate applicable laws, the Standards of Business Conduct, or policies are subject to disciplinary action, which may include termination.
6. DEVELOPMENT
6.1 OPEN COMMUNICATION / ETHICS HOTLINE
At Axionlog, we communicate openly and honestly, and we listen to reach an understanding. We ask questions and raise issues, even difficult ones.
If an employee becomes aware of any violation of the Business Conduct Standards or any applicable law or policy, they are responsible for reporting the violation immediately. Failure to do so makes them jointly responsible for the violation.
There are several ways to raise issues. If you believe a law has been violated, you should report it immediately to the HR Department or to lineadeetica@axionlog.com. For other matters, you can speak with your direct supervisor or another member of Management.
Axionlog, and all supervisory personnel, will not permit any form of retaliation against an employee who raises an issue or asks a question in good faith. Individuals who retaliate will be subject to disciplinary action, which may include termination.
6.2 OUR PEOPLE
We have a strong commitment to our people. We value their development and their contributions. We support and encourage working with passion to serve our customers, striving for excellence in everything we do.
6.2.1 EMPLOYMENT EXPERIENCE
We provide opportunities, promote talent, develop leaders, and reward achievements. We believe that a team of individuals with diverse experiences and backgrounds, working together in an environment that fosters respect and encourages high levels of engagement, is essential to our continued business success.²
The selection and promotion of our employees is based on transparent procedures that consider talent, aptitude, job skills, vocation, background, performance evaluation, ethical conduct, and commitment to the Company’s interests.
6.2.2 PROTECTION AGAINST RETALIATION
Axionlog protects its employees against retaliation. Axionlog will not allow retaliation against employees who report misconduct, raise an issue, or cooperate with an investigation, provided the employees acted in good faith and with a reasonable belief that the information provided was true. Anyone who retaliates will be subject to disciplinary action, which may include termination. If you believe you have been retaliated against, please contact HR.
6.2.3 HUMAN RIGHTS AND THE LAW
We support the fundamental human rights of all people. We will not employ children or workers below the legal working age for the type of work in the country where the work is performed. We prohibit physical punishment and harassment. We comply with labor laws in all the countries where we operate.
6.2.4 RESPECT AND DIGNITY
Each of our employees deserves to be treated with fairness, respect, and dignity. We provide equal opportunities to employees and job applicants.
Axionlog employees have the right to work in a workplace free from harassment, intimidation, or abuse, whether sexual or otherwise, or acts or threats of physical violence. We do not tolerate verbal or physical conduct that demeans another person, unreasonably interferes with another person’s job performance, or creates an intimidating, hostile, or offensive work environment.
For the purposes of this policy, harassment includes insults, offensive comments, electronic communications, and other
visual, verbal, or physical conduct that could create an intimidating, hostile, or offensive work environment. “Sexual harassment” includes unwanted sexual advances, requests for sexual favors, and any other conduct of an inappropriate sexual nature.
6.2.5 INCLUSION AND DIVERSITY
Axionlog is committed to diversity and equal opportunities for all. We respect the unique attributes and perspectives of each employee and leverage those perspectives to develop and enhance our relationships with customers and business partners. We promote diversity among our employees, customers, and business partners, and work diligently to ensure that everyone at Axionlog feels welcome.
Axionlog provides equal treatment and equal employment opportunities without regard to race, ethnicity, color, religion, sex, age, national origin, sexual orientation, military status, or other status protected by law.
The Company believes that diverse perspectives, working toward a common goal, enrich teams and contribute to sound decision-making.
This policy applies to our employees, candidates, independent contractors, and suppliers. It also applies to all aspects of interaction between Axionlog and customers and to our employment decisions, including recruitment, hiring, transfer, development, promotion, training, benefits, compensation, and termination.
6.2.6 SAFE WORKPLACE
We are committed to providing a safe and healthy work environment for our employees. We require all employees to comply with safety rules and practices and to take the necessary precautions to protect themselves and their coworkers. For everyone’s safety, employees must report accidents and unsafe practices to their immediate supervisors as soon as possible.
6.2.7 ALCOHOL AND DRUGS
The Company is committed to a safe, healthy, and productive workplace for all employees.
The possession and use of alcohol and illegal drugs are prohibited in the workplace and while participating in any work-related activity. You must not work under the influence of alcohol, illegal drugs, or any psychoactive substance that impairs your ability to perform your job safely and effectively.
- The distribution of drugs and alcohol in the workplace is prohibited.
- The possession and consumption of alcohol is prohibited on Company premises, except at social events sponsored by Axionlog where alcohol consumption is specifically authorized.
Axionlog can implement a random psychotropic testing program (drug and alcohol screening) for all employees to promote a safe and healthy work environment. This program is conducted fairly and equitably, ensuring that all employees, without exception, participate.
The random tests will be conducted confidentially and respectfully, guaranteeing employee privacy and complying with all applicable legal regulations. Due to the importance of workplace safety, these tests are mandatory, and any employee who refuses to take them will be committing an act of indiscipline and violating current safety regulations.
This preventative approach will not only help identify and address potential alcohol and substance abuse problems but will also reinforce the company’s commitment to the well-being and safety of its staff and our customers.
6.3 AXIONLOG, OUR COMPANY
We are committed to our suppliers, sharing the Company’s best practices with them. Our employees and suppliers must work together to provide the best logistics service experience.
6.3.1 WE ACT IN THE INTERESTS OF AXIONLOG
We always act with the long-term benefit of Axionlog in mind, never for personal gain or to favor family and/or friends.
6.3.2 SUPPLIER RELATIONS
At Axionlog, we recognize the importance of developing strong supplier relationships. We treat our suppliers honestly and fairly, and we expect them to treat us similarly.
Axionlog bases its supplier relationships on legal, efficient, and fair practices. While these Business Conduct Standards do not apply to our suppliers, we expect them to adhere to relevant legal requirements in their business relationships, including those with their employees, communities, and Axionlog.
Axionlog does business with suppliers from many countries with diverse cultural, social, and economic backgrounds and is committed to fair employment practices and strives to provide a safe, healthy, and productive work environment for its employees.
Furthermore, we strive to work with suppliers who share our values. This means that our suppliers are expected to share our support for fundamental human rights for all people; to treat their employees with fairness, respect, and dignity; and to follow practices that promote health and safety.
6.4 ETHICS
We operate our business within an ethical and responsible framework. We structure our business actions and conduct according to ethical and fair principles, respecting the laws and regulations of each market where we operate.
6.4.1 PROTECTION OF COMPANY ASSETS
The Company’s assets include information, financial assets, vehicles, office supplies, equipment, heavy machinery, computers, networks, software, telephone and internet services, voicemail and email, and all materials provided by the Company.
Any action involving theft, fraud, embezzlement, or misappropriation of any Company property is prohibited. Therefore, you may not use Company property, information, or your position within the Company for personal gain. Exercise your judgment and responsibility in the use of Company assets and do not abuse any privileges you receive in your position at Axionlog.
Company computers may not be used in any way that could compromise the security or integrity of Company information or software. Company computers or networks may not be used to access, receive, or transmit material that is inappropriate, illegal, or that may violate our confidentiality policy.
No Company property may be loaned, donated, or sold unless specifically authorized by the responsible executive. You will not use company assets, information, or your position for personal gain. You will not participate in any activity involving theft, fraud, embezzlement, extortion, or misappropriation of assets.
6.4.2 CONFIDENTIAL INFORMATION
Information is a valuable asset. Confidential information should not be disclosed to anyone outside of Axionlog or discussed with Axionlog employees who have no need to know it. Confidential information may include, for example, unpublished sales and financial information, significant changes within the Company, operating or product methods, marketing or real estate plans, research results, employee data, and information about relationships with suppliers and other relevant parties. Treat all information as confidential if it could be useful to your competitors, if it invades the privacy of employees or customers, or if it could be harmful to Axionlog if publicly disclosed.
Take precautions to avoid accidentally disclosing confidential information. For example, mark it appropriately, never discuss it in public, and keep your personal computer secure.
6.4.3 PERSONAL DATA
We respect and value the privacy of our employees and customers, and we maintain confidentiality when handling your personal information. This means that you must treat the personal data of all employees and customers with care and respect, while safeguarding against inappropriate access and disclosure. You must never use such data for personal gain or in any other inappropriate manner.
6.4.4 CONFLICTS OF INTEREST
Each person working at Axionlog must avoid any situation in which our personal or financial interests could cause our loyalty to be divided or questioned. Employees must refrain from taking for themselves opportunities discovered through the use of corporate assets or through their positions within the Company.
Employees must avoid transactions involving Company securities based on material, non-public information known through their positions within the Company. Employees must refrain from competing with the Company. Any conflicts of interest that could cause others to question our fairness or integrity must be avoided.
We are all responsible for reporting any actual or potential conflict of interest to the Human Resources Department and for complying with all conditions imposed on you to control or eliminate the conflict. Such conditions could include, for example, removing you from decision-making on behalf of Axionlog or requiring you to divest yourself of the external interest that creates the conflict.
The following are some activities that may be considered conflicts of interest. This list is not exhaustive, but serves as a guide to identify potential conflict situations.
- Employment outside the Company and other business arrangements
Employees have a primary duty to promote the interests of Axionlog, and any personal business arrangements must not interfere with this obligation. As an Axionlog employee, you may not accept or receive compensation from any supplier or business entity with which you conduct business on behalf of Axionlog.
- Doing Business with Family and Friends
A conflict of interest can arise when you have any business dealings with close family members or friends. You must report any potential conflicts of interest to both your supervisor and the Human Resources department. You should also be cautious about the information you share with family members or friends who work for competitors or have business interests in competitors. This also applies if you have family members or friends who work for suppliers or service providers that have business interests in those companies.
- Conflict of interest among Axionlog employees
Any employee who becomes aware of a potential conflict of interest arising from the position held within the company by their spouse, relative, family member, or other person must report it to the Human Resources Department. This also includes romantic relationships between supervisors and subordinates, which must be reported immediately in order to resolve the conflict of interest.
- Business-Related Gifts, Favors, and Entertainment
We will not offer or pay bribes or provide items of value for the purpose of influencing, or giving the appearance of influencing, the judgment or actions of others.
We will not seek or accept any type of bribe, kickbacks, or any other type of inappropriate payment. We respect the policies of other organizations with which we do business; however, we understand that the purpose of offering gifts and entertainment in a business setting is solely to foster a satisfactory and good-faith business relationship between companies.
Furthermore, any person who receives a gift or an invitation to an event in the global work environment receives it by virtue of their position and their affiliation with Axionlog. Therefore, all employees of the company should be able to participate in the enjoyment of the gift or event, as everyone shares in the reason for receiving the gifts.
The following applies to Company employees, immediate family members of Company employees, and agents or third parties working on behalf of the Company: Do not offer, give, or accept any gift, entertainment, or other personal benefit if it: Does not adhere to customary or customary business practices; or Is in cash or a cash equivalent, commissions, loans, credits, discounts, securities, goods, or services below market price; or Could be considered a bribe or reward; or Violates any law, policy, or regulation.
Based on the above, and as a strict rule: All business gifts received must be turned over to the local Human Resources Department, including personalized gifts. All gifts must be raffled among Company employees, ensuring that everyone benefits, as everyone is involved in the Company’s business. If, due to its low value or any other circumstance, someone wishes to keep a gift received, they must consult with the HR Manager and obtain express authorization to do so. A written record of this fact and the reasons must be kept.
Furthermore, the HR Manager must inform the Corporate HR Director of the reasons for granting this authorization. Gifts received at a personal residence will be treated the same and must follow the same procedure for delivery to the HR Department. The local HR Department will be responsible for determining at which company event the received gifts will be raffled and who may be excluded from the raffle due to having received a serious or very serious disciplinary sanction or for non-attendance.
In the case of business events and/or lunches, it is not considered appropriate to attend frequently or to participate in extraordinary events, unless expressly authorized by the Country General Manager for business reasons. Any questions should be directed to the HR Department or the Country General Manager.
Violating these rules by misappropriating gifts or attending extraordinary events without proper authorization will be considered a serious offense and will carry the corresponding consequences. We reiterate, all Axionlog employees build the company and contribute to the business, and therefore all employees should share in any gifts received for their work.
- Foreign Investments
Employees may not own, directly or indirectly, a substantial interest in any business entity that conducts or intends to conduct business with or competes with Axionlog.
A substantial interest means an ownership interest exceeding 5% of the total net worth held by the employee and their immediate family members, or exceeding 1% of the outstanding shares for investments in a publicly traded company.
Exceptions to this rule may include investments in mutual funds or managed accounts where employees have no discretion over investment choices. Do not exploit for your personal benefit any business or investment opportunities discovered through the use of company assets, information, or your position within the company. This includes directly or indirectly purchasing, leasing, or otherwise acquiring rights to any property or materials if Axionlog may also have an interest in pursuing such an opportunity.
Finally, do not make a personal investment in an entity if the investment could or would affect your judgment in business decisions related to that entity. Be aware of potential conflicts of interest that may arise in private and public companies and exercise caution regarding insider trading issues that may be associated with investments in public companies.
6.4.5 USE OF ELECTRONIC COMMUNICATIONS
Everything related to email and electronic communication systems in general, including all communications and information created, received, stored, or sent on Axionlog’s systems, is the property of the Company. Employee access to and use of these systems is a privilege granted by the Company.
Employee emails sent and received through Company computers, including email and internet search activity, are subject to search and monitoring, with or without notice, regardless of whether Company systems are accessed from inside or outside the office, or whether communications pass through a Company server. The Company will periodically and randomly monitor individual employee usage. For these reasons, employees have no personal right to privacy in any material created, received, stored, or sent using email or the Company’s computer systems, including external internet providers, nor can they expect privacy in such communications.
The Company will take the necessary actions to implement clearly and precisely the points described herein, guaranteeing at all times the purpose of the use of the tools provided for the performance of the work, and the protection of the rights of the people involved, in accordance with the applicable legal regulations.
6.4.6 USE OF USER ID AND PASSWORDS
The systems are designed so that user IDs and passwords are personal. Each employee must use their personal username and password to access Axionlog systems. These must not be shared under any circumstances. Failure to comply will result in disciplinary action, which could include termination.
Employees are responsible for keeping their user IDs and passwords secure. They must never be disclosed or shared with anyone. If someone asks for your password or user ID, refuse to give it and immediately inform the Human Resources Department.
If you suspect for any reason that your password and/or user ID has been compromised, change it immediately and report your suspicion to the Human Resources Department.
6.4.7 BUSINESS RECORDS AND COMMUNICATIONS
Axionlog has a responsibility to efficiently inform its shareholders about material aspects of the Company. Shareholders must receive honest, accurate, and truthful information that allows them to make responsible business decisions based on reliable records.
All financial books, records, and accounts must accurately reflect transactions and events. They must also conform to both generally accepted accounting principles and Axionlog’s system of internal controls.
All reports, statements, and public documents submitted to regulatory authorities in any of the countries where Axionlog operates, as well as all official communications from the Company, must be accurate, complete, clear, and understandable. To ensure the accuracy of all records and presentations made by Axionlog, you must never: Make false entries or alter receipts in expense reports; Enter false information on timesheets; Alter or falsify quality or safety results; or Understate or exaggerate known assets or liabilities. Maintaining undisclosed or unrecorded assets, funds, or property, or assets “off the books”; incorrectly recording or failing to record items that should be considered expenses; or making entries that intentionally conceal or mask the true nature of any transaction.
Employees are expected to accurately record all business transactions in the Company’s books and records and to be honest and communicative with the Company’s internal and independent auditors.
During the course of litigation or government investigations, nearly all business records, including email and computerized records, may be made public. The media and other organizations frequently obtain records. Therefore, employees must be clear, concise, truthful, and accurate when recording any information. Avoid exaggeration, flowery language, guesswork or assumptions, drawing legal conclusions, and making derogatory characterizations of people and their motives.
Documents must be retained in accordance with the regulatory and legal requirements of each country. Please contact the HR Department if you have any questions about whether it is appropriate to keep or destroy a document.
6.4.8 THE LETTER AND THE SPIRIT OF THE LAW
Our first and foremost obligation in every country and community where we operate is to obey both the letter and the spirit of the law. This applies to Axionlog employees as well as to third parties acting on behalf of our company.
If you have any concerns about the legality of any matter, you are responsible for consulting with the Human Resources Department before any potentially illegal action takes place.
6.4.9 INTERNATIONAL BUSINESS
Axionlog complies with all applicable laws and regulations wherever we do business. Almost every country in the world prohibits making payments or offerings of anything of value to government officials, political parties, or candidates to obtain or retain business. Commissions or fees should never be paid to intermediaries, distributors, agents, brokers, or advisors that are used as bribes or kickbacks.
The term “government official” includes any employee of any government or any government agency or any international public organization, any political party or party official, or any person acting in an official capacity for or on behalf of any government or any candidate for public office.
Payments made indirectly through a third party are also prohibited, especially if it is known or highly likely that the payment or offer of payment is being made to a government official for the purpose of influencing their actions or decisions.
Many laws govern business conduct across borders. These include laws that: Require that transactions not be used for money laundering; They ensure that companies do not cooperate in any way with unsanctioned boycotts; they restrict trade with certain countries; and they prohibit transactions that could aid terrorists or organizations that support terrorists.
Any employee with concerns about any legal matter is responsible for consulting with the Human Resources Department before taking any potentially illegal action.
6.5 PROFITABLE GROWTH
We grow our business profitably. We maximize the profitability of our operations.
6.5.1 FAIR COMPETITION AND ANTITRUST POLICY
Most of the countries in which we operate in Latin America have fair competition or antitrust laws to safeguard consumers’ right to obtain the best products at the best prices. Axionlog supports and complies with these laws. Among other things, these laws generally prohibit: Entering into any contract or agreement, whether formal or informal, with a competitor that fixes, controls, or affects prices, products, terms of sale, costs, profits, profit margins, markets or market shares, or distribution practices.
Contracts or agreements with a competitor to allocate customers or products, to boycott suppliers or individuals with whom they would otherwise do business, or to bid or not bid in business in general. Competition laws also govern our relationships with suppliers.
It is the responsibility of any individual who has questions about these matters or any other discussion, decision, or action that may have potential antitrust implications to consult with the Human Resources Department before taking any such action.
6.5.2 BUSINESS PRACTICES
Information about competitors and suppliers is a valuable asset. We respect the rights of competitors and suppliers and will act fairly with them in the marketplace. We strive to achieve competitive advantages through research, marketing, execution, quality, and service, never through unethical or questionable business practices.
We do not engage in unfair or illegal business practices. The following rules apply when Axionlog or anyone working on our behalf collects or uses information regarding competitors or suppliers: Respect the intellectual property rights of others, including patents, copyrights, and trademarks; do not accept, disclose, or use information that was disclosed to you in contravention of a confidentiality agreement; do not disclose or use information that could be proprietary or confidential without consulting the HR Department; do not use unethical or illegal methods to collect information about companies; do not steal information that constitutes a trade secret or persuade former or current employees of other companies to divulge trade secrets; and do not take any action that could create the appearance of an improper agreement with competitors.
6.5.3 GOVERNMENT INFORMATION REQUESTS
Axionlog cooperates with government agencies and authorities. All requests for information other than those routinely provided should be forwarded immediately to the Finance Department for a proper response.
All information provided must be honest, accurate, and truthful. Never deceive any investigator or alter or destroy documents or records subject to an investigation.
6.6 CONTINUOUS IMPROVEMENT
6.6.1 CORPORATE MANAGEMENT AND INTERNAL CONTROLS
We have a system of internal controls and reporting mechanisms designed to protect the Company’s assets and operations and to provide accurate, honest, and timely information to Management, the Board of Directors, and shareholders.
The external auditor provides independent oversight of the preparation of the Company’s financial statements and internal control systems. Employees are required to conduct themselves in accordance with the letter and spirit of our internal control system and to cooperate fully with any audit or investigation.
6.6.2 CHANGES TO THE RULES
Any modification to the Rules must be approved by the Axionlog Board of Directors, after formulation by the HR Department and must be publicized on the Axionlog bulletin boards within five days of its approval.
6.6.3 INTERNAL INVESTIGATIONS
Axionlog encourages employees to raise questions, express personal concerns, and provide appropriate suggestions regarding the Company’s business practices. Employees are expected to promptly inform Management of any suspected violations of the law, Company policies, and internal controls so that Management can take appropriate corrective action.
Management should communicate with the Human Resources Department. The Human Resources Department is responsible for investigating violations of the Company’s internal controls.
Reports of suspected misconduct are taken very seriously by Axionlog. If you become aware of an internal investigation, or if you are asked to provide information or assist with an internal investigation, the following rules apply: You may not discuss anything about the investigation with any person, whether inside or outside of Axionlog, without the express consent of the individuals authorized to conduct the investigation; You must provide all relevant information completely and truthfully, and fully cooperate with the authorized investigation team throughout the course of the investigation. And if you interfere with the investigation or provide false information during the course of it, you may be subject to disciplinary action, which may include termination of employment.
6.7 RESOURCES
Each of us personally embodies these values. Get support if you need it. These resources are a good place to start.
The HR Department is available to answer any questions about the Business Conduct Standards or to review potential violations. Please send an email to lineadeetica@axionlog.com.
You can obtain copies of these policies by requesting them from your local HR office or downloading them from the intranet.
Once you have read these standards, you must complete and sign Appendix A and then submit this certification to the HR Department.
7. FREQUENCY
This policy applies every time a document is created, modified, and controlled.
8. MONITORING, SURVEILLANCE AND VERIFICATION
This policy is monitored during each document authorization process. Monitoring is recorded through the publication of the documents themselves, while oversight is documented via email to the Corporate Internal Audit Manager, reporting any findings. The policy’s validity is verified annually and recorded with any policy modifications or authorized extensions. In all cases, this is the responsibility of the HR manager in each country.
9. CORRECTIONS
The corrective actions in case of non-conformities in the format and control of documents and records are as follows:
- Inform the person responsible for the nonconformity so they can review the procedure and correct it.
- Inform your direct supervisors if you lose control of the documentation.