2. www.garnica.one
1. PURPOSE
2. SCOPE OF APPLICATION
3. ORIGIN, APPROVAL AND EFFECTIVENESS
4. MISSION AND VALUES
5. PATTERNS OF BEHAVIOUR
5.1 PRINCIPLES
5.2 BEHAVIOURAL STANDARDS
5.2.1 In relations with employees and interest groups
5.2.1.1.Professional performance and respect
5.2.1.2.Health and safety
5.2.1.3.Intimacy
5.2.2 Before situations of conflict of interest
5.2.2.1.Gifts, compensations, presents, assistance and other type of offerings
5.2.3 Treatment of information and law
5.2.3.1.Confidentiality
5.2.3.2.Transparency and disclosure
5.2.3.3.Law. Prevention of money laundering
5.2.4 In relations with the environment and other agents in its environment
5.2.4.1.With the environment and territory
5.2.4.2.With costumers and consumers
5.2.4.3.With suppliers and contractors
5.2.4.4.With partners
5.2.4.5.With respect to the competition
5.2.4.6.In the market, in institutional relations and in relations with third
parties
5.2.4.7.With legal and tax authorities
5.2.5 In relation to the assets and rights of GRUPO GARNICA PLYWOOD S.A. and
subsidiaries
6. RESPONSIBILITIES RELATED TO THE CODE OF ETHICS
6.1 SHARED RESPONSIBILITIES
6.2 ADDITIONAL RESPONSIBILITIES
7. ACCEPTANCE, COMPLIANCE AND SUPERVISION
8. DISCIPLINARY PROCEEDING
Annex 1
3. www.garnica.one
1. PURPOSE
This Code of Ethics sets forth the fundamental principles and rules considered
essential to this purpose and they should serve as a behavioural guide for the
people to whom it applies in their professional relationships with third parties and
Society as a whole, thus consolidating a culture and a set of responsible behaviour
patterns that should be shared, accepted and endorsed by all.
This Code, together with the rest of the corporate documentation, is a commitment
with the law, good governance, transparency, responsibility, independence and
reputation, in terms of socially accepted ethical standards.
2. SCOPE OF APPLICATION
This Code of Ethics applies to all the members of the administration bodies and all
the employees of GRUPO GARNICA PLYWOOD S.A. and subsidiaries (interest
groups), regardless of the legal modality that determines their labour relationship,
the position they occupy or the geographic location in which they perform their
work.
Particularly and for the purpose of completing the Communications contained in
Annex 1, this Code of Ethics considers interest parties those that on a non-
exclusive basis, due to their position in the Group's organisation chart, perform
functions that bear responsibility over people and/or assets.
The total or partial application of this Code can be extended to any individual
and/or corporate body related to GRUPO GARNICA PLYWOOD S.A. and subsidiaries
when required to comply with its purpose and if possible due to the nature of the
relationship.
4. www.garnica.one
3. ORIGIN, APPROVAL AND EFFECTIVENESS
This Code of Ethics includes a series of guidelines that the Group, since its origins,
has been applying and encouraging among its interest groups, understanding as
such, its employees, customers, suppliers, competitors, regulating bodies and
shareholders. This Code of Ethics is an inescapable reference for all its activities
and the conduct of its interest groups, as the reputation, credibility, independence
and success of GRUPO GARNICA PLYWOOD S.A. and subsidiaries depends largely
on all the interest groups respecting its content in an honest, civic, comprehensive,
strict, transparent and devoted way.
This Code of Ethics, to which all the companies that comprise the Group must
adhere, was approved in the meeting held by the Board of Directors on 21 July
2015, and it shall be published on the corporate website of GRUPO GARNICA
PLYWOOD S.A. with an indefinite duration.
GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall adopt the necessary
measures to implement the set of values and standards that comprise this Code, as
well as circulate the content among the interest groups and solve any queries that
may arise in its application.
However, the Code shall be reviewed and updated with the necessary frequency.
4. MISSION AND VALUES
MISSION: Wherever GRUPO GARNICA PLYWOOD S.A. and subsidiaries operates, its
aim is simply to become, and then continue being, the best company, providing:
Its customers: Products and services with an excellent value
Its investors: A good return on their investment
Its employees: A gratifying job both personally and economically
Its suppliers: Valued contracts and fair trade
5. www.garnica.one
Its community: Supporting implication and examples of good practices
The environment: Commitment to improve and respect
VISION: GRUPO GARNICA PLYWOOD S.A. and subsidiaries desires to be a reference
worldwide in promoting the use of wood as an element capable of improving our
quality of life, not only individually but also collectively. In addition, it wants to be
recognised for the level of eagerness and professionalism it displays in its
performance. Lastly, it intends to build a strong and solvent organisation that
withstands time by means of a solid relationship with all those that have an
interest and relation with it.
VALUES:
• Feel and be Garnica
• Continuous improvement and innovation
• Result-oriented
• External and internal customer-oriented
• Sense of collectiveness
• Commitment with the environment
• Above all, an ethical, professional, rigorous and systematic conduct
5. PATTERNS OF BEHAVIOUR
All interest groups shall behave in accordance with the principles of behaviour
listed below.
These principles establish the benchmark that should inspire the basic conduct of
all the interest groups, complying with the principles of loyalty, good faith and
respect for the law.
6. www.garnica.one
5.1. PRINCIPLES
GRUPO GARNICA PLYWOOD S.A. and subsidiaries assumes a commitment to carry
out its business activities and encourage conducts in the interest groups that are in
accordance with the legislation in force and that are ethically respectable.
The activities carried out by GRUPO GARNICA PLYWOOD S.A. and subsidiaries and
the actions of the interest groups must be performed in a framework of healthy
competition and dignity, while complying with the law, especially the Human
Rights and Public Liberties, and the rights of third parties, especially in matters
such as the worker's rights and the industrial and intellectual property rights.
All the interest groups must observe an ethical behaviour and prevent any conduct
that, despite not being against the law, may harm the reputation of GRUPO
GARNICA PLYWOOD S.A. and subsidiaries or be detrimental to its interests,
reputation and public image.
Furthermore, all the interest groups must be aware of the laws and regulations
applicable to their specific professional activity and shall request the necessary
information, if appropriate, from their superiors or through the relevant bodies or
departments of GRUPO GARNICA PLYWOOD S.A. and subsidiaries, strictly in
adherence to the protocols established to detect or prevent, if appropriate, the
commitment of illegal activities within the activities of GRUPO GARNICA PLYWOOD
S.A. and subsidiaries.
No interest group shall knowingly cooperate with third parties in the infringement
of any law or collaborate in any actions that might endanger the principle of
legality or that might damage the reputation of GRUPO GARNICA PLYWOOD S.A.
and subsidiaries or represent a prejudice for the perception of the markets,
customers, suppliers or regulatory bodies, among others.
7. www.garnica.one
Summarising, GRUPO GARNICA PLYWOOD S.A. and subsidiaries encourages
complying with the law and rejects any interest group affecting any third parties
with any illicit or unethical behaviour, especially if it affects any recognised legal
rights within the scope of intellectual property, intimacy, honour or the disclosure
of secrets.
GRUPO GARNICA PLYWOOD S.A. and subsidiaries assumes that in any relationship
with third parties, these should act with the same commitments towards the law,
the rights of any affected party, loyal competition and the respect for human
dignity.
5.2. BEHAVIOURAL STANDARDS
5.2.1. In relations with employees and interest groups
5.2.1.1. Professional performance and respect
In the management of human resources and the relationships between the
employees, GRUPO GARNICA PLYWOOD S.A. and subsidiaries imposes on itself and
the Group to always focus on the most thorough respect for the dignity and privacy
of people, following the principles of mutual confidence and respect.
Similarly, the relationships between the employees of GRUPO GARNICA PLYWOOD
S.A. and subsidiaries and those of the cooperating companies shall be based on the
above criteria, as well as on professional respect and mutual cooperation.
GRUPO GARNICA PLYWOOD S.A. and subsidiaries expressly prohibits any abuse of
authority and any kind of harassment, either of a physical, psychological or moral
nature, as well as any other behaviour that might give rise to an intimidating,
offensive or hostile work environment for any individual.
8. www.garnica.one
Similarly, GRUPO GARNICA PLYWOOD S.A. and subsidiaries does not tolerate any
type of discrimination based on any circumstance.
In this respect, GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall ensure that
the companies with which it engages in its professional activities respect the
International Agreements on employment and the human rights standards,
expressly rejecting any commercial relationship with companies or individuals that
encourage opposite behaviours towards the rights of employees and foreign
citizens.
5.2.1.2 Health and safety
GRUPO GARNICA PLYWOOD S.A. and subsidiaries commits to providing a healthy
and safe working environment.
All the employees of GRUPO GARNICA PLYWOOD S.A. and subsidiaries will be
responsible for the thorough observance of the occupation health and safety
regulations, with the aim of avoiding, to the extent possible, any occupational risks
and accidents.
In this sense, it is forbidden to perform any tasks under the influence of alcohol or
any other legal or illegal substances that can hinder the level of safety required to
perform the required activity.
Likewise, GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall not tolerate any
type of activity that could involve the custody, storage or traffic of illicit goods in
legal relations.
GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall encourage among its
contractors and suppliers compliance with the legal standards on occupational
health and safety.
9. www.garnica.one
5.2.1.3. Intimacy
GRUPO GARNICA PLYWOOD S.A. and subsidiaries commits to not disclosing any
information requested from employees or other interest groups, except for
personal information required by law or given with their consent.
Any employees or interest groups that have access to information as a result of
their activity commit to using this information correctly and in accordance with the
law, guaranteeing their confidentiality.
5.2.2 Before situations of conflict of interest
A conflict of interest will be understood as any situation where the personal
interests of any member of the interest groups and the interests of GRUPO
GARNICA PLYWOOD S.A. and subsidiaries directly or indirectly collide. The former
should avoid any situation that could involve a conflict of interest on a personal,
family or any other level. The interest groups should also abstain from
representing GRUPO GARNICA PLYWOOD S.A. and subsidiaries or include or
intervene in any decision-making where they or any person related directly or
indirectly has a personal interest.
5.2.2.1. Gifts, compensations, presents, assistance and other type of offerings
The employees and executives of GRUPO GARNICA PLYWOOD S.A. and subsidiaries
in the performance of their activity shall act giving priority to the interests of the
company against any personal or third-party interests that could influence their
decisions or actions.
The Employees of GRUPO GARNICA PLYWOOD S.A. and subsidiaries may neither
offer nor receive gifts in the course of their professional activities. Exceptionally,
the delivery and acceptance of gifts and presents will be authorised when, not
prohibited by the legislation, their economic value is irrelevant or symbolic and
10. www.garnica.one
they respond to the customary courtesy or business habits while not affecting any
decision-making or professional performance.
Specifically, the employees of GRUPO GARNICA PLYWOOD S.A. and subsidiaries
may not give or receive, without valid legal grounds, any kind of bribery or
commission, originated or made by any other party involved, such as Spanish or
foreign civil servants, employees of other companies, political parties, customers,
contractors, suppliers and shareholders. This includes any direct or indirect offer or
promise of any kind of improper benefit, any instrument to conceal such benefit
and influence peddling.
If any employee or executive of GRUPO GARNICA PLYWOOD S.A. and subsidiaries
were to receive a gift or assistance with a relevant economic value that does not
answer to any usual business courtesy or attention and that does not affect any
decision-making or professional performance, on a general basis, the employee or
executive shall return it and explain the policy of GRUPO GARNICA PLYWOOD S.A.
and subsidiaries in this respect. If this were not possible due to reasons of culture
or any other, the gift or attention shall be forwarded to the department of Human
Resources for its delivery to renowned social associations, charities or non-
governmental organisations.
5.2.3 Treatment of information and law
5.2.3.1 Confidentiality
Professional secrecy shall be kept of commercial, economic or strategic
information belonging to GRUPO GARNICA PLYWOOD S.A. and subsidiaries or to
companies or people comprising it or with which it engages, except for when its
disclosure is allowed by law, when express authorisation has been provided or
when requested by law or court order.
11. www.garnica.one
Strict confidentiality shall be respected in the use of operational processes, work
systems and any other internal procedure.
5.2.3.2. Transparency and disclosure
GRUPO GARNICA PLYWOOD S.A. and subsidiaries assumes transparency as a
principal of behaviour. This shall be understood as the commitment to transmit
reliable information to the market and Society as a whole, allowing them to obtain
a truthful picture of the activities, strategy and economic, social and environmental
performance of GRUPO GARNICA PLYWOOD S.A. and subsidiaries.
The interest groups must transmit the information in a truthful, complete and
comprehensible manner. Under no circumstances shall they provide or allow the
generation of incorrect, inexact or imprecise information that could induce to error
in the recipients. The forgery, manipulation and deliberate use of false information
represent a fraud.
5.2.3.3. Law. Prevention of money laundering
All the operations and transactions performed by GRUPO GARNICA PLYWOOD S.A.
and subsidiaries must be strictly legal, especially ensuring the compliance of all tax
and social security obligations. They should all be posted in the accounting system
at the appropriate time and following the criteria of existence, integrity clarity and
precision. This shall be performed in conformance with the accounting standards
applicable at each moment and in such a way that all the financial information is
reliable and includes all the assets and liabilities of GRUPO GARNICA PLYWOOD
S.A. and subsidiaries.
Particularly, the employees and executives of GRUPO GARNICA PLYWOOD S.A. and
subsidiaries shall abstain from:
12. www.garnica.one
a) Establishing accounts that are not recorded in the books
b) Not recording any performed transactions or posting them erroneously
c) Recording fictional incomes, expenses, assets and liabilities
d) Posting expenses with an incorrect indication of its purpose
e) Using false documentation
f) Deliberately destroying accountancy records before the period required
or established by law
g) Incorporating companies and opening bank accounts in tax havens
GRUPO GARNICA PLYWOOD S.A. and subsidiaries and the employees, as well as the
interest groups involved, must comply with the obligations imposed by the law on
money laundering and shall not illicitly or inappropriately use, in any case,
information related to customer payments.
Accordingly, it is forbidden to perform any activity that involves falsifying or using
fraudulently any payment mechanisms used by the customers and/or suppliers of
GRUPO GARNICA PLYWOOD S.A. and subsidiaries, such as credit or debit cards,
among others.
5.2.4 In relations with the environment and other agents in its environment
No interest group must collaborate with any third party in the violation of any law
or collaborate in actions that could compromise the principle of legality or that
could damage the reputation of GRUPO GARNICA PLYWOOD S.A. and subsidiaries.
5.2.4.1. With the environment and territory
GRUPO GARNICA PLYWOOD S.A. and subsidiaries is committed to the environment
and the situation of the territory, and it faces its environmental commitment by
looking after the compliance with the applicable legislation in any of its spheres of
activity.
13. www.garnica.one
The interest groups shall perform their activities with the greatest respect for the
environment, complying with the applicable regulation in order to minimise the
negative environmental impact and optimise the use of the available resources in
all its spheres of activity.
Likewise, the interest groups shall pay special attention to the use of explosive or
potentially radioactive material, if any, with the purpose of avoiding any incident
that could affect its employees or any third parties.
In addition, the interest groups shall apply this commitment to the customers,
suppliers and all the people with which it relates in the scope of its activity, taking
as a basis the minimum standards established by the Spanish law.
5.2.4.2. With costumers and consumers
Independence shall always be safeguarded in any professional performance with
customers and consumers, avoiding any influence from economic or family links or
friendship. Specifically, independence shall be guaranteed in the granting and
establishment of conditions in any information or work or in any procurement of
goods or services in general.
Rigour in the treatment of the personal information related to customers shall also
be ensured. The access to customer information shall only be justified for legal
reasons, and its custody and use shall be performed with strict adherence to the
provisions established in the current regulation, specifically, in the law on personal
data protection.
The products and services shall be offered to customers and consumers through
sufficient and precise information.
14. www.garnica.one
Under no circumstances shall the interest groups be encouraged to perform
actions that could result in direct or indirect advertising of illicit or potentially
fraudulent activities.
In particular, the interest groups commit to respecting customer information that is
especially protected from a point of view of intellectual or industrial property.
GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall search for the best formulas
in promoting respect for the content and principles of this Code of Ethics among its
customers, specifically, for the contents and principles that affect the safety and
the compliance with the law, accurate information, the respect for the rights of
third parties and the human dignity.
5.2.4.3. With suppliers and contractors
The relations with suppliers in GRUPO GARNICA PLYWOOD S.A. and subsidiaries
shall be performed in a framework of transparent collaboration that allows and
helps achieve the shared goals and the fulfilment of the social responsibility held
by GRUPO GARNICA PLYWOOD S.A. and subsidiaries, always complying with the
current legislation.
The interest groups shall not encourage or participate in any potentially illicit
activity, especially if there is a risk of a supplier harming any third party.
The selection and contracting of suppliers must comply with the internal standards
existing at any time, guaranteeing transparency, an equal treatment and the
application of objective criteria without any beneficial treatment.
GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall encourage and widespread
the contents and principles of this Code of Ethics among its main suppliers.
15. www.garnica.one
In any case, the interest groups shall only contract with suppliers that offer
possibilities of complying with the current law and the provisions of this Code.
5.2.4.4. With partners
GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall encourage the awareness of
this Code of Ethics among its partners with the purpose of applying its contents in
the best possible manner.
5.2.4.5. With respect to the competition
GRUPO GARNICA PLYWOOD S.A. and subsidiaries is committed to free competition
and the compliance of the laws established in this field. It shall avoid incurring in
any action that involves an illicit abuse or restriction of the competition. The
interest groups shall honour this commitment and also avoid any action that
involves a disloyal behaviour in the markets. Particularly, they shall by not carry out
any misleading advertising of activities, products or services of GRUPO GARNICA
PLYWOOD S.A. and subsidiaries. All this with the aim of avoiding any conduct that
constitutes or could constitute an illicit abuse or restriction of the competition or a
legally disloyal practice or the use of a trade secret or any confidential information
belonging to a third party.
5.2.4.6. In the market, in institutional relations and in relations with third parties
The relations with institutions, bodies and public or private authorities must be
governed by institutional respect and must be performed strictly following the
criteria of legal compliance. Therefore, all the sections of this Code are applicable,
especially those cases referred to in section 5.2.2.1.
16. www.garnica.one
5.2.4.7. With legal and tax authorities
GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall consider as wrongful any
action that involves a failure to comply accurately and faithfully with any legal and
tax obligations. The interest groups must conform their behaviour to the previous
criterion, and especially not perform any activity that is not within the scope of the
authorisation or licence applicable in each case.
Likewise, GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall collaborate with
the Public Authorities at all times, complying with its requirements regarding the
organisation itself and its requirements with respect to its employees or external
collaborators. In this regard, GRUPO GARNICA PLYWOOD S.A. and subsidiaries shall
ensure entering rigorous and reliable information in its computer systems, thus
avoiding any collaboration with employees or third parties for fraudulent
purposes.
5.2.5 In relation to assets and rights of GRUPO GARNICA PLYWOOD S.A. and its
Group
The resources, means, goods and premises of GRUPO GARNICA PLYWOOD S.A. and
subsidiaries must be used in benefit of GRUPO GARNICA PLYWOOD S.A. and the
Group while complying with the Law. This shall be performed without harming any
third-party rights and without any particular intention or personal benefit or
benefit of third parties other than the purpose of GRUPO GARNICA PLYWOOD S.A.
and subsidiaries.
All interest groups must comply with the current law on Data Protection and
exclusively use and request the information that is strictly required. This obligation
includes the correct use of what should be done with corporate resources related
to information technology and communications put at the availability of those
17. www.garnica.one
concerned, complying with the contents established in the applicable internal
procedures.
GRUPO GARNICA PLYWOOD S.A. and subsidiaries respects the personal
communications carried out using the Internet and other means of communication.
The interest groups, especially the employees, commit to a responsible use of the
Internet and other means of communication, the computer systems and, in general,
any other media made available by GRUPO GARNICA PLYWOOD S.A. and
subsidiaries.
In any case, all computer elements, such as personal computers, email, temporary
files, access to the Internet, etc. shall be considered work tools, and they shall be
used exclusively for professional purposes. In spite of allowing a reasonable
personal use of these systems, GRUPO GARNICA PLYWOOD S.A. and subsidiaries
shall adopt the necessary control measures on these work tools by using different
mechanisms and/or media, with the purpose of guaranteeing a suitable and
effective use.
The servers and other tools provided by GRUPO GARNICA PLYWOOD S.A. and
subsidiaries cannot be used for personal or illicit purposes (especially if seeking to
attack the competition), for downloading or taking advantage of unauthorised
information that is protected by copyright or industrial or intellectual property
laws when not holding the corresponding licence, or for taking advantage of
information with the aim of achieving an illicit purpose.
In this sense, GARNICA PLYWOOD S.A. and subsidiaries shall ensure that its
employees, executives and external collaborators do not infringe any third-party
industrial and intellectual property rights, in accordance with the applicable
legislation.
18. www.garnica.one
6. RESPONSIBILITIES RELATED TO THE CODE OF ETHICS
The tasks entrusted to each employee shall be performed following criteria of
rigour and responsibility. A responsible professional behaviour abides by the
efficient contribution to applying the policies and reaching the objectives defined
by GARNICA PLYWOOD S.A. and subsidiaries.
Understanding and complying with the principles of this Code of Ethics is a general
responsibility of all the interest groups.
However, it is worth noting some differences in their responsibilities.
6.1. SHARED RESPONSIBILITIES
All the interest groups must fulfil the following responsibilities:
Comply with the principles and standards established in this Code
Comply with the laws, regulations and other rules of application to their jobs
Seek advice in the event of any doubts regarding the compliance with this
Code of Ethics
Participate in the training and assessment activities offered
Inform about any non-fulfilment or infringement of the rules included in this
Code
Collaborate in good faith with the carrying out of the controls and internal
audits performed to identify and correct any eventual deficiency and
weakness
6.2. ADDITIONAL RESPONSIBILITIES
Interest groups with directive powers have certain additional responsibilities:
- To lead through example. Their conduct must be a model of upright
behaviour
- To ensure that the employees under their responsibility understand the
requirements of the Code
19. www.garnica.one
7. ACCEPTANCE. COMPLIANCE AND SUPERVISION
The condition of interested party involves the obligation of complying with this
Code. Its circulation and amendments shall follow the applicable internal
procedures.
GARNICA PLYWOOD S.A. and subsidiaries expects from the interest groups an
honest, strict and transparent behaviour that is aligned with the principles of this
Code.
Nobody, regardless of their position, is authorised to request anything contrary to
the contents established in this Code of Ethics or to protect a behaviour relying on
the position of a superior.
For this reason, all the interest groups must immediately inform, in conformance
with the provisions established at that time, of any non-compliance or violation,
especially when it could constitute an offence.
GARNICA PLYWOOD S.A. has implemented a specific communications procedure
known as Ethical Box that enables all interest groups, with a guarantee of
confidentiality and without fear of retribution, to easily and confidentially
communicate those actions that, at their sound judgement, constitute conducts or
actions that are inappropriate or breach the Code of Ethics or any other applicable
internal or external regulation.
The Ethical Box consists of a specific email address (buzonetico@garnica.one) and
a postal address: Dirección de Control de GRUPO GARNICA PLYWOOD S.A., Parque
de San Miguel, núm. 10 Bajo, CP: 26007 Logroño (La Rioja), and it can also be used
by any of the Group's interest groups whose companies are adhered to it.
20. www.garnica.one
The communications received at the Ethical Box shall be treated confidentially;
therefore, all the necessary measures to guarantee this confidentiality shall be
implemented at all times.
However, in order to ensure the accuracy of the information received, only those
complaints in which the complainant is clearly identified will be accepted. The
Ethics Committee has been empowered to analyse and assess these complaints,
and it will reach its decisions by majority. This Ethics Committee shall be made up
of all the people defined in the internal documents of GARNICA PLYWOOD S.A. and
subsidiaries.
8. DISCIPLINARY PROCEEDING
As the behaviours included in this Code of Ethics are mandatory in GARNICA
PLYWOOD S.A. and subsidiaries, the Ethics Committee must assess every complaint
received. The General Directorate of Human Resources or the equivalent body of
each Group company must take the appropriate disciplinary measures that arise
from applying the Code of Ethics, while considering in all cases the applicable
bargaining agreements and regulations and the Manual for Prevention and
Response to Offences prevalent at the time.
Among the violations that can be subject to disciplinary measures are:
a) Breaching or inciting to breach any prohibitions or standards established in the
Code.
b) Refraining from the obligatory communication of a suspicion of a violation or
notable non-compliance of the standards established in the Code of Ethics of
GARNICA PLYWOOD S.A. and subsidiaries.
c) Not cooperating with the investigations carried out by GARNICA PLYWOOD S.A.
and subsidiaries in possible breaches of the Code.
21. www.garnica.one
d) Taking retaliation against an employee or executive of GARNICA PLYWOOD S.A.
and subsidiaries for communicating a breach of the standards of the Code of
Ethics.
e) Lacking the leadership or being negligible in the duty of demanding adherence
to the Law and the standards of the Code of Ethics.
