The business philosophy of Nano Chemical Technologies LLC. ( "NCT" or " We" ) and its growth strategy in different markets around the world, has management and Corporate Governance schemes of the highest international standards; in addition to unrestricted compliance with the local and international regulatory framework, considering the reputation of “NCT” as one of the key factors based on loyalty, fairness, transparency, integrity and full respect for laws and regulations In this context, corruption represents an intolerable obstacle to business efficiency and to fair competition.
For these reasons, "NCT" has adopted, within its business principles and practices, policies aimed at structuring its operations within a framework of ethics and transparency that guarantee the continuity and sustainability of business, also seeking to safeguard the reputational capital of the organizations and contributing and impacting positively to the communities in which they operate, as well as other stakeholders .
We understand that, in the way we do business, we put institutional principles and values before the achievement of corporate objectives
The "NCT" Ethics, Anti-Corruption and Anti - Bribery Policy , based on, but not limited to, the OECD Convention on Combating Bribery of Foreign Officials in International Business Transactions; US Foreign Corrupt Practices Act of 1977; UK Bribery Act 2010 ; and equivalent relevant lists of restricted persons by other relevant jurisdictions , its purpose is to publicly declare its commitment to acting ethically and transparently before its stakeholders and conducting its business in a socially responsible manner, acting with a philosophy of "zero tolerance ”To acts that contradict its organizational principles.
This policy is applicable to all employees of Nano Chemical Technologies LLC. , partners, shareholders, commercial representatives, allies, as well as all related parties and interest groups , understood as: clients, suppliers, shareholders, investors, allies, contractors, subcontractors; and in general to all those with whom a commercial, contractual or cooperation relationship is established directly or indirectly.
Guiding Principles
The central axis of this policy expresses the guidelines that must be applied in the company and those that carry out operations directly or indirectly.
These principles presuppose the condition of integrity that all our collaborators have as ethical citizens. The application of these principles will not be discretionary, nor will it admit interpretations that give or seek to give the appearance of legality to acts or situations about which there are clearly reasonable doubts about their relevance and legality.
In the event of doubts about its application, the governing bodies of the policy that are set out later in this document should be consulted.
These guiding principles are as follows:
Consistency : All collaborators, regardless of rank or hierarchical position in the Organization, are referents of an act in accordance with our condition as exemplary citizens; as well as institutional principles and practices and setting an example with our behavior. No collaborator may directly or indirectly participate, hide or sponsor acts of corruption or bribery, either to public or private entities, both local and foreign.
Commitment to prevention : the commitment to preventing ethical anti-corruption and anti-bribery practices, considering that anti-corruption laws: prohibit payments made either directly or indirectly - including those payments made to anyone with the knowledge that said payment will be shared with a Public Official or with a private one - as well as the offers or promises of a payment or other utility for corruption purposes to Public or private Officials.
Responsibility: Any event reported or detected that has some kind of relationship with corrupt , unethical or bribery practices, either with public or private entities, will be carefully investigated, documented and analyzed within the organization.
Those situations that effectively correspond to acts of corruption or bribery will be sanctioned; regardless of the amount, characteristic or hierarchical position of those responsible, keeping proportionality with the facts and guaranteeing due process.
The response of Nano Chemical Technologies LLC to this type of situation will imply the administrative sanctions that may arise and will transfer to the competent authorities for those of a commercial, civil and criminal nature, accompanying the respective processes by the legal representatives of the companies. .
Transparency and legality: All the facts or circumstances that are detected and verified will be reported in accordance with the protocols established in front of the different interest groups and always respecting the official spokespersons of the companies for these matters, guaranteeing transparency, legality and informative balance . On the Anti-Corruption and Anti-Bribery Ethics Policy .
Fundamental Provisions
Nano Chemical Technologies LLC ("NCT" or We ") has a Code of Conduct and Corporate Ethics, and Anti-Corruption and Money Laundering Prevention policies, which seek, above all, to: i) guide the conduct of all employee partners, shareholders , commercial representatives, allies, as well as all related parties and interest groups, understood as: clients, suppliers, shareholders, investors, allies, contractors, subcontractors; and in general to all those with whom a commercial, contractual or cooperation relationship is established directly or indirectly. ii) Maintain adequate internal controls; iii) Have appropriate records and reports of all transactions; and iv) comply with the pertinent laws. Reading implies your unconditional adherence to the aforementioned documents.
The worker partners, shareholders, commercial representatives, allies, as well as all related parties and interest groups, understood as: clients, suppliers, shareholders, investors, allies, contractors, subcontractors; and in general all those who directly or indirectly is a commercial, contractual or cooperative relationship established declares n, guarantees n and forces are n to each of its owners, directors, officers, employees and anyone else who act on their behalf, in relation to the transactions contemplated in the Ethics, Anti-Corruption and Anti-Bribery Policy , carry out , offer , or promise to carry out, nor will make, offer or promise to make or authorize any payment or other transfer of anything of value including without limitation, any part of compensation or reimbursements received gift or entret eni any lie, directly or indirectly: i) any government official, including but not limited to mayors, governors, office secretaries, directors; ii) any officer or employee of Nano Chemical Technologies LLC ("NCT" or We ") or any of its affiliates, including but not limited to : President, Vice Presidents, Directors, Managers, Leaders; iii) no political party, official of a political party or candidate for political office; iv) an agent or intermediary for the payment of any of the above; or v) no other person or entity, for the purpose of obtaining or influencing official actions or decisions or securing an undue advantage in order to obtain or retain business, or to engage in acts or transactions that otherwise violate or are inconsistent with the principles of any applicable anti-corruption laws, including, but not limited to, anti-corruption laws.
For the purposes of the ethics, anti-corruption and anti-bribery manual, the term "government official" is understood to include any minister, minister in charge, manager, director, official or employee of the national, departmental or municipal government, or a company in which this government is the owner. of a majority stake or of CONTROL, and / or of any international public organization. This term also includes any police or military personnel and any person acting in an official, administrative or judicial capacity for or on behalf of the government or international public department, agency, body, company or organization.
. Employees Nano Chemical Technologies LLC, partners, shareholders, business representatives, allies , as well as all related parties and interest groups, understood as customers, suppliers, shareholders, investors, partners, contractors, subcontractors; and in general all those who directly or indirectly is a commercial, contractual or cooperative relationship established is obliged n in relation to the Policy d and Ethics, Anti - Corruption and Bribery , each subordinate apply effective controls and disclosure procedures; keep and maintain adequate and precise books, records and accounts that, in reasonable detail, accurately and fairly reflect any and all payments made, expenses incurred and assets that have been disposed of; and that it has and will maintain a system of internal accounting controls that is sufficient to ensure the proper authorization, registration and reporting of all transactions and to provide reasonable guarantees in the sense that violations of anti-corruption laws will be prevented, detected and prevented. of applicable jurisdictions.
PREVENTION OF MONEY LAUNDERING AND TERRORISM FINANCING.
The employees of Nano Chemical Technologies LLC., Partners, shareholders, commercial representatives, allies, as well as all related parties and interest groups, understood as: clients, suppliers, shareholders, investors, allies, contractors, subcontractors; and in general all those with whom so directly or indirectly is a business relationship, contractual or cooperation stipulates, explicitly states n and guarantees No funds or assets received or provided by or to Nano Chemical Technologies LLC ( "NCT" or Us ") regarding Policy Prevention d e Laundering d e Assets and Financing d Terrorism. , will not be transferred to / or from any Restricted Person or against applicable laws, including, but not limited to, laws, rules or regulations against money laundering or against corruption.
It is the obligation of the employees of Nano Chemical Technologies LLC., Partners, shareholders, commercial representatives, allies, as well as all related parties and interest groups, understood as: clients, suppliers, shareholders, investors, allies, contractors, subcontractors ; and in general to all those with whom a commercial, contractual or cooperative relationship is established directly or indirectly, not to make payments or transfers of things of value that have the effect or purpose of being a public or commercial bribe, any form of financing of terrorism or illegal armed group, money laundering, or other improper means to obtain or retain business. For the purposes of this clause, a "RESTRICTED PERSON" is a person identified from time to time by any governmental or legal authority under applicable trade sanctions, export controls, laws against money laundering, against non-proliferation, anti-terrorism and similar laws (collectively the "Trade Restrictions") as the person with whom it is prohibited or restricted for Nano Chemical Technologies LLC ("NCT" or We ") or its affiliates to conduct commercial or financial business and transactions, including, but not limited to a: i) OECD Convention on Combating Bribery of Foreign Officials in International Business Transactions; ii) US Foreign Corrupt Practices Act of 1977; iii) UK Bribery Act 2010; and iv) equivalent relevant lists of restricted persons by other relevant jurisdictions.
Nano Chemical Technologies LLC ( "NCT" or we ") states that: i) is qualified and competent to perform and fulfill their duties under the Policy d and Ethics, Anti - Corruption and Anti - Bribery and Policy Prevention d e Laundering d e Assets and Financing of Terrorism that, to the extent required by law, regulation or applicable administrative requirement, "NCT" has obtained the licenses or fulfilled the records that are necessary or required to fulfill its duties as contemplated in the Anti-corruption Laws ; ii) Except as otherwise stated in writing to Nano Chemical Technologies LLC ("NCT" or We ") as of the date of subscription of this manual and during the term of this manual , no" government official "is or will be associated with , will either own or currently have an interest, direct or indirect , or have or will have legal, financial interest or existing or entered profit or payments to be made by Nano Chemical Technologies LLC (“NCT” or We ”) under this document; and iii) Nano Chemical Technologies LLC (“NCT” or We ”) is not aware of or has reason to suspect that: a) the product, funds or goods that are the subject of transactions involving the employees of Nano Chemical Technologies LLC., partners , shareholders, commercial representatives, allies, as well as all related parties and interest groups, understood as: clients, suppliers, shareholders, investors, allies, contractors, subcontractors; and in general to all those with whom a commercial, contractual or cooperative relationship is established directly or indirectly, are or will be derived from, or are related to illegal activities under the applicable laws; and b) the products, funds or goods that are or will be the object of said transactions are not intended to compromise, sponsor or sponsor a violation of applicable law, including but not limited to violations of tax, customs, income or anti-terrorism laws. In the event that "NCT" has any basis to presume in good faith that the employees of Nano Chemical Technologies LLC., Partners, shareholders, commercial representatives, allies, as well as all related parties and interest groups, understood as : clients, suppliers, shareholders, investors, allies, contractors, subcontractors; and in general to all those with whom a commercial, contractual or cooperative relationship is established directly or indirectly, the commitments and / or requirements established in the Code of Conduct and Corporate Ethics Policy , Nano Chemical Technologies LLC (“ NCT "or We") will inform you in writing and you must fully cooperate with any and all requests made by or on behalf of Nano Chemical Technologies LLC ("NCT" or We ") in connection therewith, including the provision of personnel and documents and supporting statements that Nano Chemical Technologies LLC ("NCT" or We ") deems reasonably necessary.
Without prejudice to any rights or remedies you may have Nano Chemical Technologies LLC ( "NCT" or we ") under the Policy d and Ethics, Anti - Corruption and Anti - Bribery Policy and Prevention d e Laundering d e Assets and Financing d Terrorism , as applicable, the right to compensation for damages for breach of the Policy d and Ethics, Anti - Corruption and Anti - Bribery Policy and Prevention d e Laundering d e Assets and Financing d Terrorism , Nano Chemical Technologies LLC ( "NCT" or we " ) will have the right to terminate any relationship that involves Nano Chemical Technologies LLC. employees, partners, shareholders, commercial representatives, allies, as well as all related parties and interest groups, understood as: customers, suppliers, shareholders, investors, allies, contractors, subcontractors; and in general to all those with whom, directly or indirectly, a commercial, contractual or cooperative relationship is established with immediate effect in the event that it reasonably considers that any of the agreements, commitments, declarations and guarantees, affirmations or requirements established in this clause have not been fulfilled .
The employees of Nano Chemical Technologies LLC., Partners, shareholders, commercial representatives, allies, as well as all related parties and interest groups, understood as: clients, suppliers, shareholders, investors, allies, contractors, subcontractors; and in general all those who directly or indirectly is a commercial, contractual or cooperative relationship established agrees n and undertakes that, in connection with the implementation of the policy d and Ethics, Anti - Corruption and Anti - Bribery and Policy prevention d e Laundering d e Assets and Financing d Terrorism , act in a manner consistent with applicable principles of the Code of Ethics and Conduct of Nano Chemical Technologies LLC , which acknowledges also employees Nano Chemical Technologies LLC., partners, shareholders, commercial representatives, allies, as well as all related parties and interest groups, understood as: clients, suppliers, shareholders, investors, allies, contractors, subcontractors; and in general all those who directly or indirectly is a commercial, contractual or cooperative relationship established forces are n to communicate to Nano Chemical Technologies LLC ( "NCT" or we ") as soon as it becomes aware of any information or event that implies a deviation to the precepts included in this clause as in the aforementioned Code of Conduct and Corporate Ethics to the means provided , Nano Chemical Technologies LLC makes available to all interest groups, different channels to access the ethical line, such as: - - Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Failure of Policy d and Ethics, Anti - Corruption and Anti - Bribery Policy and Prevention d e Laundering d e Assets and Financing d Terrorism constitutes a serious breach and may be considered as grounds for termination d and relationship with employees of Nano Chemical Technologies LLC., Shareholders, commercial representatives, allies, as well as all related parties and interest groups, understood as: clients, suppliers, shareholders, investors, allies, contractors, subcontractors; and in general to all those with whom, directly or indirectly, a commercial, contractual or cooperative relationship is established under the conditions indicated in the Termination clause.
The above obligations extend to the employees of Nano Chemical Technologies LLC., Shareholders, commercial representatives, allies, as well as all related parties and interest groups, understood as: clients, suppliers, shareholders, investors, allies, contractors, subcontractors; and in general to all those with whom a commercial, contractual or cooperative relationship is established directly or indirectly , and Nano Chemical Technologies LLC is obliged to include the policy and this clause in the Projects it enters into with its Subcontractors.
Update January 2021