CODE OF ETHICS AND CONDUCT - Oben Group€¦ · This Code of Ethics and Conduct defines our collective personality: an ongoing sense of duty and responsibility designed to maintain

ETHICS AND CONDUCT

CODE OF

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CONTENTS

MESSAGE FROM THE EXECUTIVE PRESIDENT1.

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A CODE BASED ON VALUES

EVERYBODY’S RESPONSIBILITY

THESE ARE OUR COMMITMENTS

REGARDING ADMINISTRATION OF THE CODE

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PRESIDENTTHE EXECUTIVEMESSAGE FROM

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Dear colleagues:

Thank you very much,

Yamal Zaidán

MESSAGE FROM THE EXECUTIVE PRESIDENT

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In the Oben Holding Group family, we have always been characterized by our duty to ourvalues. It is our daily actions which define and highlight the company’s personality, for eachone of us and for our families. That is why we have a duty to reflect that value culture throughexemplary conduct and ethical behavior at all times; and remember that we are bound toreinforce such values every day, to ensure that they will endure.

This Code of Ethics and Conduct defines our collective personality: an ongoing sense of dutyand responsibility designed to maintain the value culture of our company. Meeting suchstandards involves more than simply reading this document: such a culture must be lived andpromoted from one day to the next; at work, in our homes, and among our family members.

And that is why I invite you to give life to these guidelines by striving to transform them intohabits. That is the best tool we have in the task of working to achieve our objectives year afteryear, while maintaining our character intact. This is a guide committing us to our own valueculture, our culture of doing the right thing.

At Oben, we are committed to what we do, and what we do we do well. I am counting on yourvaluable support and commitment to our shared goals.

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2. VALUESBASED ONA CODE


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SAFETY COMMITMENT EXCELLENCE

EXCELLENCEDYNAMISM

Our code is based on our corporate values, which are reflected in the behavior expected from all those who workwith Opp Film Peru. This code is the vital ingredient necessary for full compliance with our Mission and Vision.

Develop, produce and market plastic films for flexible packaging and complementary products with commitment,quality and efficiency

To be a global leader in the production of plastic films for flexible packaging.

At Opp Film Peru we value:

2.1 MISSION

2.2 VISION

2.3 CORPORATE VALUES

We seek new ways of doingthings.

We do our best to be one stepahead.

We respond quickly and positivelyto changes.

We seek out best practiceswithin the market in order toimplement them.

Our customers receive animmediate reply; we arequick and precise whenproviding information.


2.3.3. EXCELLENCE: We seek constant improvementthrough learning, efficiency andinnovation

2.3.4. DYNAMISM: We evolve in a proactive mannerin order to adapt to changes inthe environment

2.3.5. PASSION:We act with joy, optimism,perseverance and lots ofenergy.

We analyze our processes inorder to improve them.

We recognize that we havethings to learn.

We seek to generate savingsin costs, time, and resources.

We work in an orderly, cleanand safe manner.

Our customers always receivea quality service.

We like what we do and alwaysenjoy doing it with a smile.

We are coherent in what we sayand do, we take on challengesenthusiastically and willingly.

For us, the only approach is“Yes we can”; we look to thefuture with enthusiasm.

Each one of our customers isunique and special; their prioritiesare our priorities.

2.3.1. SAFETY:

2.3.2. COMMITMENT:We are always careful to remaina team dedicated to surpassingour goals and exceeding theexpectations of our customers.

We fully comply with establishedsafety guidelines.

We identify risk situations,and we correct unsafe acts byteaching and reporting.

We propose ongoingimprovements that minimizerisks in the workplace.

By working in a safeenvironment, we produce to ahigher standard, transmittingconfidence to our customers.

We overcome difficultiesthrough our perseverance.

Our knowledge is complementedby the experience and knowledgeof other team members.

We cooperate in order to achieveand exceed our objectives.

We provide our customers witha range of alternative solutions,as part of our commitment totheir satisfaction.

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We prioritize the wellbeing ofour collaborators, because theyare our most important asset.

We instill in our collaborators aculture of prevention.

UN CÓDIGO BASADO EN VALORES

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RESPONSABILITYEVERYBODY’S

Our Code constitutes a public declaration through which OppFilm Peru states its commitment to doing the right thing. It is ahighly valuable resource which contributes to collaborators andother persons making well-founded and ethical decisions.

Our Code includes references to in-house requirements of OppFilm Peru, including policies and procedures. Naturally, no codeof conduct can cover every possible situation; therefore, wetrust that individuals will use their good judgment and speak outclearly whenever a question or concern arises.

The fact that we operate in more than 10 countries means thatoccasions may arise in which local laws, regulations or customsmight enter into conflict with our Code. In the event that aconflict or difference arises between our Code and applicablelegal requirements, the law must always take precedence.

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3.

It is the responsibility of all Opp Film Peru collaborators to:

Read all the informationdescribed in our Code and to actin accordance with the established.p rinciples.

Act in a safe, ethical manner,in accordance with applicablelaws and regulations, in-houserequirements, values andbehavior, and in keeping withour objectives.

Ask questions and express yourconcerns if you become awareof any possible infraction of thelaw, regulations, our Code, orthe requirements of Opp FilmPeru.

Cooperate fully if required atany time to respond to aninvestigation or audit.

Help the members of your teamto understand the principles andguidelines of our Code, therequirements of Oben HoldingGroup, and applicable laws.

EVERYBODY’S RESPONSIBILITY

3.1.1 THE ENTIRE OBENHOLDING GROUPOur Code is applicable to allOpp Film Peru collaborators,including the Senior Managementand the members of the Board ofthe Oben Holding Group.

3.1.2 OUR CUSTOMERSAND SUPPLIERSOur customers and suppliersinclude partner companies andthird parties, and they can directlyaffect our reputation through theirown behavior.That is why we wish to worktogether with clients and suppliersand share our commitment tosafety, ethics and compliance.In this regard, we expect andencourage all our contractors andtheir employees to act inaccordance with our Code.If we consider that they havenot complied with our expectationsor with their obligations, we willtake appropriate measures toensure their compliance.

3.1 WHO MUSTADHERE TO OURCODE?

3.2 RESPONSIBILITIESOF ALL OURCOLLABORATORS

Each one of us is responsible forspeaking out if we see an unsafe,unethical or potentially damagingsituation. If you have any questions,need help, or you would like toexpress your concerns, you havea number of options available toyou, defined in Section 5.2“Receipt of Complaints”.

3.3 SPEAK UPUNRESERVEDLY

At Opp Film Peru reprisals are nottolerated. We believe that acts ofreprisal constitute reproachableconduct. Reprisals may take a numberof forms, such as for example threats,intimidation, exclusion, humiliation, andthe posing of questions in a maliciousmanner or in bad faith. If you believethat you or someone you know hassuffered reprisals, contact us throughthe options available, as defined bySection 5.2 “Receipt of Complaints”.

3.4 ZERO TOLERANCEFOR REPRISALS

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Below, we present our commitments, those principles that governthe conduct of Opp Film Peru.

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4. COMMITMENTSTHESE ARE OUR

Stop any type of work activity(yours or that of another person)if you consider it unsafe.

Comply with established companysafety protocols (for example,wear an identification card andrespect inspection of the samewhen entering the workplace).

4.1.2 INFLUENCE OFALCOHOL AND DRUGSDURING WORKING HOURSUnder no circumstances will wetolerate the following conduct:

Reporting for work under theinfluence of alcoholic drinksand/or illegal drugs.

Possession or consumption ofillegal drugs within or beyondthe facilities of the companieswithin the Group.

4.2.1 WORKING PRACTICESAND CONDUCT IN THEWORKPLACEAs a collaborator of Opp Film Peru,you must comply with the followingobligations:

Display integrity, ethics andtransparency at all times in theperformance of your duties.

Do not take advantage ofanother collaborator throughmanipulation, covering up,undue use of confidentialinformation, false declarationsconcerning relevant occurrences,or other unfair practices.

Generate a working environmentin which respect and professionalismtake precedence.

Comply with the laws andregulations applicable toyour company.

Arrive punctually at your workplaceand do not fail to report to workwithout proper justification.

Always wear the complete companyuniform when at the workplace.

Eeport any failure to comply withthis Code.

We know that each one of ourcollaborators has a family to lookafter (directly or indirectly), andthat their family expects them tocome home safely at the end ofthe day. That is why we concernourselves with maintaining a safeworking environment, providingthe tools and equipment neededto ensure the health and safetyof our collaborators.

4.1.1 HEALTH AND SAFETYIN THE WORKPLACEAs a collaborator of Opp Film Peru,you must comply with the followingobligations:

Comply fully with safety proceduresand rules (for example, usepersonalprotective equipment, respect safeoperating rules and safety notices,etc.), because this is the only wayin which we can meet our target ofzero accidents.

Our collaborators are the key to thesuccess of Opp Film Peru, and thatis why we cultivate a workingenvironment in which integrity,honesty and transparency prevailin all our actions, 24 hours a day,365 days a year, because we areaware that we are representativesof Opp Film Peru and Oben HoldingGroup at all times.

Only perform those tasks for whichyou have been trained.

Immediately report any accident,incident, illness or unsafe conditions.

Do not assume that someoneelse has completed a task.


4.1 OPERATE IN ASAFE, RESPONSIBLEAND RELIABLEMANNER

4.2 MAINTAINETHICAL CONDUCTAT ALL TIMES

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4.2.4 CONDUCT INPRIVATE LIFEWe respect the privacy of ourcollaborators, and we take aninterest in what they do beyond theworkplace if it affects the reputationof the legitimate business interestsof the group; in this context,collaborators are expected not toinvolve themselves in illicit, immoralor degrading businesses, or otheractivities which place in doubt theirmoral solvency.

4.2.5 CONDUCT IN SOCIALNETWORKSAs a collaborator of Opp Film Peru,you are expected to comply withthe following obligations:

Employ appropriate languageand conduct in communicationswith the media or social networksassociated with Oben HoldingGroup or subsidiary companies,providing truthful information atall times.

Avoid acting on your ownaccount and provoking debateson social networks associatedwith Oben Holding Group orsubsidiary companies, or whichare associated with competitors.

4.2.6 CONFLICTS OFINTERESTAt Opp Film Peru we act honestlyand ethically, avoiding situationsthat might involve a conflict betweenpersonal interests and those ofOpp Film Peru. In this regard,collaborators are expected to adhereto the following guidelines:

Do not take decisions or conducttransactions with customers,suppliers or competitors withthe intention of generating anypersonal benefit, directly orindirectly, above what is best forOpp Film Peru.

Do not use the assets, or theconfidential, privileged and strategicinformation of Opp Film Peru forpersonal benefit, directly or indirectly.

Do not develop other activitieswhich interfere with or enter intoconflict with our activities or yourduties at Opp Film Peru.

Investments must not be madewhich grant a collaborator managementpowers with supplier companies,customers or competitors, or with anycompany which maintains businessrelations with Opp Film Peru.

Any conflict of interest must be divulgedto the Human Management departmentfor assessment at the time an individualjoins the company and at any timeduring their working relationship withthe company.

4.2.2 USE OF THE NAMESOR LOGOS OF OPP FILMPERU AND OBEN HOLDINGGROUP

No collaborator should use the namesor logos of Opp Film Peru and ObenHolding Group or of any of the othercompanies that belong to the groupfor any purposes beyond thoseperformed in the workplace, such asexternal work or other activities forpersonal benefit, or for the benefitof unauthorized third parties.

All collaborators must safeguardthe tangible and intangible assetsof Opp Film Peru. In this regard,collaborators must abide by thefollowing guidelines:

4.2.3 INAPPRORIATE USEOF ASSETS

Use the assets and resourcesof Opp Film Peru solely for thepurposes for which they areintended, avoiding any personaluse or other type of use.

Do not reveal confidentialinformation, including after leavingthe company.

Do not remove any information referring to Opp Film Peru upon completion of your working relationship.


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vacancy he/she is applying to areevaluated. If a relative is selected,he/she could not take a positionmanaged the collaborator he/sheis related to.

No decision is taken based ondiscriminatory criteria such asrace, color, religion, gender, sexualpreference/orientation, nationality,civil status, age or disability, nor inany other condition protected bylaw or regulations.

4.3.2 WORKING ENVIRONMENTFREE OF HARASSMENT

We do not tolerate any form of harassmentor behavior that creates an intimidating,hostile and offensive working environmentfor the collaborators. Some types ofharassment are:

Sexual harassment, through physicalcontact or unrequested gestures.

Inappropriate comments or jokes.

Offensive and explicit images

Abuse or intimidation.

Harassment at work.


When the respect and cherish isshared among us, we can achievesuccess both individually and as acompany. We all play an importantrole in keeping a corporate culturebased on respect and equity.

We valued having workforce

4.3.1 DIVERSITY ANDINCLUSION / EQUALOPPORTUNITY

4.3 RESPECT ANDEQUITY

composed by collaborators with different skills, perspectives and opinions. On this regard:

The decisions regarding hiring andpromotions are taken based onmerits/performance, individual skills,abilities, training and other factorsrelated to the business.

If a collaborator’s relative wants tobe hired, he/she should applyaccording to the available jobopening and must go through thecorresponding selection process,in which competencies andexperience necessary to fill the

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TRABAJAR CON LOS SOCIOS

Sustainability is the purpose of allinitiative and, being aware of that,we look for not only sustainability ofthe business, but significance withthe clear objective of consistentlycontributing to communitydevelopment, environmental careand respect for human rights.

4.4.1 ENVIRONMENT

We are committed to conductingbusiness in such a way that theenvironment is protected, naturalresources are preserved andsustainable development isguaranteed. In that regard, wehope that each of our collaboratorsserves in an environmentallyresponsible way, according tothe policies set forth for suchobjective.

4.4.2 COMMUNITYWe contribute in different ways tothe development of communities,not only the nearby ones,through the support of differentorganizations seeking to generate

a comprehensive developmentand social promotion of peoplein distressed areas.

4.4.3 HUMAN RIGHTSWe work hard to conduct ourbusiness in such a way humanrights and people dignity isrespected, in that sense:

We provide a workingenvironment and conditionsensuring the correspondingcompliance of the functionsof each collaborator.

We are against human rights’abuse, such as child labor, humantrafficking and forced labor.

We expect our collaborator toreport any abuse of humanrights in our operations orwithin our commercial partners.

4.4 CONTRIBUTE TOTHE SUSTAINABLEDEVELOPMENT OFGOVERNMENTS ANDCOMMUNITIES WEWORK WITH

4.5 WORK WITH CLIENTS AND SUPPLIERS IN ANHONEST,RESPECTFUL ANDRESPONSIBLE WAY

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We treat our clients and suppliers fairly, encouraging free competition among suppliers and equal treatment among all our clients.

4.5.3 UNFAIR COMPETITIONWe are committed to compete in themarket under a context of integrityand respect with our competitors.In that sense, the collaborators ofOpp Film Peru must:

Comply with the current laws andregulations on fair competitionof the countries we participate.

Exhibit a professional attitude,based on the principles andvalues of Opp Film Peru, in allengagement with the competitorand the regulators.

Not participate in any agreementwhich intends to limit the freecompetition in the market weoperate.

4.5.4 TRUSTWORTHINESS OFOUR PRODUCTS

Elaborating products of high qualitythat meet our clients’ needs.

We value the trust that our client investin us. In that regard, in Opp Film Peru,we are committed to:

Increasing our quality standards tomore demanding levels. In compliancewith the necessary certifications,we improve our management systemsand make regular audits.

Complying with good manufacturingpractices (GMP) and hygiene.


4.5.1 CLIENTS

Our clients are very important to us,in that regard, we are committed to:

Providing accurate informationthat is appropriate and suitableto the clients’ demands andrights.

Always treating the client in apolite way.

Not keeping commercialrelationships with clientsparticipating in illegal business.

4.5.2 SUPPLIERSWe engage in commercialrelationships with our suppliers ina responsible way, based onhonesty, respect and ethics. Inthat regard, we are committed to:

Negotiating in an honest andfair way with our suppliers,without discrimination and/orimpositions.

Respecting our suppliers,paying them on time for theirservices.

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Working with suppliers who actaccording to the principles setforth in this Code in the activitiesrelated to Opp Film Peru.

SER HONESTOS Y TRANSPARENTES EN NUESTRAS OPERACIONES Y RESULTADOS


4.6.1 ACCURATE ANDCOMPLETE INFORMATIONRECORDING

The business partners, thegovernment officials and the publictrust that our business disclosuresand registrations are accurate andcomplete.Such information is also essentialwithin Opp Film Peru, so that wecan take appropriate decisions.In that regard, we are committed to:

Guaranteeing that all transactionsare duly authorized, recordedand timely declared, as required.

Complying with the applicablelaws and with the requirements ofOpp Film Peru when documentsare created, kept, retained ordestroyed, including those inelectronic format.

Ensuring that all necessary approvals are in place when an answer is given to an information request made by agovernmental or regulatory body.

4.6.2 CONFIDENTIALINFORMATION USE

Confidential information isinformation you become aware ofduring the performance of yourfunctions, information related tothe brand of Opp Film Peru and/orinformation regarding its personnel,current and future clients, suppliersand shareholders. As collaborator,you must comply with the followingobligations:

Not to disclose confidentialinformation to unauthorized thirdparties unless it is part of yourwork functions and you receiveexplicit authorization to do so.

Not to disclose informationrelated to clients to any personwho is not part of Opp Film Peru.

To require approval of theGeneral Management torespond information requestsconsidered as unusual madeby regulatory, supervisory andgovernmental entities.

To ensure the adequatepreservation of documentationand information managed byyou during the performance ofyour functions, applying to that

end the policies and standards ofsecurity and protection of informationset forth by Opp Film Peru.

To comply with the current regulationregarding the security and protectionof the personal information of clientsand collaborators.

4.6 BEING HONESTAND TRANSPARENTIN OUR OPERATIONSAND RESULT

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We all contribute in the recordingprocess of financial and non-financialinformation of Opp Film Peru.In that sense, apart from protectingour interests, we must also exhibitan open and honest attituderegarding our business and results.

Travel and accommodation expensesand/or personal expenses for executivesor officials from other entities may becovered when their presence is requiredat a business activity or institutional event.Care must be taken to ensure that giftsbearing the logo of Opp Film Peru,Oben Holding Group or subsidiaries aresocially and legally permissible withinthe jurisdiction in which they are given.

No cash gifts may be offered.

Care must be taken to ensure that allexpenses associated with gifts arerecorded correctly, and that the truepurpose of such expenses is reflected.

SER HONESTOS Y TRANSPARENTES EN NUESTRAS OPERACIONES Y RESULTADOS


At Opp Film Peru we stronglyoppose corruption, bribery andmoney laundering. In this regard,we comply with domestic legislationagainst these challenges within thecountries or markets in which weoperate. In alignment with this aim,we have established a series ofguidelines designed to minimizethe risks associated with theseissues.

4.7.1 REGARDING THESERVICES AND GIFTSWE BESTOW

The lunches, gifts, trips and otherservices we bestow uponcustomers, suppliers and otherthird parties are permitted as longas they involve legitimate businessactivity and they are within theframework of approval limits.

Expenses associated withlunches and other services forinterest groups in order to maintainrelations are permitted as long asthe sums involved are within theframework for approval limits.

4.7.2 CONSIDERATIONS FORTHE TREATMENT OF PUBLICOFFICIALS

The decisions of the public sectorshould not be influenced, directly orindirectly, by granting or proposingthe granting of personal benefits topublic officials.

When a company of the ObenHolding Group wishes to hire apublic official (current or who hasbeen an official in the last two years)or a direct family member, HumanResources Management must makethe necessary efforts to ensure thatthe recruitment does not contravenelegal provisions.

4.7 FIGHT AGAINSTCORRUPTION,BRIBERY ANDMONEY LAUNDERING

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negotiate on behalf of or in favorof any Oben Holding Group company,you should consider:

All collaborators of Opp Film Perumust be committed to the pursuit oftheir activities within a framework ofsecurity, legality, and the guaranteeof transparency, in a manner whichprevents the entry of illegal moniesfor the purpose of legitimization.

Carrying out the selection withdue diligence, evaluating thereputation and integrity of theparty involved.

That participation with suppliers,agents and third parties is coveredby a prior written agreement.

That the written accord includescontractual agreements, so thatthe party involved expressly agreesto abide by the central tenets ofthe anti-corruption, bribery andmoney laundering guidelinesmaintained by Opp Film Peruand Oben Holding Group.

4.7.6 AGAINST MONEYLAUNDERING AND THEFINANCING OF TERRORISM


4.7.3 REGARDING THESERVICES AND GIFTSWE RECEIVE

Employees must avoid acceptingservices or gifts from third parties;if this is not possible, these mustmaintain a direct relationship,proportionality and appropriateness,in order to ensure maintenanceof a transparent relationship.

If it becomes necessary toaccept a service or gift consideredsignificant (and which generates aconflict of interest in the employee),this must be communicated toand validated by the GeneralManagement through theprocess established by theorganization.

4.7.4 DONATIONSOpp Film Peru can only makedonations to institutions, underno circumstances will donationsbe made or offered to therepresentatives of institutions.Also, every donation must beaccompanied by the correspondingdonation certificate.

4.7.5 CONTRACTING OFSUPPLIERS, AGENTS ANDTHIRD PARTIES

Prior to the selection of any supplier,agent and/or third party who may

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OF THE CODEADMINISTRATIONREGARDING

Our Code is public; we therefore encourage all collaboratorsto share it with their peers and to form part of its dissemination,in order to create a broader understanding of its content.

5.

5.1.1 REGARDING THEDELIVERY OF THE CODEAND CONFIRMATION OFITS RECEIPTAll current and future collaboratorsof Opp Film Peru will have accessto a copy of this Code throughtheir direct Supervisor or Manager,and they will be responsible forreading it and confirming that it hasbeen read and understood throughsubmission of the form“Commitment to Compliance withthe Code”, which must be dulysigned.

5.1.2 REGARDINGDISSEMINATION OFTHE CODEThis Code will be published in theintranet and other in-house mediaof Opp Film Peru.

All collaborators at all levels willmaintain an “open door” policyregarding queries concerning thisCode and its applicability. We

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expect all collaborators topresent their queries regardingany specific situation, no matterhow small and insignificant itmay seem.Each collaborator must remain alert to any work-related activitywhich might be interpreted as aninfraction of this Code. If you haveknowledge of or suspect a violationof this Code, your obligation is toreport it immediately. Your statementmay be oral or in writing, and if youprefer, it can be made anonymously.Several options are available whenmaking a statement.

Explain your concerns to yourOpp Film Peru direct Supervisoror Manager.

Explain your concerns tothe Opp Film Peru HumanResources Manager.

Explain your concerns to an ObenHolding Group In-House Director.

Explain your concernsanonymously through thechannels of the CorporateEthics Line (shown at theend of this document).

Any collaborator with the companieswithin the Group who violates this Codemay be subject to civil and/or criminalaction, as well as sanctions levied bytheir respective employer. It is importantto note that all collaborators of theGroup’s companies will be subject todisciplinary measures defined by theorganization which employs them,in accordance with local regulationsand applicable policies, and that suchdisciplinary measures may includedismissal.

More information is available in the“In-House Work Regulations” of therespective employers.

Updated versions of the Code willbe redistributed to all collaborators,and the activities outlined in section5.1 “Delivery and Dissemination ofthe Code” will be initiated.

5.1 DELIVERY ANDDISSEMINATION OFTHE CODE

5.2 RECEIPT OF COMPLAITS

5.3 SANCTIONSAPPLICABLE TO ANYFAILURE TO COMPLYWITH THIS CODE

5.4 UPDATING OFTHE CODE

Web: www.bdolineaetica.com/oben

:

WhatsApp:

976 32 64

0 626

ETHIC LINECORPORATE

Through these contact channels, you can reportviolations of the Ethics and Conduct Code,corporate policies and procedures, in a secure,anonymous and confidential manner.

Phone:

lineaeticao @ obdben . .com peEmail

Documents

CODE OF ETHICS AND CONDUCT - Oben Group€¦ · This Code of Ethics and Conduct defines our collective personality: an ongoing sense of duty and responsibility designed to maintain