Purpose and Scope

The Polopiqué Group’s Code of Conduct is the document that includes a set of principles governing the activity of the Group’s companies and a set of rules of an ethical and deontological nature to be observed by the respective members of the Governing Bodies and by all Employees in their relations with Customers and Suppliers.It is also intended for third parties contracted by or acting on behalf of Polopiqué, in cases where the latter may be held responsible for their actions. As such, the Code is based on the following general principles that define our ethical behaviour:

• Our operations are carried out from an ethical and responsible perspective.
• Persons or entities that maintain, directly or indirectly, any type of employment, economic, social and/or industrial relationship with us are treated fairly and with dignity.
• Our activities are carried out with respect for the environment.
• All manufacturers and suppliers must fully comply with these commitments and undertake to ensure that the standards established in the Code are met.

1. FORCED LABOUR

The use of any form of servitude, forced, slave, trafficked or involuntary labour is not permitted. Employees may not be required to make any kind of “deposit”.

Employees’ identification documents will not be retained.

Employees may be absent from work or terminate employment contracts under the terms of the law. It is guaranteed that employees are not subjected to inhuman or degrading treatment, corporal punishment, mental or physical coercion and/or verbal abuse.

All forms of “modern slavery” are prohibited. No human trafficking for labour or any other purpose is permitted.

2. CHILD LABOUR

The direct or indirect use of child labour is not permitted. The minimum age for admission is 16 with the minimum compulsory schooling completed (with the exceptions provided for by law). Robust age verification mechanisms must be established as part of the recruitment process, which must not be degrading or disrespectful to the worker, in any way.

Special Protection for Young Employees – (under 18):

• Ensure that young people do not work at night and that they are protected against working conditions harmful to their health, safety, morals and development, without prejudice to the specific expectations set out in this principle.
• Ensure that the type of work is not harmful to their health or development; their working hours do not hinder their school attendance, their participation in vocational guidance approved by the competent authority, or their ability to benefit from training or instruction programs.

3. DISCRIMINATION

All employees are treated with dignity and respect.

No discriminatory behaviour shall be perpetrated or permitted in relation to employment practices, recruitment, remuneration, promotion, access to training and hiring on the basis of race, nationality, religion, disability, gender, age, marital status, sexual orientation, illness, political association or affiliation, or any other condition that may give rise to discrimination.

Employees must not be subject to illegal medical examinations as a condition of recruitment or employment.

4. FREEDOM OF ASSOCIATION

Respect for the right of workers to associate, organise or bargain collectively, in accordance with the law, is guaranteed. When national legislation restricts these rights, suppliers must adopt alternative means to facilitate employee representation.

5. DISCIPLINARY MEASURES, HARASSMENT AND ABUSE

Under no circumstances should the use of physical punishment, sexual/racial harassment, physical and psychological abuse and/or any other type of harassment/intimidation be permitted.

6. WORKING HOURS

Everyone must comply with the applicable legislation and the respective sector’s rules on working hours.

7. REMUNERATION

The national minimum wage must be guaranteed to all employees, as well as payment for overtime work under the legally defined terms. Respect the right of employees to receive fair and sufficient remuneration to provide a decent life for themselves and their families, as well as the social benefits legally granted. It is not permitted to make salary deductions other than those permitted by law. Wages must be paid monthly by the last day of the month.

8. EMPLOYEES

a) In carrying out their duties, Polopiqué Group employees must act in accordance with the principles of legality, good faith, responsibility, transparency, loyalty, professionalism and confidentiality.

b) Polopiqué Group employees must adopt a proactive attitude in the pursuit of excellence, seeking and sharing knowledge and information, cultivating team spirit, based on relationships of trust, respect for the hierarchical structure existing in the companies that make up the Group, and acting with integrity and dignity in their relationships with each other.

c) It is forbidden to obtain personal benefits, advantages or favours by virtue of the position held or duties performed by employees, and they may not negotiate on their own account or in competition with Group companies.

d) Polopiqué Group employees are prohibited from accepting gifts and/or any benefits for themselves, their family members or in favour of third parties, with the exception of those of symbolic value. Likewise, Polopiqué Group employees are prevented from offering, giving or receiving any gift or payment to third parties that is or could be considered bribery or any form of corruption.

e) Employees must avoid situations that could lead to a conflict of interest, by intervening in decision-making processes that directly or even indirectly involve entities with which they collaborate or have collaborated, or natural persons to whom they are or were linked by ties of kinship or affinity of any kind. If they are unable to do so, they must immediately report the existence of these relationships. In addition, they must refrain from exercising any functions outside the company, whenever such activities jeopardise the fulfilment of their duties.

f) Employees of the Polopiqué Group are subject to the duty of confidentiality regarding all information concerning the activity carried out by the companies that make up the group, except for information that is public knowledge or constitutes a notorious fact.

g) Failure to comply with the provisions of this clause shall constitute a serious offence, liable to disciplinary or other legally applicable sanctions, namely administrative, civil or criminal, and may eventually lead to the termination of existing contractual ties.

9. EMPLOYMENT PRACTICES

Each employee must have a copy of a written employment contract describing the terms of employment in the local language and in the language understood by the employee. All employees must be in a legal labour relationship.
The hiring of trainees must be conducted in accordance with the law and this Code. Apprenticeship/internship schemes must not be used to avoid paying wages and benefits. Ensure that its labour relations do not cause insecurity and social or economic vulnerability to employees; Work is carried out on the basis of a recognised and documented employment relationship, established in accordance with legislation, custom or practice and international labour standards, whichever provides greater protection. Business partners must not use employment agreements in a way that deliberately does not correspond to the genuine purpose of the law. This includes, but is not limited to, apprenticeship schemes where there is no intention to pass on skills or provide regular employment; seasonality or contingency labour when used to undermine the protection of Employees. Furthermore, the use of subcontracting must not serve to jeopardise employees’ rights.

10. SUBCONTRACTING

Our manufacturers and subcontractors may only carry out their production in factories or establishments expressly authorised by Polopiqué. The use of home-based labour must comply with applicable laws and regulations. Suppliers must require all subcontractors involved in operations related to the Polopiqué Group to comply with this Code of Conduct.

11. ETHICAL BEHAVIOUR

We guarantee respect for the rules of fair competition defined by the applicable legislation. Business partners must not engage in any act of corruption, extortion or embezzlement, nor in any form of bribery – including, but not limited to: promising, offering, giving or accepting any improper monetary or other incentive. This includes all kinds of deceptive business practices, protection money, tax evasion and money laundering. Dumping is expressly prohibited.

12. HEALTH AND SAFETY AT WORK

All employees are guaranteed a safe and healthy working environment, namely by complying with the legal and regulatory precepts applicable to this matter (building structure, interior, machinery, electrical equipment, and any chemical products used in the production process, etc.). Provide employees with regular training in health and safety at work. Promote good health and safety practices to prevent accidents and risks to employees’ health. Provide employees with effective Personal Protective Equipment (PPE) free of charge. All employees are guaranteed access to hygienic toilets and drinking water. Vulnerable individuals, such as – but not limited to – young employees, new and pregnant mothers, and people with disabilities, must receive special protection. Ensure that systems are in place to detect, assess, prevent and respond to possible threats to employees’ health and safety. Respect the right of employees to leave the premises in imminent danger without asking permission. Ensure adequate occupational health care and related facilities.

13. PRODUCT SAFETY

All products supplied and services rendered must fulfil the required requirements, so that the products marketed do not pose any risk to customers. Care must therefore be taken in selecting the chemicals used in the manufacture of products, complying with REACH, MRSL \ RSL requirements and adopting the ZDHC (Zero Discharge of Hazardous Chemicals) program, as well as all the requirements agreed with customers.

14. ENVIRONMENTAL PROTECTION

All manufacturing activity will be carried out with respect for the environment, in compliance with applicable legal and regulatory standards, adopting the necessary measures to reduce and compensate for its impact.
The supplier must fulfil all legally applicable environmental requirements and demonstrate continuous improvement in its environmental performance.
As a minimum, it must engage in activities to minimise its impact on the environment, its use of natural resources (including energy and water) and prevent or minimise possible environmental risks as a result of its operations. Adequately manage atmospheric emissions, waste water and the use and disposal of hazardous materials.

15. PRIVACY AND DATA PROTECTION

We guarantee that the personal data entrusted to us will be strictly used for the purposes for which it was collected and will not be communicated to third parties, except when there is a need for such transmission in the performance of a contractual relationship or in fulfilment of legal obligations. They will be kept for as long as necessary. We have created the conditions for the holders of personal data to be able, at any time and free of charge, to exercise their rights of access, rectification and, within the legal limits, erasure, opposition, limitation of processing and portability.

16. GOVERNING BODIES

The Governing Bodies of the Polopiqué Group companies will ensure that the measures necessary to comply with this Code of Conduct are implemented, assessing their sufficiency and appropriateness.

17. COMPLIANCE WITH APPLICABLE LAWS

Compliance with applicable legislation is guaranteed in all matters not covered in the previous points. If national regulations or any other applicable or assumed commitments, including collective labour agreements, govern the same issue, the provision offering the greatest protection to employees shall apply. Polopiqué assumes, within the scope of its internal rules, the content of the national and international agreements and conventions to which it has adhered, and which are applied in its relationship with suppliers, committing itself to their promotion and fulfilment.

18. MANAGEMENT SYSTEMS

Implement a grievance mechanism that allows all employees to confidentially communicate any concerns, without the risk of retaliation, to management and/or employee representatives.