Operation

By means of this Ethics Management Platform you can make queries or whistleblowing reports about doubts, dilemmas or situations of an ethical nature that arise from the activities of our company.

Queries are those questions or doubts about how a value or provision of the Ethics Handbook should be applied. On the other hand, whistleblowing reports provide information on situations that breach the guiding principles contained in the Ethics Handbook. The element distinguishing queries from whistleblowing reports is the time when they occur. Queries are ideas or presentations on hypothetical events or those that have not occurred, and whistleblowing reports are on events that are occurring or have already occurred.

This Ethics Management Platform is available 24 hours a day throughout the year and enables you to make a query or whistleblowing report simply and anonymously, if you so wish. This anonymity is safeguarded by an external system, which has computer servers located in Canada and to which nobody in our company can gain access.

If you decide to reveal your identity, all the necessary safeguards will be taken to maintain the privacy and confidentiality of the query or the case you are raising, and it is essential for the success of the investigation and to safeguard the protection of people that you too maintain your query or whistleblowing report confidential, without disclosing or commenting on it to others.

If you have a query or whistleblowing report, we ask you to follow the procedure below that entails a few steps which will take about 10 minutes:

1. Enter the website www.eticaultramar.cl
2. From the buttons on the right, select the option “file a whistleblowing report” or “make a query” according to the nature of what you want to raise.
3. Select whether you want to file the case anonymously or confidentially, and if you choose this latter option provide the information requested.
4. Fill out a form with the information you want to raise. If it is a query, you should simply ask your question. If it is a whistleblowing report, you should select a category to classify the situation you are going to raise and then fill out a form on which you can provide the information for the investigation.
5. When you have made your query or provided information for your whistleblowing report, the system will give you an identification number and a one-time password, which will help you follow up on what you have raised. Remember to note it down in a safe place.

Whistleblowing reports received and analysed, depending on their complexity, will undergo an investigation process of no more than 20 days. If the complexity so warrants, this term can be extended sufficiently to gather all the necessary information and decide on corrective action, even with the participation of external bodies, if the case so requires.

The investigation process of a whistleblowing report shall abide by the following principles:

• We shall promote a fair, rational, timely and transparent investigation with guarantees of impartiality and fairness for the whistleblower and accused.
• The anonymity of the whistleblowing report is a legitimate option and we shall safeguard it.
• We shall keep all the information gathered in the investigation confidential, and it is strictly prohibited to disclose it.
• We shall try and make progress with the investigation quickly, timely, confidentially and effectively.
• The principle of innocence shall be present in the investigation right from the outset and during the process, so all people shall be considered innocent until proved otherwise.
• The company will not tolerate or accept any kind of reprisals or action against an employee, supplier or customer who files a whistleblowing report or participates in the investigation process, which harms their employment, the provision of services or their commercial relations with the group of companies.

We have a specially trained team to safeguard the correct operation of our Ethics Management System:

Ethics Committee: this is a resolution body comprising representatives of the board of directors and the general coordinator. This Committee is in charge of safeguarding the impartiality and correct operation of the Ethics Management System, including implementing action regarding the Offence Prevention Model. The function of the Ethics Committee is to provide guidelines for those situations that are unregulated and globally review those cases or queries to create guidelines to prevent the most frequent ethical dilemmas.

General Ethics Coordinator and Person in Charge of Offence Prevention: he is in charge of receiving and dealing with those cases or whistleblowing reports sent by company employees and launching investigations, whenever necessary. In our company Mauricio Sepúlveda Mestre will be in charge of making sure the Ethics Management System operates timely, based on the guiding principles contained in our Ethics Handbook and the Offence Prevention Manual.