CORPORATE RESPONSIBILITY POLICY

In PRODUCTOS J.V., S.L. (from now on “JV”) we consider the Corporate Responsibility as the actions carried out to build stable and solid relations of trust and mutual benefit with our groups of interest. Its purpose is to establish the principles of action and compromises that determine our socially acceptable behavior and that are complementary with our QUALITY AND PROTECTION OF THE ENVIRONMENT POLICY described in the following section 5.3.

1. Anti-bribery policies: any kind of bribery and corruption related with the professional activity of the company are strictly prohibited in JV. The employees caught taking part in a case of bribery or corruption, either offering or receiving it, will face disciplinary measures that can include dismissal, economic penalties or penal prosecutions, depending on the importance of the case and the applicable laws. The actions made through third parties (agents or representatives, sellers, clients, partners, suppliers, etc.) are also included in the above-mentioned disciplinary measures. Employees must refuse, politely but firmly, any kind of bribery, as subtle as it could be. That means, that the employees should avoid that their comments could give the impression that they might be suggesting or accepting it. It should be clear to the other person that we do not want to offer or receive any kind of gift or preferential treatment and that JV has strict policies regarding these issues and we might lose our job if we get involved in actions that violate these principles.

2. Ethical policies: In JV we commit ourselves to conduct all our business with honesty, integrity, reliability and responsibility as basis of our Code of Conduct and Corporate Ethics. As a consequence, we acquire the commitment to refuse any commercial or professional relations with organizations that may use the work of children or may take part in any kind of discrimination or abuse because of origin, race, gender, religion, opinion or any other social or personal circumstance. Also any kind of action that could be considered extortion, sexual or psychological harassment (mobbing) at work, physical or verbal, with or without abuse of authority will be also watched and refused. The resources of the company and/or tasks of the employees cannot be used for political contributions or activities. The employees, as citizens with private rights and during their free time, will obviously be able to have and keep political relations if it is their will, but never in working hours or during the activities that belong to the company.

3. Professional confidentiality: the employees in JV commit to preserve the confidentiality of the documents and information directly or indirectly received, either if they come from JV or from its clients; and they should demand the same responsibility to their suppliers. The employees are also not allowed to work simultaneously in competitor companies. JV also keeps the confidentiality of the personal data of all their employees, provided only for the processes resulting from their professional relation with the company.

4. Protection of the environment: JV follows all the laws related to the protection and preservation of the environment, professional health and security that are applicable in the country and controls that the manufacturing of the products has the slightest effects for people and the environment. We follow an appropriate protection of the environment policy and process and also the principles of the United Nations in their UN Global Compact Initiative, as long as the prohibition laws and substance declaration from each client. When JV has to work in the client’s facilities we will also follow their current preventive regulations.

5. Escalation Policy for reports of deficiency of ethics: JV establishes an escalation system that gives any employee the possibility to report any irregularity detected about the before mentioned sections, without risk of any form of retaliation, including the possibility to preserve their anonymity (the suggestion boxes can also be used for this purpose).
   The person in our organization designated to receive these reports is the responsible for Human Resources, who must attend to these statements with total discretion, impartiality and determination to preserve the honor of the company.