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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

 

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.

2.Shareholders

 

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.

3.Customers

 

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.

4.Suppliers

 

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.

5. Community

 

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.

Policies governing relationships

1.Conflicts of interest

 

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.

2.Activities outside SQM

 

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.

3.Improper influence

 

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.

4.Gifts or invitations

 

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.

Policies related to information management

1.Generation of
information

 

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.

2.Record keeping

  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.

3.Property of the
information

 

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.

4.Confidentiality of
information

 

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.

5.Use of privileged
information

 

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.

Policies related to the use of Company's assets

1.Obligations

 

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.

2.Allowed uses

 

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.

3.Use of electronic mail
and Internet

 

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.

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.

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