Molymet and its subsidiaries have, as their purpose, that all activities are carried out, registered and monitored in accordance with a strict observance of the laws, policies, standards and procedures applicable, and in that regard, the staff should choose the path of the highest degree of integrity.
Ethical Behavior Values
As a result, the company considers it essential that, in the exercise of their functions, staff observes the following values of ethical behavior:
1.- The staff of the Company may not use their relationship with the company or confidential information obtained as a result of this relationship, for their personal benefit, or of any member of their family group or third parties.
Also, they may not, directly or indirectly, sell or lease, to the company, any kind of property, facilities, equipment, mineral resources, products or services.
2. The staff of the Company shall not, directly or indirectly, have any participation or receive benefits, services, profits or payment from any company or individual who has or is trying to obtain business dealings with Molymet or any of its subsidiaries.
This does not imply that the employee, their spouse and/or members of their family group may not invest in securities of publicly traded companies, even when they are related to Molymet or any of its subsidiaries.
In the event that an employee has the absolute need for the services, for a particular purpose, of any company or individual that has or is trying to obtain business dealings with Molymet or any of its subsidiaries, the employee shall report this fact to the Corporate Manager of Human Resources and Corporate Internal Auditor of Molymet, indicating the nature of the service, the cost and the support of the corresponding payment.
3. An employee may not approve or control contracts or other business activities between the Company and a direct member of their family group or with a company or individual in which a member of their immediate family has a decision responsibility. The review, approval or administrative control of these businesses, invoices or vouchers shall be sent to upper senior management.
4. An employee of the Company shall not, unless Molymet has required and authorized so, disclose to third parties any confidential data or information concerning the businesses of Molymet or any of its subsidiaries.
5. An employee of the company will not be able to use, for their particular benefit; information, staff, facilities, equipment, supplies or commercial relationships of Molymet or any of its subsidiaries.
6. An employee may not render services as an executive or as a consultant for any company or individual sharing, doing business or trying to do business with Molymet or any of its subsidiaries.
7. All applications developed, or the way in which an application is to be used in the Company, including, specifically, the software, network and communication equipment, security devices, computer programs, manuals, formulas, variables of calculation, business rules, source codes, designs and documentation, is the intellectual property of Molymet and constitutes "confidential information" to be used only within the Company, therefore it should not be copied, reproduced or distributed totally or partially.
8. The employee must maintain, in complete reserve, everything that reaches their knowledge directly or indirectly, either due to their functions or by correspondence, contracts, accounting books or reports on business, industrial activities, methods of preparation or any operation of the Company, regardless of its nature.
9. The staff of the Company shall not, directly or indirectly, accept invitations or gifts from customers and suppliers. Exceptionally, in order not to incur in discourtesy to them, accept gifts of low amounts may be accepted, for example during Christmas. However, such must be reported in writing to a superior, either Executive President, Vice President, Manager or Deputy Manager of the unit, in order to caution that the acceptance does not result in deterioration to the image, objectivity and impartiality of the Company.
A low amount gift is considered to be that which has a commercial value not exceeding three (3) U.F.
9.1 For the case of public employees, the delivery or reception of gifts is expressly forbidden, regardless of amount, in order to fully comply with la 20,393.
Exceptions to this Policy must be analyzed and recommended by the Vice President, Manager or Deputy Manager of the relevant unit, approved by Corporate Management Office of Human Resources and finally authorized by the Executive Presidency. Said exceptions must be established in writing and copies must be registered in the Personal Folder of the Employee involved.
Based on these values, we have declared the following Principles of Action:
1. We promote free competition. We do not accept violations to the current legislation. We comply with the laws, both internal as well as international affecting the business.
2. We have integrity in our business. Zero Tolerance to corruption and poor commercial practices.
3. We promote the principle of sustainability. We do not accept risk to health of persons or the environment.
4. We drive equality of opportunities in commercial transactions. We say no to the use of insider information in the stock exchange.
5. We do not accept falsehood, simulation or deception, in the registration of accounting information, reflected in our financial statements.
6. We do not accept discrimination and we promote just working conditions and equality of opportunity.
7. We protect the results of our efforts and respect legally acknowledge rights of third parties.
8. We separate corporate interests from personal interests to prevent conflicts of interest.
The hereby Policy is an integral part of the individual working agreement.
Board of Directors
The hereby Policy is applicable to the members of the Board of Directors of the Corporation.
Possible conflicts of interest shall be submitted to the knowledge of the Board of Directors in its next meeting.
Force of the Modification
The hereby modification will come into effect in March 5th, 2013.
John Graell M.
Chief Executive Officer CEO