The Code of Ethics in the Synthesia Group

1) About us

In the SYNTHESIA GROUP we are dedicated to the production and sale of polyurethane systems, saturated polyesters and resins. In order to consolidate our presence and leadership in the market, we are strongly committed to the promotion of research and development. This allows us to differentiate ourselves and provide solutions to the individual needs of our clients. Because we care about their results: their goals are our challenges..

Our objective is to be a leader in manufacturing and sales through the excellence of our products, permanently exceeding the expectations of both customers and suppliers, and adding value in a sustained way to our employees and shareholders.

In particular, our MISSION is:

  • To provide suitable chemical solutions adapted to our customers’ and users’ needs, together with our target markets’ needs, resulting in a high competitive value, committed to excellence and corporate social responsibility.

TheVISION of the SYNTHESIA GROUP is:

  • To be recognized as a leading reference nationally and internationally in our sector, standing out for innovation, quality and high performance of our products by providing industrial and technological solutions with the objective of achieving the maximum value, preserving the differential feature of an independent company.

The VALUES that guide our behaviours and identify us are:

  • Flexibility: we have the capacity to adapt to the requirements of the interested parties and, therefore, we work to satisfy their needs and expectations.
  • Excellence: we anticipate the look-out for the best solutions and the efficiency applied to our results.
  • Sustainability: we apply the best available technological improvements towards environmental, economic and social sustainability.
  • Honesty: we act with truthfulness in the fulfilment of our work and we promote the transparency of the information along the supply chain.
  • Safety and Health: we are committed to the safety and health of all people and professionals, as well as to their quality of life.
  • Responsibility: we are a responsible company and we comply with the legislation that applies to us in the different policy areas, as well as the commitments agreed with the interested parties.



2) Purpose of the Code

The Code of Ethics defines the standards and responsible behaviours that all people related to the SYNTHESIA GROUP must comply with and must put into practice. We are all responsible for the compliance with these guidelines, essential directives meant to ensure our management system.

The Code has been designed as a guide to facilitate the correct decision against common situations in daily management in the SYNTHESIA GROUP.

The Code of Ethics presents the standard operating procedures in relation to:

  • Our team.
  • Our environment.
  • Our business.

Failure to comply with this Code may result in disciplinary action.

3) Scope and entry into force

The Ethical Code applies to the employees of the GROUP, regardless of their function, position or hierarchical level, and establishes the frame of reference for the behaviours aligned with the Mission, Vision and Values of the SYNTHESIA GROUP.

In the case of business activities related to third parties, we must ensure that they acquaint and accept our Code of Ethics and are committed to complying with its principles as a basic element of our business relationship.

In conclusion, what is expected from us?

  • To acquaint the content of the Code.
  • To encourage and raise awareness about the described standards.
  • To comply with the values and act accordingly as described therein.
  • To extend the Code to our partners.

This document has been approved by the Board of Directors of SYNTHESIA ESPAÑOLA, S.A., being applicable from the moment of the communication, for all the companies from the SYNTHESIA GROUP. Any modification of the current content will require the approval of the Executive Board.

The application of the Code implies the compliance with the legislation in force in each of the different countries where the companies of the GROUP carry out their activity.

The Company reserves the right to exercise the appropriate legal measures in case of any infringement of the law, of this Code and of other applicable policies in the GROUP.

4) Our team

Respect

We contribute to create a fair, respectful environment, free of any type of harassment, physical, psychological, sexual or moral, or discrimination based on ideology, religion or belief, race, gender, sexual orientation, disability, political opinion, marital status or any other legally protected condition.

In the SYNTHESIA GROUP we respect the right to join any legally recognized workers' association, supporting the exercise of the trade-union freedom and the right to strike.

Motivation

We are committed to equal and fair treatment and, for this reason, we hire, remunerate, train and enhance the professional development of people based on work performance, according to their knowledge and skills.

It will be our responsibility to stimulate and motivate the different work teams, basing professional relationships on equity, support and mutual trust.

Healthy and safe work environment

We promote and demand the compliance of the rules and procedures established in matters of quality, environment, safety and health and prevention of serious accidents in the GROUP, as well as the correct use of facilities and materials, along with a prudent and responsible behaviour. Likewise, we require the subcontracted companies to respect the internal laws and regulations and to contribute to the creation of a safe and efficient working environment.

We must all know and comply with the rules of health and safety protection at work, and ensure our own safety and that of all persons who may be affected by the development of any activity.

Honesty

We avoid situations in which personal, labour, economic or financial interests may be or may appear to be in conflict with the fulfilment of the duties and functions of our roles within the company.

We do not establish relationships with clients and / or suppliers that could question the professional independence and objectivity, nor do we express attitudes that imply an abuse of power in order to prejudice or benefit a third party linked to the business.

Accordingly, we must not accept, nor of course request, any gift or invitation from suppliers or clients that may raise doubts about our personal integrity or about the independence of the SYNTHESIA GROUP. Therefore, we only accept them if they are occasional and of symbolic value and do not entail any doubt about our present and future behavior.

Confidentiality

We comply with the current legislation on confidentiality and data protection of employees, customers, suppliers and other partners. Therefore, we request and use only those data that are necessary for the management of the GROUP's activities and for the purpose for which they were provided.

We communicate any doubt or uncertainty about the use and treatment of confidential data and information.

5) Our environment

  • Environmental responsibility

In the SYNTHESIA GROUP we ensure the control and the correct management of the environmental aspects linked to our day-to-day operations, and we have up-to-date discharge, waste disposal and wastewater management systems.

In case of handling or using any toxic, corrosive, explosive or flammable substance, we strive to know and evaluate the effects of it in order to determine and take the necessary precautions that are supposed to surround such activities.

We safeguard the land and the property of landscape value, of ecological, historical or of special protection complying with the legislation in force in any construction and building work.

We ensure that in the emergency action plans, in case of any given situation, the environmental emergencies, as well as the limitation of the environmental damage are considered.

Likewise, we ensure compliance with the current environmental regulations by our suppliers or our external partners.

  • Transparency

We take the necessary measures to ensure the compliance with the current legislation and in particular, the legislation on the Prevention of Serious Accidents, Labour Risk Prevention, Product Safety, Industrial Safety and Environmental Protection.

We refrain from any practice that violates the commitment to clearly and accurately reflect the GROUP's financial statements, records, transactions and accounts, and we will pay particular attention to the reliability of the information entered in our computer systems.

We have a documented information management system to ensure that the records and other documentation containing essential data for the performance of the GROUP are kept, stored and, at an appropriate time, destroyed in accordance with the Organic Law of Protection of Data in force.

In addition, we comply with our fiscal and tax obligations to the Public Treasury and Social Security. Likewise, in the SYNTHESIA GROUP we are committed to cooperate with any internal or external investigation or audit that is carried out, and in the event of denunciation or in view of the intervention of the public authorities, we are committed to provide the legally required information and to maintain an attitude of collaboration and support to the competent authorities.

  • Reputation

All employees should take utmost care in preserving the image and the reputation of the SYNTHESIA GROUP in all their professional activities. They will also monitor the respect for the image and reputation of the SYNTHESIA GROUP, from customers’, suppliers’ and, in general, from collaborating companies’ side.

Consequently, the name, brand, logos or other corporate symbolism cannot be used, in any case, for personal reasons or interests.

6) Our business

  • Integrity. Zero Tolerance to Corruption

In the SYNTHESIA GROUP we condemn bribery and any form of corruption. In no case will we resort to illegal or unethical practices to influence the will of people outside the SYNTHESIA GROUP with the objective of obtaining some benefit for the Company or for ourselves.

All employees who participate in selection processes that concern suppliers and external collaborators including ourselves, have the obligation to act with impartiality and objectivity, applying transparent criteria aligned with the principles of this Code.

In particular, non-contractual or unlawful payments are expressly prohibited to any person or entity, public or private, with the intention of obtaining or maintaining business, other benefits or advantages.

We record any price offered or any payment made, so we are committed to ensuring that the accounting ledgers and records contain the correct and accurate information.

We only establish commercial relations with people according to their professional competence and we ensure the legal origin of the money managed. We must detect the relationships and commercial transactions that put the SYNTHESIA GROUP at risk. For this reason, we will correctly identify any natural or legal person with whom any type of transaction is to be established.

Special attention is paid to transactions involving places identified as tax havens or known for money laundering or terrorist financing activities.

Likewise, in the SYNTHESIA GROUP we are independent of any political ideology, therefore, with our funds, we do not finance any political party nor trade union organization.

Employees who wish to make donations or sponsorships on behalf of the SYNTHESIA GROUP must first receive the approval of the corresponding Governing Boards.

  • Commitment

We take the necessary measures to ensure that any information related to the operations and business of the SYNTHESIA GROUP is protected and stored in a safe place, irrespective of its format. We are obligated to protect confidential information, as well as industrial and commercial secrets belonging to the SYNTHESIA GROUP and to our partner companies.

We respect the patented and confidential information of others, in the same way that we protect ours. In this line, we ensure that confidentiality agreements have been signed with third parties, with whom we share confidential information.

We undertake not to perform commercial espionage or covert surveillance of the competition.

  • Care for the assets

We have an obligation to ensure that the assets and resources that the SYNTHESIA GROUP makes available to us for business and professional purposes are used in a suitable and appropriate manner. We must protect and preserve them from any loss, damage, theft or improper use, that could result in detriment to the interests of the companies that are part of the SYNTHESIA GROUP. The obligation to protect the resources also includes the information and knowledge generated within the SYNTHESIA GROUP, owned or held by the GROUP.

We do not use information systems or communications devices for any unlawful, disruptive or obscene acts that could lead to loss or damage to them (e.g. malicious software download), nor do we use unauthorized devices as personal devices, to store data and information of the SYNTHESIA GROUP.

  • Consumer Protection

In the SYNTHESIA GROUP we are committed to free competition and compliance with the laws established in this regard in the different countries where we carry out activities, avoiding any action that involves an abuse or unfair restriction of the competition.

Likewise, we always act with responsibility and with the utmost respect to the client. Any commercial communication is governed by the principle of truthfulness.

The safety of our products is always a priority, above our economic interests or of any other type. Therefore, we pay special attention to the organization's key processes, providing them with the appropriate resources.

We are committed to combating drug trafficking by establishing specific systems for controlling stockpiles.

7) Acceptance

On behalf of the SYNTHESIA GROUP we will communicate and disseminate the current Code of Ethics among all our employees and collaborators, who must expressly accept the entire content of the Code and ensure its compliance.

8) How should I proceed in case of doubts or detection of non-compliances?

It is the responsibility of the employees and collaborators to acquaint and apply the internal policies and regulations. To this effect, the SYNTHESIA GROUP makes available all the necessary means to comply with and ensure compliance of the guidelines contained in both this Code and other internal policies communicated and implemented.

In particular, in the SYNTHESIA GROUP we have a Complaints Channel at the email addressbuzondenuncias@synthesia.com through which any irregularity, breach or behaviour contrary to ethics, legality and the rules that govern our GROUP can be expressed, with the maximum guarantees of security and confidentiality, although the aforementioned communication process cannot be anonymous.

The Chief Compliance Officer, a member of the Ethics Committee, will be responsible for receiving your communication and for coordinating the thorough analysis of any data or related information.

We are committed to providing sufficient guarantees to preserve the privacy of the person contacting us through the Complaints Channel and we guarantee that no employee will be aggrieved by the communication of a possible non-compliance.

<h2>1) About us</h2>

<p>In the SYNTHESIA GROUP we are dedicated to the production and sale of polyurethane systems, saturated polyesters and resins. In order to consolidate our presence and leadership in the market, we are strongly committed to the promotion of research and development. This allows us to differentiate ourselves and provide solutions to the individual needs of our clients. Because we care about their results: their goals are our challenges..</p>

<p>Our objective is to be a leader in manufacturing and sales through the excellence of our products, permanently exceeding the expectations of both customers and suppliers, and adding value in a sustained way to our employees and shareholders.</p>

<p>In particular, our <b>MISSION</b> is:</p>

<ul>
<li>To provide suitable chemical solutions adapted to our customers’ and users’ needs, together with our target markets’ needs, resulting in a high competitive value, committed to excellence and corporate social responsibility.</li>
</ul>

<p>The<b>VISION</b> of the SYNTHESIA GROUP is:</p>

<ul>
<li>To be recognized as a leading reference nationally and internationally in our sector, standing out for innovation, quality and high performance of our products by providing industrial and technological solutions with the objective of achieving the maximum value, preserving the differential feature of an independent company.</li>
</ul>

<p>The <b>VALUES </b> that guide our behaviours and identify us are:</p>

<ul>
<li><b>Flexibility: </b> we have the capacity to adapt to the requirements of the interested parties and, therefore, we work to satisfy their needs and expectations.</li>
<li><b>Excellence: </b> we anticipate the look-out for the best solutions and the efficiency applied to our results.</li>
<li><b>Sustainability: </b> we apply the best available technological improvements towards environmental, economic and social sustainability.</li>
<li><b>Honesty: </b> we act with truthfulness in the fulfilment of our work and we promote the transparency of the information along the supply chain.
</li>
<li><b>Safety and Health: </b> we are committed to the safety and health of all people and professionals, as well as to their quality of life.</li>
<li><b>Responsibility: </b>we are a responsible company and we comply with the legislation that applies to us in the different policy areas, as well as the commitments agreed with the interested parties.</li>
</ul>

<br/>
<br/>
<br/>

<h2>2) Purpose of the Code</h2>

<p>The Code of Ethics defines the standards and responsible behaviours that all people related to the SYNTHESIA GROUP must comply with and must put into practice. We are all responsible for the compliance with these guidelines, essential directives meant to ensure our management system.</p>

<p>The Code has been designed as a guide to facilitate the correct decision against common situations in daily management in the SYNTHESIA GROUP.</p>

<p>The Code of Ethics presents the standard operating procedures in relation to:</p>

<ul>
<li>Our team.</li>
<li>Our environment.</li>
<li>Our business.</li>
</ul>

<p>Failure to comply with this Code may result in disciplinary action. </p>

<h2>3) Scope and entry into force</h2>

<p>The Ethical Code applies to the employees of the GROUP, regardless of their function, position or hierarchical level, and establishes the frame of reference for the behaviours aligned with the Mission, Vision and Values of the SYNTHESIA GROUP.</p>

<p>In the case of business activities related to third parties, we must ensure that they acquaint and accept our Code of Ethics and are committed to complying with its principles as a basic element of our business relationship.</p>

<p>In conclusion, what is expected from us?</p>

<ul>
<li>To acquaint the content of the Code.</li>
<li>To encourage and raise awareness about the described standards.</li>
<li>To comply with the values and act accordingly as described therein.</li>
<li>To extend the Code to our partners.</li>
</ul>

<p>This document has been approved by the Board of Directors of SYNTHESIA ESPAÑOLA, S.A., being applicable from the moment of the communication, for all the companies from the SYNTHESIA GROUP. Any modification of the current content will require the approval of the Executive Board.</p>

<p>The application of the Code implies the compliance with the legislation in force in each of the different countries where the companies of the GROUP carry out their activity.</p>

<p>The Company reserves the right to exercise the appropriate legal measures in case of any infringement of the law, of this Code and of other applicable policies in the GROUP.</p>

<h2>4) Our team</h2>

<p><b>Respect</b></p>

<p>We contribute to create a fair, respectful environment, free of any type of harassment, physical, psychological, sexual or moral, or discrimination based on ideology, religion or belief, race, gender, sexual orientation, disability, political opinion, marital status or any other legally protected condition.</p>

<p>In the SYNTHESIA GROUP we respect the right to join any legally recognized workers' association, supporting the exercise of the trade-union freedom and the right to strike.</p>

<p><b>Motivation</b></p>

<p>We are committed to equal and fair treatment and, for this reason, we hire, remunerate, train and enhance the professional development of people based on work performance, according to their knowledge and skills.</p>
 
<p>It will be our responsibility to stimulate and motivate the different work teams, basing professional relationships on equity, support and mutual trust.</p>

<p><b>Healthy and safe work environment</b></p>

<p>We promote and demand the compliance of the rules and procedures established in matters of quality, environment, safety and health and prevention of serious accidents in the GROUP, as well as the correct use of facilities and materials, along with a prudent and responsible behaviour. Likewise, we require the subcontracted companies to respect the internal laws and regulations and to contribute to the creation of a safe and efficient working environment.</p>

<p>We must all know and comply with the rules of health and safety protection at work, and ensure our own safety and that of all persons who may be affected by the development of any activity.</p>

<p><b>Honesty</b></p>

<p>We avoid situations in which personal, labour, economic or financial interests may be or may appear to be in conflict with the fulfilment of the duties and functions of our roles within the company.</p>

<p>We do not establish relationships with clients and / or suppliers that could question the professional independence and objectivity, nor do we express attitudes that imply an abuse of power in order to prejudice or benefit a third party linked to the business.</p>

<p>Accordingly, we must not accept, nor of course request, any gift or invitation from suppliers or clients that may raise doubts about our personal integrity or about the independence of the SYNTHESIA GROUP. Therefore, we only accept them if they are occasional and of symbolic value and do not entail any doubt about our present and future behavior.</p>

<p><b>Confidentiality</b></p>	

<p>We comply with the current legislation on confidentiality and data protection of employees, customers, suppliers and other partners. Therefore, we request and use only those data that are necessary for the management of the GROUP's activities and for the purpose for which they were provided.</p>

<p>We communicate any doubt or uncertainty about the use and treatment of confidential data and information.</p>

<h2>5) Our environment</h2>

<ul>
<li><b>Environmental responsibility</b></li>
</ul>	

<p>In the SYNTHESIA GROUP we ensure the control and the correct management of the environmental aspects linked to our day-to-day operations, and we have up-to-date discharge, waste disposal and wastewater management systems.</p>
<p>In case of handling or using any toxic, corrosive, explosive or flammable substance, we strive to know and evaluate the effects of it in order to determine and take the necessary precautions that are supposed to surround such activities.</p>
<p>We safeguard the land and the property of landscape value, of ecological, historical or of special protection complying with the legislation in force in any construction and building work.</p>
<p>We ensure that in the emergency action plans, in case of any given situation, the environmental emergencies, as well as the limitation of the environmental damage are considered.</p>
<p>Likewise, we ensure compliance with the current environmental regulations by our suppliers or our external partners.</p>
<ul>
<li><b>Transparency</b></li>
</ul>	
<p>We take the necessary measures to ensure the compliance with the current legislation and in particular, the legislation on the Prevention of Serious Accidents, Labour Risk Prevention, Product Safety, Industrial Safety and Environmental Protection.</p>
<p>We refrain from any practice that violates the commitment to clearly and accurately reflect the GROUP's financial statements, records, transactions and accounts, and we will pay particular attention to the reliability of the information entered in our computer systems.</p>
<p>We have a documented information management system to ensure that the records and other documentation containing essential data for the performance of the GROUP are kept, stored and, at an appropriate time, destroyed in accordance with the Organic Law of Protection of Data in force.</p>
<p>In addition, we comply with our fiscal and tax obligations to the Public Treasury and Social Security. Likewise, in the SYNTHESIA GROUP we are committed to cooperate with any internal or external investigation or audit that is carried out, and in the event of denunciation or in view of the intervention of the public authorities, we are committed to provide the legally required information and to maintain an attitude of collaboration and support to the competent authorities.</p>

<ul>
<li><b>Reputation</b></li>
</ul>	

<p>All employees should take utmost care in preserving the image and the reputation of the SYNTHESIA GROUP in all their professional activities. They will also monitor the respect for the image and reputation of the SYNTHESIA GROUP, from customers’, suppliers’ and, in general, from collaborating companies’ side.</p>
<p>Consequently, the name, brand, logos or other corporate symbolism cannot be used, in any case, for personal reasons or interests.</p>

<h2>6) Our business</h2>

<ul>
<li><b>Integrity. Zero Tolerance to Corruption</b></li>
</ul>	

<p>In the SYNTHESIA GROUP we condemn bribery and any form of corruption. In no case will we resort to illegal or unethical practices to influence the will of people outside the SYNTHESIA GROUP with the objective of obtaining some benefit for the Company or for ourselves.</p>
<p>All employees who participate in selection processes that concern suppliers and external collaborators including ourselves, have the obligation to act with impartiality and objectivity, applying transparent criteria aligned with the principles of this Code.</p>
<p>In particular, non-contractual or unlawful payments are expressly prohibited to any person or entity, public or private, with the intention of obtaining or maintaining business, other benefits or advantages.</p>
<p>We record any price offered or any payment made, so we are committed to ensuring that the accounting ledgers and records contain the correct and accurate information.</p>
<p>We only establish commercial relations with people according to their professional competence and we ensure the legal origin of the money managed. We must detect the relationships and commercial transactions that put the SYNTHESIA GROUP at risk. For this reason, we will correctly identify any natural or legal person with whom any type of transaction is to be established.</p>
<p>Special attention is paid to transactions involving places identified as tax havens or known for money laundering or terrorist financing activities.</p>
<p>Likewise, in the SYNTHESIA GROUP we are independent of any political ideology, therefore, with our funds, we do not finance any political party nor trade union organization.</p>
<p>Employees who wish to make donations or sponsorships on behalf of the SYNTHESIA GROUP must first receive the approval of the corresponding Governing Boards.</p>

<ul>
<li><b>Commitment</b></li>
</ul>	

<p>We take the necessary measures to ensure that any information related to the operations and business of the SYNTHESIA GROUP is protected and stored in a safe place, irrespective of its format. We are obligated to protect confidential information, as well as industrial and commercial secrets belonging to the SYNTHESIA GROUP and to our partner companies.</p>
<p>We respect the patented and confidential information of others, in the same way that we protect ours. In this line, we ensure that confidentiality agreements have been signed with third parties, with whom we share confidential information.</p>
<p>We undertake not to perform commercial espionage or covert surveillance of the competition.</p>

<ul>
<li><b>Care for the assets</b></li>
</ul>	

<p>We have an obligation to ensure that the assets and resources that the SYNTHESIA GROUP makes available to us for business and professional purposes are used in a suitable and appropriate manner. We must protect and preserve them from any loss, damage, theft or improper use, that could result in detriment to the interests of the companies that are part of the SYNTHESIA GROUP. The obligation to protect the resources also includes the information and knowledge generated within the SYNTHESIA GROUP, owned or held by the GROUP.</p>
<p>We do not use information systems or communications devices for any unlawful, disruptive or obscene acts that could lead to loss or damage to them (e.g. malicious software download), nor do we use unauthorized devices as personal devices, to store data and information of the SYNTHESIA GROUP.</p>

<ul>
<li><b>Consumer Protection</b></li>
</ul>	

<p>In the SYNTHESIA GROUP we are committed to free competition and compliance with the laws established in this regard in the different countries where we carry out activities, avoiding any action that involves an abuse or unfair restriction of the competition.</p>
<p>Likewise, we always act with responsibility and with the utmost respect to the client. Any commercial communication is governed by the principle of truthfulness.</p>
<p>The safety of our products is always a priority, above our economic interests or of any other type. Therefore, we pay special attention to the organization's key processes, providing them with the appropriate  resources.</p>
<p>We are committed to combating drug trafficking by establishing specific systems for controlling stockpiles.</p>
<h2>7)	Acceptance</h2>
<p>On behalf of the SYNTHESIA GROUP we will communicate and disseminate the current Code of Ethics among all our employees and collaborators, who must expressly accept the entire content of the Code and ensure its compliance.</p>
<h2>8)	How should I proceed in case of doubts or detection of non-compliances?</h2>
<p>It is the responsibility of the employees and collaborators to acquaint and apply the internal policies and regulations. To this effect, the SYNTHESIA GROUP makes available all the necessary means to comply with and ensure compliance of the guidelines contained in both this Code and other internal policies communicated and implemented.</p>
<p>In particular, in the SYNTHESIA GROUP we have a Complaints Channel at the email address<a href='mailto:buzondenuncias@synthesia.com '>buzondenuncias@synthesia.com</a> through which any irregularity, breach or behaviour contrary to ethics, legality and the rules that govern our GROUP can be expressed, with the maximum guarantees of security and confidentiality, although the aforementioned communication process cannot be anonymous.</p>
<p>The Chief Compliance Officer, a member of the Ethics Committee, will be responsible for receiving your communication and for coordinating the thorough analysis of any data or related information.</p>
<p>We are committed to providing sufficient guarantees to preserve the privacy of the person contacting us through the Complaints Channel and we guarantee that no employee will be aggrieved by the communication of a possible non-compliance.</p>