Ethics handbook

Letter by the Managing Partners

The history of our companies, founded by Captain Albert von Appen, started over sixty years ago with our employees. Our daily endeavours have been focused on supporting our customers and communities by providing maritime, port and industrial logistics services of excellence.

Over this time, ethics has been a key element for the development of people and the prestige and sustainability of our company, as it enables us to make progress with achieving our objectives, not in any fashion but aligned with the principles of the Ultramar Group.

Currently, the development and expansion of our Group has driven us to bear in mind certain ethical standards to enhance our hallmark of the way of doing business. The Ethics Handbook of Ultramar Agencia Marítima, which belongs to the Ultramar Group, arises from the need of uniting all employees around core values, which are the transversal driver of our operations and encourage us to act with excellence, passion and integrity.

We want to provide a tool that embodies the company’s aims now and in the future. We therefore hope this handbook, which is available to our employees, customers, contractors, consultants and suppliers, is useful so every day we can fulfil our mission of being a partner you can trust.

Dag von Appen

Richard von Appen

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Business vision

I. Our business:

In Ultramar Agencia Marítima we put the customer at the heart of our decisions, striving to provide in the most efficient and effective way allowed by the industry a wide range of maritime, port and industrial logistics services by means of five business lines (ports, agency services, logistics, tugs and shipping).

II. Our work culture

Our values are the hub underpinning our culture and our way of doing things.

Based on integrity, we respect all people, who are at the heart of everything we do; we honour promises; we strive to deliver on commitments, safety, care of the environment and the development of communities around our operations; we seek high ethical standards that guarantee sustainability and safeguard our reputation.

The value of >passion for our work and company drives us to get to know and understand our customers, and challenges us to exceed their expectations. We strive to do a good job focusing on the details that make a difference; there is also joy and a good mood, and build a company to which others would like to belong, fostering the personal and professional development of the team.

We seek excellence to add value to the development and competitiveness of our customers; we work with an open-door and open- agenda policy and encourage creativity and innovation to come up with solutions that go beyond what is established.

We work with strict safety measures, permanently driving self-care.

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Purpose and scope of this handbook

I. What for?

This Handbook aims to provide a reference framework generated from the values, principles and culture of Ultramar Agencia Marítima, seeking to clarify what we can expect from each other and regarding the different stakeholders with whom we engage in the activities of our organisation.

This Handbook does not seek to repeal or replace other in-house policies, regulations or procedures of the company, but on the contrary to complement and add to them.

II. Who is it targeted at?

We hope that any person who works, advises or represents Ultramar Agencia Marítima in any of our business lines knows and uses this Handbook.

It is an invitation to act committed to our values and culture considering the guidelines given herein, and resort to the channels implemented to resolve concerns through our Ethics Management System in all relations that arise within the company, be they between employees, directors, executives; relations that arise between the company and its customers or suppliers or the company and its partners or shareholders, the market and authorities.

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1. A profitable and responsible company of excellence

Our business approach is to provide service excellence in the merchandise transport area in a profitable way, taking care of and being accountable for the impact that as an organisation we might have on other people, on society and the environment.

To such effect, it is our interest as an organisation:

  1. For everybody to win: for our business, the customer and society to win. We permanently review the responses to our customer needs, the impact of our decisions on society and the environment, organising our work processes so that everybody, without distinction, gets fair treatment and a quality service.
  2. To always strive for excellence in what we do: we constantly review the condition of the industry, seeking to embrace best practice for our customers to continually enhance our work, our services and the footprint of our activities.
  3. To optimise profitability with the right balance between benefits and the risks undertaken: we detect the key elements that create value, we constantly review our costs and appraise the effect of our decisions on long-term sustainability.

For this, we individually:

  1. Value and respect all our customers, working to get to know and meet their expectations and deliver on the commitment we have made with each of them.
  2. Seek to consider the vision of our customers to continually improve our work and come up with creative solutions to support them with the services we provide, adding value to their business.
  3. Take care of and efficiently use the resources the company makes available to perform our work, aware of the impact that our individual decisions have on our company’s sustainability.


Q: “I’ve recently received many complaints by customers who are unsatisfied with the service we provide, mainly due to delays with deliveries. What should I do?”

A: We’re working in the company to meet the needs of our customers, so an unsatisfied customer must become a priority for whoever identifies this. We seek to build trusting relations, so by detecting issues with the service provided, we must analyse them immediately with our work teams or the corresponding area to express the concern and be able to act timely and efficiently to complaints.


Q: “After talking to my work colleagues, I realised that we could cover a new business line in a contract that’s already operating with an important customer for the company with whom we’ve been working for some time. Unfortunately, I have a lot of work and believe that if I mention the issue, this will be given to me. I don’t know if I can take on any more work.”

A: If we discover new opportunities to make our business more efficient and provide a better service to our customers, we should not ignore them. It’s important that you can talk frankly to your boss and express your idea, but also what concerns you about the extra workload this could entail. Teamwork is a core part of our way of addressing challenges, and with your help we can organise ourselves to distribute the work better.

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2. A realiable brand

We act in keeping with our values and objectives, seeking to take care of the image, brand and hallmark we project to all our stakeholders.

To such end, it is our interest as an organisation to:

  1. Project our hallmark: we seek to deliver on our objectives, our organisational practices and the way we act to project a clear image showing our intention of making a contribution to society.
  2. Inform about our activities: we continually provide clear information about what we are doing so our employees, customers and communities know our objectives, priorities and the care we take.
  3. Act with discretion: the information we handle deserves the maximum care and respect, let’s take care of it as it is an asset for our company and customers.

For this, we individually:

  1. Are aware of the importance of taking care of our conduct and the decisions we make, as these also project and have an impact on the company’s image.
  2. Are proactive about getting to know, understand and act in accordance with the objectives that guide us as a company, and also to provide complete and trustworthy information for the continuous improvement of our activity.
  3. Safeguard and promote the careful use of any sensitive, reserved or confidential information to which we have access, even if we no longer belong to the company, because we are aware that is a key asset of our work.


Q: “I have a friend who has a Foundation and he needs new partners to be able to maintain the project, so he asked me if I could give him a database of our customers to be able to contact them. I believe this is for a good cause and it would not be misuse of the data. What should I do?”

A: Databases and any confidential information are given to our employees to facilitate their work, boost the company’s business and enhancement opportunities, so it should not be given to any person outside the company who could use it for other purposes, irrespective of the cause.


Q: “We have found out that management has made a decision which we believe is wrong. In corridor chat, we’ve commented on this with work colleagues and some criticism has arisen because our boss is always very busy and the truth is that we never have time to express our point of view.”

A: If we believe a decision has been made wrongly or we simply do not like it, we should find the right moment to discuss it with our bosses. Although that might be a tough conversation, by stating our opinion we can make a contribution with a standpoint that has perhaps not been considered, or better understand the arguments behind a decision. It’s important to recall that instead of criticising, we can always suggest, make a contribution or improve what we disagree with by providing creative and constructive ideas.

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3. A good place to work

We trust our teams and appreciate the contribution made by each employee.

To such effect, it is our interest as an organisation to:

  1. Drive the safety commitment: we take care of the health and safety of our employees, seeking to manage the risks and providing personal protection equipment so they can do their work. We safeguard healthy workplaces and communication and training to advance learning and the continuous improvement of our measures and controls on this issue.
  2. Develop people: we seek to be an opportunity for comprehensive development, generating conditions and opportunities based on merit and transparency so we can keep pace with our employees and get the best out of them.
  3. Promote a respectful work environment: we take care to forge constructive relations in our teams, appreciating the contribution of each member to add value to what we do. We safeguard the freedom and rights of everybody, staying on the alert to avoid situations that might be intimidating, violent or insulting.

For this, we individually:

  1. Are focused on taking care of our own safety, that of our work colleagues and of the workplace. Let’s be proactive showing appropriately the elements that prevent and manage the risks in our daily work.
  2. Encourage work as an area for development, understanding that each individual can enhance learning and growth from the proactive commitment to the quality of what he or she does.
  3. Enhance the company’s culture, living the values in all our relations. Let’s make trust the core element of our culture, fostering close relations and addressing possible differences respectfully and proactively.

For further information about our internal policies, please see the Internal Order, Hygiene and Safety Regulation


Q: “I’ve found out that one of the conveyors that hoists the containers is worn, but to change it for another would take a long time and we’re behind on delivery timescales. I’ve thought about patching it to be able to continue with the work. What should I do?”

A: Safety is a core value for the company so you must report this to your supervisor as soon as possible so the conveyor is replaced with another good one.


Q: “A vacancy has become available for a higher position in the company. I told my boss I was interested in applying due to my time in the company and my positive evaluation. Shortly later, a work colleague was promoted to the position without any explanation or selection process. Is there anything I can do?”

A: At the company we strive to assure the development of our employees in the company with transparent internal posting processes. Our interest is for work opportunities to be offered based on clear criteria, so you must raise your concern to your boss or another higher level that you trust. If you get no reply, you can use the channels available in the Integrity Management System.

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4. A sustainable activity

We strive for sustainability to involve everything we do, with a special focus on relations with the environment to thereby make a contribution to society.

To such effect, it is our interest as an organisation to:

  1. Take care of our supplier relations: let’s forge bonds of loyalty with our suppliers, understanding their importance for our value chain and taking care of transparency and impartiality in the relations we establish.
  2. Take care of the environment: let’s adhere to current legislation everywhere we operate and make sure that our initiatives make an improvement to the environment, whenever possible.
  3. Take care of our community relations: let’s understand local communities and their needs. Let’s seek to make a contribution to their development with what we do, striving to respect the cultural diversity of the environment in which we operate.

For this, let’s individually:

  1. Be active in understanding the business and our suppliers’ motivation to co-ordinate better and forge efficient, competitive and responsible relations.
  2. Strive for our work to be performed with special care of our environment and its sustainability, taking care of and efficiently using natural resources by preserving and safeguarding them.
  3. Consider the interests and values of the communities where we operate to act respectfully and make a contribution to them.
  4. Only give gifts or make invitations that suitably represent the company’s institutional image and which are in accordance with the Corporate Gifts Policy. We shall not accept gifts or invitations that affect our professional or personal independence and objectiveness.


Q: “I’ve noted that no maintenance has been undertaken on the vessels for some time and I’m worried there might be an oil spillage. Is there anything I can do?”

A: As a company we’re concerned about the impact of our activities on the environment, so we value the proactive attitude and alert of our employees. Consult your team about the action that can be taken in this case and if you still have doubts, you can raise them on the Ethics Platform.


Q: “The company has just launched a tender process because we need a new freight supplier. My brother-in-law has a small company in this sector and I think it would be a very good opportunity for him to work with us. I know details of the tender that would undoubtedly help him. What should I do?”

A: You should not provide insider information about the tender, as that would jeopardise free and healthy competition. It’s important to let your boss know you have a relative who will apply to the tender, as there could be a possible conflict of interest.

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5. An activity pursuant to our law

We comply with the regulations and good practice expected of the industry.

To such effect, it is our interest as an organisation to:

  1. Make sure there is compliance with the law: let’s make sure we get to know the laws, regulations and standards related to our activities to embrace and promote good practice so our operations comply with the legal regulations and provisions.
  2. Be transparent: let’s collaborate with investigations by the authorities, assuring the truthfulness of the reporting processes and keeping records with high standards of accuracy.
  3. Establish policies and procedures guaranteeing that all those who use this Handbook have the training needed to understand, apply and honour the responsibilities in accordance with the company’s policies and principles.
  4. Take timely action when there are reports of breach of the law or the company’s current policies, and also to manage the conflicts of interest that might arise in accordance with current legislation, making sure at all times not to disclose the identity of the person reporting such conduct.

For this, let’s individually:

  1. Take care to find out and comply with the regulations on our work, acting with diligence and duly advised on the exercise of our rights and respecting the rights of others as we would like ours to be respected, at all times complying with and enforcing the company’s principles and values, laws, rules and regulations applicable to the activities we undertake.
  2. Act transparently in internal and authority investigations, seeking to collaborate, provide reliable information and learn to avoid inappropriate situations.
  3. Never adopt conduct that might give rise to the company being charged criminally pursuant to Law 20.393, for offences of asset laundering, financing of terrorism and bribery of a national or foreign public official, nor criminal or reproachable conduct that might harm the image of the company or of other people working in the company.
  4. Report any infringement of this Handbook, of the company’s policies or illegal conduct that has occurred or there is a risk of occurring within the company to the area manager, to the Ethics Committee, or on the query and whistleblowing website platform, as the case may be, who shall not disclose the identity of the person reporting such conduct.


Q: “During an inspection this morning, a Customs official insinuated that if we paid him an amount of money, we could get faster Customs clearance over the border. Our delivery timescales are very tight and we’re worried that the inspection could take longer. What should we do?”

A: On no account will we pay a public official to fast track a process. Bribery is an offence penalised by law and as a company we shall always seek to comply with it.


Q: “We’re on the verge of closing a major deal, but just need to comply with certain administrative proceedings. As the progress advances, I’ve received a reply that more information was missing to get the corresponding approval. I think if I take an alternative path and consult someone else I could get the signature I need quicker”.

A: It’s vital to follow the processes established for our work, as they’ve been designed to assure that our operations are in line with the law on our industry. When we’re asked for further information, it’s important to resolve those doubts before resorting to other alternatives that might seem easier but later on could harm the company. We must always look for the right advice, although this sometimes entails an additional cost or time.

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Our ethics management system

Our company has implemented mechanisms to guarantee that what is laid down in the Ethics Handbook remains in force for daily work. It has established a structure to receive and answer queries by customers, suppliers and employees and thereby detect situations early on that could endanger our values and principles.

We have a team of people specially trained to deal with the queries and reports about the integrity of our company. This support structure consists of an Ethics Committee and a Person in Charge of Preventing Offences and Ethics.

We have made available different channels so any customer, supplier or employee can raise their concerns, with the assurance that the issues will be duly logged, investigated and resolved, all this guaranteeing confidentiality throughout the process.

Ethics Platform – Query and Whistleblowing Website:

This enables people to make ethics queries and present cases to the person in charge 24 hours a day confidentially and anonymously. Using a high security alphanumeric password, people can follow up their query and maintain communication, even when their requirement has been resolved anonymously. This platform can also be used by customers, contractors, consultants and suppliers.

Direct Contact:

We advise you that if possible you approach your boss or someone of trust to talk directly, either in your offices, calling directly or by email.

Each director, executive and employee of Ultramar Agencia Marítima must know and accept this Ethics Handbook.

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Status of whistleblowing reports and queries