Code of Ethics & Conduct
This Code of Ethics and Conduct describes in general terms the ethical principles that all employees must apply each time they act on behalf of the company, since EDVSA considers it important that the actions taken to obtain the results respect the company values and principles.
The Code complements, but does not replace, the legal, general standards and procedures already established by the company, or those that it may establish in the future.
The Code’s purpose is to establish principles and guidelines on the actions of its employees, as well as to communicate corporate principles and values in order to contribute to their continuous implementation through certain minimum standards of non-negotiable behavior.
We expect EDVSA’s values and principles to be reflected in all the activities carried out by direct company personnel or through contractors and associates.
All activities developed by EDVSA’s employees must be based on ethical values and basic action principles:
We maintain an impeccable behavior, necessarily aligned with respect, rectitude and honesty.
In our work we think, say and do in a congruent way; and we make our actions evident and traceable.
We carry out all our activities diligently to face our commitments, the company, society, and life and environment protection. We assume the consequences of our actions and decisions.
We seek to meet our customer requirements and achieve results in a timely manner, complying with established requirements and standards, using our resources efficiently and focusing on a continuous improvement and learning perspectives.
Every employee represents the company both outside and inside it, therefore, it is expected that their actions reflect the established values. All EDVSA’s employees are responsible for taking care of and ensuring the good company name, as well as complying with the commitments that it establishes, and maintaining a good image in front of clients, suppliers, subcontractors, investors and all external agents.
In EDVSA we value and protect our confidential information and respect third parties information. We must take the necessary precautions to ensure transparent information management.
All information generated, transmitted or stored by EDVSA that is not public knowledge, will be considered confidential and may not be disseminated unless expressly authorized. The information obtained in the company should not be used for personal benefit or third parties. All employees must keep confidential information secure and limit access only to those who need it to carry out their tasks.
In order to protect the company’s confidential information management, EDVSA applies and constantly updates the following documents (SEE APPENDIX):
- Guidelines and rules for managing confidential Information.
- IT guidelines and rules.
- Guidelines and rules for internal communication.
EDVSA respects the fact that third parties have the same interest in protecting their confidential information, as it is their property. In the event that third parties such as partners, suppliers or customers share confidential information with EDVSA, said information will receive the same care as the company’s own information receives.
The obligation to protect the information subsists once the employment relationship has ended. Upon termination of the employment relationship, it will not be possible to take or use EDVSA’s material that contains any type of confidential information.
LThe property rights of all knowledge developed in the work environment belong to EDVSA, which will be the one who retains the right to exploit it in the manner and at the time it deems most appropriate, in accordance with current national legislation.
The intellectual property ownership includes drawings, systems, procedures, methodologies, courses, reports, projections or any other activity developed in the company or by contracting it. It is the responsibility of all EDVSA’s employees to protect the improper use and disclosure of the aforementioned.
Respect y NO Discrimination
In EDVSA we must treat each other with respect, fostering a comfortable, healthy and safe work environment.
Therefore, you must:
- Avoid any offensive behavior or any type of discrimination on the grounds of race, religious, political or union beliefs, nationality, language, sex, marital status, age, disability or any other personal difference.
- Eliminate acts of harassment, abuse of authority, threats, pressure, moral harassment, offense or any other form of aggressiveness and hostility that might favour a climate of intimidation.
EDVSA, in all its areas of activity, is governed by compliance with the Corporate Policy (Sustainability Policy), the Argentine Legislation, as well as by compliance with high Safety, Health, Environment and Quality Standards in order to maintain workplaces safe, healthy and in harmony with the environment. EDVSA requires all its employees to share these objectives and comply with the Integrated Management System’s rules, procedures and standards as a condition of employment, including the guidelines and rules regarding:
- Vehicle driving
- Alcohol and drug prevention and control
- Stop tasks
ZERO TOLERANCE is defined to the prohibition of possession, consumption and development of tasks under the influence of alcohol or drugs within the working day (except consumption of some type of drug under medical prescription), in our facilities and in those of our clients or suppliers, being this a condition of employment. Regarding vehicle driving, it is required to comply with the ROAD SAFETY LEGISLATION and the defined requirements applicable to the activity and the company internal requirements (SEE APPENDIX).
EDVSA grants absolute authority, to its employees and contractors, to stop any activity that threatens safety, health or environment, or may affect the normal development of activities and operations.
Conflict of interests
A conflict of interest occurs when an employee’s personal interests or a third party’s interests compete with EDVSA’s interests.
Directors and employees must refrain from engaging in situations that could lead to a conflict between personal interests and those of the company, intervene or influence decision making in any situation that, directly or indirectly, has a personal interest. They must act always, in the fulfillment of their responsibilities, with loyalty and in defense of EDVSA’s interests.
All EDVSA’s employees must:
- Inform direct or indirect participations that they own, by themselves or through third parties and / or relatives, with supply companies, customers, competitors, EDVSA’s contractors and / or sub-contractors.
- Refrain from granting other companies, organizations or individuals, undue advantages in any business transaction and must remain impartial.
- Refrain from using the goods or information owned by EDVSA by virtue of its position in the company, for personal or third-party benefit or to compete with EDVSA.
If an employee faces a situation that may involve or lead to a Conflict of Interest, the employee must communicate it through the established channels (See point 6: Compliance).
Gifts and presents
It is important to exercise caution when accepting or making gifts, meals or any type of invitation to maintain trustworthy relationships with business partners, customers or other interested parties.
The giving and acceptance of gifts, presents or invitations that are made sporadically and that do not exceed USD 100 dollars or its equivalent in Argentine currency will be allowed.
Under no circumstances can money or similar goods be given or accepted, nor easily converted into money. EDVSA and its employees must ensure the timely dissemination of these criteria to their customers and suppliers.
All gifts, presents, invitations, expense coverage or attention above the aforementioned value must be returned and reported to the internal audit department.
Compliance with this Code of Ethics and Conduct (hereinafter the "Code of ethics and conduct" or the "Code") will be the exclusive and personal responsibility of each EDVSA’s employee. Once the application of the Code has been disseminated, the transgression will not be admissible, alleging ignorance or obedience to instructions received from a hierarchical superior.
All EDVSA’s employees are expected to adopt a proactive attitude towards possible violations, acting on their own initiative when incidents are detected in which the Code of ethics and conduct is not complied with.
Violation of this Code will result in the application of disciplinary sanctions that merit the facts in question, which may mean even termination of employment or contractual relationship, as the case may be, and lead to the legal actions that may correspond.
Situations that oppose this Code must be communicated to the Internal Audit area, which will be responsible for reviewing the complaints and assign, if applicable, the sanction determined with Human Resources. The cases that are more serious will be evaluated by the Senior Management, which will decide in that case the action to be taken.
Any complaint made to the ethical line will be kept confidential and will be investigated in an appropriate manner. This Code is mandatory for all EDVSA’s employees.
APPENDIX I - Guidelines and Rules for Managing Confidential Information
APPENDIX II - IT Guidelines and Rules
APPENDIX III - Guidelines and Rules for Internal Communication
APPENDIX IV - Guidelines and Rules for Vehicule driving
APPENDIX V - Guidelines and Rules for Alcohol and Drug Prevention and Control
APPENDIX VI - Guidelines to Stop Tasks