Code of Business Ethics

Code of Business Ethics

We, at Nexsys, share a commitment to conduct business with the highest level of integrity and Ethics. Nexsys has always been characterized by conducting its business with the aforementioned values of integrity and ethics. Operating in accordance with a strong sense of integrity is critical to maintaining trust and credibility among our suppliers, customers and business partners, employees, shareholders and other related parties.

For all of us, creating an environment of transparency in the development of our business is one of the most important priorities. Our Code of Business Ethics is our promise to operate candidly and truthfully in our agreements and communications to the marketplace. We expect the Company to operate in accordance with the principles set forth in this Code and that everyone, from members of the Board of Directors and executive leadership team to every single Nexsys employee, will be accountable for complying with these guidelines.

To guarantee the optimal development of this Business Code of Ethics, the company has designated the Ethics Committee as those responsible for compliance, monitoring and decision-making regarding what is designated in this document; This is made up of the General Manager, Human Resources Manager, and the Compliance Manager.

• Guarantee compliance with the Code of Ethics.

• Establish the necessary sanctions for employees who violate the Code of Ethics.

• Stipulate confidentiality in the face of acts infringing the Code of Ethics.

• Ensure respect for and protection of Human Rights.

• Watch for the prevention of conflicts, reprisals and act in accordance with the mechanisms for resolving interpersonal conflicts.

• The Ethics Committee will meet when circumstances so require and at least twice a year.

• Prepare an action plan for Ethics and Transparency in the Company.

The responsibility of administering the Code lies with the Compliance and Corporate Social Responsibility Management with the supervision of the General Management. In the event of a violation of the Code by an employee, he or she will have the opportunity to be heard before any final determination is made.

No adverse action will be taken against a person who makes a complaint, denounces, participates or collaborates in the investigation of an alleged violation of the Code of Ethics, unless it is determined that the accusation made or the information provided is intentionally false. To the maximum extent possible, the company will maintain the confidentiality of all claims.

This Code of Ethics does not contemplate all the work environment conducts that the company has designed through additional policies and procedures. Therefore, the Business Code of Ethics is complementary to all other standards that the company has established.

The company will impose disciplinary measures that are adapted to the nature and circumstances of each violation of this Code.

Violations of a serious nature lead to the dismissal of the employee.

The illegal activities and the lack of Ethics framed in acts of corruption of which the company is aware must be sanctioned and penalized according to the results of the study of the facts.

• Administrative sanctions.
• Pedagogical sanctions.
• Calls for attention.
• Termination of the contract.
• Legal actions.
• Criminal sanctions.

Our Code of Business Ethics contains rules related to individual and peer responsibilities, as well as responsibilities to our employees, customers, suppliers, shareholders, and other related parties, including:

• Compliance with laws, rules and regulations (including laws regarding the use of privileged inside information).

• Protection of confidential information and any other private domain, and that of our customers and suppliers. • Protection and proper use of Company assets.

• Respect fundamental rights, human rights, in all our business operations.

• Compliance with the provisions of the SAGRLAFT Manual.

• Prohibition of Forced Labor and Child Labor.

• Compliance with what is related to the Occupational Health and Safety Management System.

• Dealing with conflicts of interest.

• Protect the environment.

• Encourage reporting of any illegal or unethical behavior.

We all need to study and follow this Code, as well as comply with all applicable laws and Nexsys Group policies and directives. Failure to comply with the aforementioned may lead to civil and criminal liability and cause the imposition of disciplinary sanctions, among others, the termination of the employment relationship.

We give our managers additional responsibility. They must, through their actions, demonstrate the importance of complying with the rules. It is very important to lead by example, as is making yourself available to employees who have ethical concerns or want to report possible transgressions.

Managers are required to ensure compliance with this Code by using appropriate disciplinary measures. They must act in the face of unethical conduct.

The possibility of exemption from this Code of Business Ethics may be granted in certain cases, but only in extraordinary circumstances. Waivers of this Code requested for employees may only be granted by a member of the Executive Leadership Team. Exemptions to this Code for our executives: president, vice president, General Manager or any other senior position with responsibility for financial information may only be granted through our Board of Directors.


We encourage employees to report to their manager, or in accordance with a locally established process, any conduct that they believe, in good faith, to be a violation of the law or the Code of Business Ethics. If the direct manager is involved in the situation or cannot or has not been sufficiently concerned by the suspicions, employees are advised to report it to a higher level manager or follow the locally established procedure.

Suppliers, contractors, customers and others

Non-employees, such as Nexsys-related suppliers, customers, contractors, and other partners, may report potential violations of laws or the Code of Business Ethics to the local operations officer or follow locally established procedures.

report violations

If none of the reporting channels listed above are available or appropriate, and if the alleged violation:

• It is carried out by the management of the Group or the local management,
• Has to do with corruption, questionable accounting or audits, or any other that seriously affects the fundamental interests of Nexsys or the health and safety of people.

Violation should be reported through the internal reporting process. Reports can be managed in the process if it is in accordance with the local legislation applicable to the people involved.

Managers are expected to take the reported matter seriously and work to ensure satisfactory resolution in accordance with Nexsys Ethics and values as well as any other regulatory or local law obligations. Nexsys will not accept any form of discrimination or retaliation against an individual who reports a violation for having reported suspected violations in good faith.

Compliance with laws, rules and regulationsNexsys shall comply with all laws and regulations applicable to its business under the laws of each country in which it operates. When we conduct Nexsys business, a number of legal issues may arise. It is the responsibility of each employee to seek appropriate advice on legal requirements and other relevant legal matters.

International Business

There are specific laws and regulations that apply to our involvement in international business. Employees involved in foreign business transactions must be aware of and comply with all applicable laws and regulations of the foreign country. Nexsys employees involved in international business must, for example, be aware of relevant export and import regulations, anti-boycott rules, trade embargoes, and current sanctions.

Transparency and Anti-Corruption

Nexsys is dedicated to promoting a healthy and transparent business framed within the laws of each country where it operates. Any practice that may be questioned or associated with corruption, including but not limited to the payment of bribes, gifts or incentives that may be associated with corrupt practices, are completely prohibited and prohibited as business practices.

Fair competition is the basis of business development and innovation. All Nexsys employees shall compete in the open market as vigorously and constructively as possible, while complying at all times with the applicable law of each of the countries in which Nexsys operates.

Nexsys reaffirms its commitment to zero tolerance for illegal activities that encourage any type of illegal action such as government and commercial bribery of any degree or level or any activity that is considered corrupt within the framework of Transparency and responsibility of the Company.

Likewise, it establishes good practices aimed at ensuring and transparency in the exercise of its activities in the international supply chain; With training programs, we work against illegal activities such as drug trafficking, smuggling, drug trafficking, terrorism, terrorist financing, and arms trafficking.

Ethics in the Supply Chain

Through its Security Management Policy, it guarantees the transparency of all its operations, honest negotiation and the selection of reliable and continuous supply sources.

We do not offer, promise or provide anything to a supplier in exchange for an improper advantage to the company. We maintain courteous and honest dealings with our suppliers in order to maintain strong, long-term relationships and expect reasonable profits from them. We subject all potential suppliers to uniform and impartial consideration.

Preparation of financial and accounting reports

Nexsys has a duty to strictly follow accounting standards and principles, to produce complete and accurate financial reports, and to have adequate internal controls and procedures to ensure that accounting and financial reporting comply with the Law. Nexsys employees shall do all they can to support the Company’s efforts in this regard.

The employees who have the scope of the financial area of NEXSYS will keep discretion and confidentiality in the information that is handled, as well as guarantee the filing, storage and protection of physical and electronic documentation.