Code of Business Conduct
"SQM is committed to comply with applicable laws and regulations anywhere in
which the Company has operations, and to perform its activities in an ethical way.
This Code of Business Conduct provides policies, guidelines and principles that
must be fully complied with while executing our job. We, as SQM's employees, are
bound to act in accordance with this Code."
Patricio Contesse G.
Chief Executive Officer
SQM's Commitment
SQM's policies, as well as the actions of each of the Company's employees, must
be in line with and guided by the commitments described below and which SQM has
undertaken with respect to its own employees, shareholders, customers, suppliers
and the community.
1.Employees
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SQM is committed to give its employees a fair treatment, and to offer a workplace
that meets health and safety standards currently in effect.
Decisions on hiring are made on the basis of abilities and experience, and the evaluation
and promotion of employees is carried out considering their performance and the
fulfillment of their objectives.
SQM is against discrimination for reasons of gender, race, religion or political
affiliation.
SQM deems confidential all of its employees' personal information obtained during
the normal course of the professional relationship.
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2.Shareholders
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SQM is committed to deliver reasonable financial returns and to act for the benefit
of its shareholders in accordance with the guidelines provided by the Shareholders
Meetings and the Board of Directors.
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3.Customers
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SQM intends to meet its customers' needs through its products and services in accordance
with the quality and terms agreed with them.
SQM seeks to develop an honest and long-term relationship with its customers.
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4.Suppliers
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SQM seeks to develop an honest and fair relationship with its suppliers and contractors.
Purchasing decisions and the awarding of contracts are based on factors such as
price, quality, delivery and service.
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5. Community
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SQM undertakes to protect the environment associated with its operations through
a proper Environmental Management, meeting current environmental regulations and
the commitments set forth in the projects already included into the Environmental
Impact Assessment System.
SQM seeks to contribute with the improvement of the quality of life in the regions
in which it operates. Its social efforts are focused on the First and Second Regions
of Chile.
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Policies governing relationships
1.Conflicts of interest
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Employees shall always act in SQM's best interest and avoid situations that may
represent a potential conflict between the Company's interests and their own. There
is a conflict of interest when a personal interest interferes with those of the
Company in any way.
The Company's employees may not work for or advise competitors, suppliers, contractors
or customers of SQM, whether directly or indirectly. Also, they may not invest in
businesses of competitors, suppliers, contractors or customers of SQM or compete
with any line of business of the Company, directly or indirectly. No approval is
required for holding shares or bonds of companies of suppliers, contractors or customers
as long as they are open stock corporations.
SQM's employees shall report to their direct supervisor and to the Human Resources
Vice Presidency about working, managing or advisory activities performed by any
direct relative -by blood or affinity (parents, children, spouse, brothers, sisters,
parents in law and brothers and sisters in law)- for SQM's competitors, suppliers
and/or customers.
These activities will many times not represent an actual conflict of interest, but
every situation shall be reported and discussed in particular in order to prove
that said conflict does not exist nor will it exist in the future. It may be necessary
in some cases to reassign some duties in order to prevent any kind of conflict.
Any other potential conflict of interest should be reported to the direct supervisor
for its review.The description of the case and its resolution shall be sent to the
Human Resources Vice Presidency for its approval and later filing in the employee's
records.
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2.Activities outside SQM
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The duties ofthe employees at SQM require their whole dedication and commitment,
and in the case of full-time employees, their exclusive dedication. Any other activity
that an employee intends to perform, such as teaching, shall always be previously
approved by the Human Resources Vice Presidency.
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3.Improper influence
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SQM's employees are not allowed to ask for, receive or pay money or any kind ofdonation
to or from any supplier, customer or any other agency so as to be influenced by
or exert influence on such a third party.
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4.Gifts or invitations
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Gifts or invitations to dinners or events are attentions provided by suppliers or
partners in order to improve the business relationships. It is however important
to be sure that they do not affect the ability of taking good decisions for the
Company. These attentions, therefore, shall be legal, of low value and formally
reported to the direct supervisor and no commitment or special favor shall exist
in return.
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Policies related to information management
1.Generation of information
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Most employees must generally prepare certain types of report (expenses, production,
sales, inventories, quality control, environment and others). Said employees, although
not necessarily familiar with accounting or management principles, are bound to
make sure that all reports issued, whether internal - those used by SQM - or external
- those used by authorities and third parties - are reliable and complete.
The employees must take the necessary measures in order to be sure that the reports
issued are based on and contain true and complete information.
The existence of incomplete or biased information prevents to take good decisions,
undermines trust, damages SQM, its shareholders and employees and may even become
illegal.
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2.Record keeping
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There are specific requirements - according to every kind of operation or business
- as to which information to keep and for how long. It is important to know the
Company's policies and regulations in this respect, since the ignorance of them
may have legal or tax effects.
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3.Property of the information
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Any information or knowledge generatedin the development of the work belongs to
the Company.
Messages (voice mail), electronic mail and any other information found in the computers
are considered to be property of the Company and, therefore, they may not be considered
private. Unless prohibited by law, the Company reserves the right to access to and
disclose this information if necessary.
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4.Confidentiality of information
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The information generated in the Company is an asset of outstanding value. The protection
of this information is critical in order to maintain growth and capacity to compete.
Especially valuable and sensitive information is that related to:
- information about the market and businesses
- research
- strategies and objectives
- prices
- processes and formulae
- compensation and benefits
- software
- list of employees, customers and suppliers
Employees having access to such confidential information are bound to keep it confidential
and not to allow non authorized access to it. In fact, the following may not be
done:
- Disclosing this kind of information outside the Company. In this respect, employees
shall be especially careful when talking about the Company's businesses in such
public places as restaurants and planes.
- Using this information for the personal benefit.
- Disclosing this information to other employees, unless this is strictly necessary
for the performance of their duties.
The approval of Senior Management is required if there is the need to disclose information
outside the Company.
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5.Use of privileged information
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Employees that by means of their position or duties have access to privileged information
shall, even if they are no longer part of the Company, maintain strict confidentiality
and shall not use that information for their own or someone else's benefit, nor
shall acquire for themselves or for third parties, directly or indirectly, the securities
for which there is privileged information. Also, it is strictly forbidden to use
that privileged information to obtain profits or to avoid losses by using any type
of transaction involving the securities related to said information or by using
financial instruments whose profitability is determined by those securities. Similarly,
employees shall abstain from communicating that information to third parties or
from recommending the acquisition or selling of said securities, making sure that
the same applies to their subordinates or trusted third parties.
It is understood that privileged information is the reserved information referred
to in the law as well as any information related to SQM, its businesses or one or
more of the securities issued by the Company, not publicly disclosed, or which knowledge
-due to its nature- may affect the trading of said securities. Privileged information
shall also mean that information related to purchase and selling operations to be
carried out by an institutional investor in the stock market.
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Policies related to the use of Company's assets
1.Obligations
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All employees shall protect SQM's assets against any threat of destruction, theft,
robbery and improper use thereof. Said assets, including machinery, equipment, vehicles,
tools and computers, among many others, have been purchased or contracted with the
exclusive purpose of allowing the development of SQM's businesses and operations.
It may not be used for the personal benefit or sold, lent or rented without due
authorization. Taking SQM's assets without due authorization is a crime and a serious
breach of the employee's contractual obligations.
If an employee has any question on this subject, he/she must immediately contact
his/her direct supervisor or Human Resources. If an employee detects any improper
use of any Company asset, he/she must immediately report it to Human Resources.
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2.Allowed uses
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The occasional use of SQM's telephones or computers by its employees in subjects
that are not directly related to their duties, is permitted, provided that this
does not involve a cost for SQM and does not interfere with the employee's duties.
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3.Use of electronic mail and Internet
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Systems of electronic mail and Internet are available to the employees in order
to help them in their work. The occasional use of them for personal purposes is
allowed as long as the same does not involve a cost for SQM and does not interfere
with the tasks performed by the employee. In no case may those means be used for
personal profits or be used in an improper and illegal way. Access to, sending of
or downloading of any information which may be insulting or offensive to any other
employee is forbidden, as well as sending messages by e-mail against the law, the
moral and good manners.
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Other conflicts of interest and general questions
If an employee is not sure whether or not any particular action will result in a
violation of SQM's Code of Business Conduct, the employee shall immediately notify
his/her supervisor and the Human Resources local office. This office shall evaluate
the facts of the case and, in consultation with the Human Resources Vice Presidency,
submit an assessment with a proposed course of action that shall be delivered in
written to the employee. A copy of this resolution shall be filed to be used in
solving potential conflicts of interest or doubts of similar nature that may arise
in the future.
Sanctions
Any act in opposition to SQM's Code of Business Conduct will be subject to internal
review, may result in consequences that affect employment continuity, and could
possibly lead to external investigation, civil law proceedings, or criminal charges.