INTRODUCTION
At METALAB S.A.C, we are committed to providing services with the highest quality standards, fostering and demanding ethical behavior in all areas and in every one of our activities. This document has been developed to promote and raise awareness within our team about our principles, commitments, and culture of respect towards those with whom we interact in various ways and interests.
We firmly believe in the importance of working with integrity and refuse to compromise on ethics in our processes and relationships. In this regard, this Code is directed to all of our employees, without distinction based on their roles or functions, thus confirming and promoting a conduct and behavior grounded in our core values and principles.
This Code of Ethics outlines our perspective and what we expect from each position in their activity and interactions with the organization’s different stakeholders.
MESSAGE FROM MANAGEMENT
At Grupo Aurica, we believe that a significant part of our success and continuity is due to the deeply ingrained culture of values shared among the founders, executives, and employees of our business group. This culture represents a collective spirit that not only governs and directs our policies and procedures but also, and most importantly, guides our daily actions.
"This Code of Ethics and Conduct serves as the foundation of our business conduct, developed within the framework of the United Nations Guiding Principles on Business and Human Rights. It reflects our commitment to respect, equality, honesty, integrity, and our unwavering belief in the fundamental rights of individuals, aiming to contribute to the development of a more prosperous, equitable, and just society."
1. SCOPE
The Code of Ethics is directed to all employees of METALAB S.A.C. without distinction, as well as to contractors who are part of our processes.
It is important to emphasize that this Code of Ethics and Conduct, the Internal Work Regulations (RIT), and all policies and directives implemented within our management system are mandatory, as applicable to each of our stakeholders.
2. OBJECTIVE
• To establish guidelines and directives that ensure the proper conduct of all METALAB S.A.C. team members at all levels in the performance of their activities.
• To strengthen our principles focused on respecting human rights, the environment, and society.
• To promote a culture of ethical conduct and commitment to organizational values, as well as compliance with the organization’s policies.
• To provide clear information that allows all employees to understand the codes, regulations, and organizational policies, and to raise awareness of these and act in compliance with the guidelines, with the ability to report any act that violates the established ethics.
3. MISSION, VISION & CULTURAL PRINCIPLES:
MISSION
To create value across the precious metals value chain through the responsible development of businesses, operations, and reliable solutions, contributing to the growth of our customers, employees, and communities.
VISION
To be Latin America's leading reference in the precious metals industry, globally recognized for the reliability and excellence of our processes, products, and services.
CULTURAL PRINCIPLES:
• Integrity: We act with honesty, transparency, and consistency in every decision, strengthening trust in our relationships and everything we do.
• Safety: We protect people, operations, and the environment by fostering a culture of prevention and continuous care.
• Excellence: We continuously improve our processes, products, and services to achieve the highest standards of quality and performance.
• Accountability: We honor our commitments with responsibility and take ownership of our actions and results.
• Results orientation: We work with focus, efficiency, and discipline to achieve our objectives and create sustainable value.
• Teamwork: We collaborate, share knowledge, and combine our strengths to achieve better results.
• Respect: We value people and foster relationships built on dignity, inclusion, and fairness.
• Every customer is unique: We understand the specific needs of each customer and provide reliable solutions that create value and foster long-term relationships.
4. ETHICS WITH OUR STAKEHOLDERS
4.1 WITH OUR EMPLOYEES
• Equal Opportunity and Non-Discrimination: We promote equal employment opportunities for those applying to METALAB S.A.C and support the professional development of our employees, regardless of race, gender, religion, sexual orientation, age, or any other personal characteristic, based on merit and ability.
• Safe Work Environment: The physical and mental well-being of our employees, as well as the safe execution of operations, is of utmost importance to the organization. We strictly adhere to the guidelines set forth in the Internal Regulations on Occupational Safety and Health.
• Workplaces Free from Harassment and Violence: We are committed to offering harmonious workplaces free from any form of violence, aggression, intimidation, or similar behaviors that could undermine employee tranquility. We promote interpersonal relationships based on respect.
• Rejection of Forced, Child Labor, and Discrimination: We reject any practice considered as forced, child labor, or discriminatory, adhering to legal regulations and establishing internal procedures and policies that respect human and children's rights, as well as individual well-being and the freedom to work.
• Respect for Employee Rights: We comply with our obligations towards our employees and respect the rights accorded to them under agreed terms.
• Protection of Personal Data: We responsibly manage the information provided by our employees and respect the right to privacy and dignity. The processing of data will be limited to its intended purpose and respective databases.
• Conflicts of Personal Interest: We recognize personal interests as those that benefit an employee or their family members in a professional or financial manner. Therefore, we do not allow personal interests to take precedence over the company’s established norms, directives, policies, decisions, or procedures.
• Gifts, Favors, and Courtesies: We neither accept nor offer gifts, favors, or similar items that, due to their value, may influence a work decision or create conflicts of interest.
• Rejection of Corruption, Bribery, and Fraud: We reject all corrupt or dishonest acts, as well as those related to money laundering or the financing of terrorism, and we operate transparently in all our activities.
• Proper Use of Company Resources: Company assets such as laptops, mobile devices, ID cards, email accounts, telephone extensions, vehicles, and other similar resources, including facilities, should be used exclusively for work-related activities. Proper use and timely return of these assets are essential to maintaining the company’s integrity and operational efficiency.
4.2 WITH OUR CLIENTS AND SUPPLIERS
• We treat all our clients and suppliers with respect and professionalism, regardless of their size, location, or influence.
• We respect the confidentiality of information shared by our clients and suppliers and protect sensitive information, ensuring it is not used improperly or without authorization.
• We require our suppliers to comply with all local and international laws and regulations in their operations and develop business relationships based on respect and trust.
• We are committed to acting with integrity in our contractual negotiations and negotiate fairly, avoiding any form of corruption, bribery, or anti-competitive practices.
• We foster client loyalty through our commitment to delivering high-quality services, fulfilling commercial agreements, and providing truthful and transparent information.
• We establish procedures that enable the impartial selection of suppliers, maintaining objectivity in our commercial decisions.
• We provide timely and fair solutions, promoting open dialogue with respect, seeking mutual benefit.
4.3 WITH SOCIETY
• We respect and promote human rights in all our operations, ensuring that our practices do not contribute to the exploitation or abuse of individuals.
• We strive to create employment opportunities and foster professional development for members of society.
• We ensure that our practices are responsible and ethical, avoiding harm to the environment.
• We conduct our activities in compliance with the legal framework, without violating human rights.
5. COMMITMENTS TO SUSTAINABLE DEVELOPMENT
At METALAB S.A.C., we are deeply committed to the sustainable development of all our operations. We recognize our responsibility and the importance of acting ethically and consciously.
• Environmental Protection: We commit to minimizing the environmental impact of our activities through the implementation of responsible and sustainable practices. This includes the efficient use of natural resources, reducing emissions and waste, and promoting and training on environmental care.
• Social Responsibility: We strive to contribute positively to social and economic development. This is reflected in our hiring policies, the development and growth of our employees, and respect for human rights.
• Responsible Supply Chain: We assess our suppliers based on their commitment to social and environmental responsibility.
• Innovation and Continuous Improvement: We are committed to constant innovation in our operations, seeking new ways to make our practices more sustainable and efficient.
6. COMMITMENTS TO HUMAN RIGHTS
It is fundamental for us that, in every execution or development of activities at METALAB S.A.C., human rights are protected.
• Respect for human rights is non-negotiable: We reaffirm our commitment to respecting the human rights of all individuals who, directly or indirectly, are connected to our organization as employees, suppliers, clients, and the community at large.
• Prohibition of Child and Forced Labor: We strongly reject child labor and forced labor at any stage of our operations. We ensure compliance with all labor rights of our employees and treat them with dignity.
• Non-Discrimination and Inclusion: We promote equal opportunities and employment promotion, as well as non-discrimination in our labor practices. We are committed to creating an inclusive work environment where all individuals are treated with respect, regardless of race, gender, religion, sexual orientation, or other factors.
7. COMPLIANCE, REPORTING, AND SANCTIONS
This Code of Ethics establishes the general principles of how employees should conduct themselves in their activities at METALAB S.A.C. While not all situations that an employee may encounter are explicitly described, it serves as a guide to understanding what is expected of each individual. By having this information, we become regulatory agents; therefore, any irregular acts or suspicions of non-compliance with the Code of Ethics must be reported promptly to Human Resources or General Management. All reports must be made in good faith and with due loyalty to the company.
METALAB S.A.C. commits to maintaining the confidentiality and anonymity of communications or reports, ensuring that no retaliation will result.
Sanctions for employees will be determined based on the disciplinary measures outlined in the Internal Work Regulations, depending on the severity of the case.
- CODE OF ETHICS AND CONDUCT | SECTION 2
INTEGRITY IN OUR BUSINESS
At Metalab, we conduct our business with integrity, transparency, and in compliance with legislation and our internal provisions. Our decisions must respond to objective criteria and the legitimate interests of the organization, avoiding any situation that may compromise our impartiality, independence, or reputation.
We do not tolerate unlawful, fraudulent, or conduct contrary to our principles, even when it could represent a benefit for the organization or facilitate the achievement of an objective.
CONFLICTS OF INTEREST
A conflict of interest arises when a person’s personal, family, economic, or professional interests may interfere, or create the appearance of interfering, with the objective fulfillment of their responsibilities at Metalab.
We must all act with transparency and avoid situations in which our particular interests may improperly influence an organizational decision. Therefore, we must:
• Promptly report any actual, potential, or apparent conflict of interest.
• Refrain from participating in decisions in which our personal interests may compromise our objectivity until the situation has been evaluated.
• Not use our position, authority, or information obtained in the performance of our duties to obtain improper benefits for ourselves or third parties.
• Disclose personal, family, commercial, or economic relationships that may influence decisions related to customers, suppliers, contractors, employees, or other third parties linked to Metalab.
The existence of a conflict of interest does not, in itself, constitute improper conduct. However, concealing it, failing to report it promptly, or acting by prioritizing particular interests over those of the organization may constitute a violation of this Code. In case of any doubt, the situation must be reported before making a decision or taking the corresponding action.
GIFTS, HOSPITALITY AND COURTESIES
Gifts, invitations, hospitality, and business courtesies may form part of legitimate business relationships; however, they must never be used to improperly influence a decision, obtain an advantage, create an obligation, or compromise the objectivity of the recipient.
At Metalab, gifts, hospitality, or courtesies may only be offered or accepted when they are reasonable, occasional, appropriate to the context of the business relationship, and consistent with applicable legislation and internal provisions. The following are not permitted:
• Offer, request, or accept cash or cash equivalents.
• Offer or accept gifts, invitations, or benefits that seek to influence or could reasonably be perceived as an attempt to influence a decision.
• Request gifts, favors, discounts, services, or personal benefits from customers, suppliers, or other third parties as a result of our position in the organization.
• Offer or accept hospitality that may compromise our independence, objectivity, or reputation.
• Use third parties to deliver or receive a benefit that would not be permitted if carried out directly.
Special attention must be paid to any gift, invitation, or courtesy offered or received during negotiation processes, supplier selection, contracting, evaluation, oversight, or other situations in which a pending decision exists.
In case of any doubt regarding the acceptance or offering of a gift, hospitality, or courtesy, the appropriate authority must be consulted beforehand.
ANTI-CORRUPTION AND BRIBERY
At Metalab, we maintain a zero-tolerance policy toward any form of corruption or bribery. We conduct our activities and business relationships with integrity and transparency, without resorting to improper practices to obtain benefits, advantages, or preferential treatment.
• We do not make improper payments to facilitate or expedite procedures, permits, authorizations, or other processes.
• We do not use intermediaries, representatives, advisors, or other third parties to carry out acts that would be prohibited if performed directly by Metalab or its employees.
• We do not accept requests for improper payments or benefits, even when refusing them may result in the loss of a business opportunity or cause a delay in a process.
• We record operations and transactions truthfully, completely, and transparently, without concealing payments, benefits, or concepts different from their true nature.
• We promptly report any request, offer, suspicion, or situation that may be related to an act of corruption or bribery.
• In any situation that raises doubts, guidance must be requested before carrying out or authorizing the corresponding transaction.
PREVENTION OF FRAUD, MONEY LAUNDERING AND TERRORIST FINANCING
At Metalab, we reject and prevent any form of fraud, money laundering, terrorist financing, or other illicit activity that may compromise the integrity of our operations.
We develop our business relationships by applying the knowledge, evaluation, and due diligence processes established by the organization, with particular attention to the identity and activities of our counterparties, the legitimacy of transactions, and, where applicable, the origin of funds and metals related to our activities.
All employees must act diligently and comply with the controls established to prevent Metalab, its operations, or its supply chain from being used directly or indirectly for illicit purposes. In particular, we must:
• Comply with the applicable knowledge and due diligence procedures for customers, suppliers, and other counterparties.
• Verify and maintain the documentation and information required to properly support transactions.
• Not alter, falsify, conceal, or provide information or documentation that could mislead regarding an operation, counterparty, or transaction.
• Remain alert to unusual transactions, behaviors, or circumstances that may constitute warning signs.
• Not continue, approve, or facilitate a transaction when there are observations or alerts that require prior evaluation in accordance with established procedures.
• Promptly report any irregularity, inconsistency, suspicion, or warning sign through the appropriate internal channels.
• Cooperate with the applicable review, control, and investigation processes.
Preventing these behaviors is everyone’s responsibility and constitutes an essential condition for protecting the legality, integrity, and reputation of Metalab.
RESPONSIBLE USE OF THE ORGANIZATION’S ASSETS AND RESOURCES
Metalab’s assets and resources are intended for the development of its activities and must be used responsibly, efficiently, and in accordance with applicable internal policies and provisions.
We are all responsible for protecting the assets under our use, administration, or custody, avoiding their loss, deterioration, improper use, or exploitation for unauthorized purposes. This responsibility includes, among others, facilities, equipment, tools, vehicles, electronic devices, systems, email accounts, information, documents, funds, and other physical or digital resources of the organization. In particular, we must:
• Use Metalab’s assets and resources primarily for purposes related to our duties and in accordance with the corresponding authorizations.
• Protect them against loss, damage, theft, misuse, or unauthorized access.
• Not use resources, information, or our position within the organization to obtain improper personal benefits or favor third parties.
• Comply with the measures established for access to and use of systems, equipment, information, and other technological resources.
• Promptly report any loss, damage, theft, misuse, or situation that may compromise the organization’s assets.
• Return the assets, documents, access credentials, and other assigned resources when applicable or upon termination of the relationship with the organization.
Responsible use of our resources contributes to protecting Metalab’s assets, information, and continuity of operations.
INFORMATION, CONFIDENTIALITY AND RECORDS
Information is a fundamental asset of Metalab and must be used, protected, and managed responsibly. We must all preserve the confidentiality, integrity, and availability of the information we access as a result of our duties.
Confidential, restricted, or sensitive information belonging to Metalab, its employees, customers, suppliers, and other third parties must not be disclosed, used, or shared without authorization, except when there is a legal obligation or when it is appropriate to do so in the authorized performance of our duties. In particular, we must:
• Access only the information necessary for the performance of our duties and use it for authorized purposes.
• Protect documents, files, systems, credentials, and other means containing information belonging to the organization or third parties.
• Not share confidential information with unauthorized persons, inside or outside Metalab.
• Not use information obtained as a result of our duties for personal or third-party benefit.
• Prepare and maintain records, reports, documents, and communications in a truthful, complete, and accurate manner.
• Not falsify, alter, conceal, improperly destroy, or manipulate information for the purpose of misleading, concealing a situation, or changing the true nature of a transaction.
• Promptly report any loss, unauthorized access, improper disclosure, or situation that may compromise the security or confidentiality of information.
The obligation to protect confidential information remains in effect even after the employment, commercial, or professional relationship with Metalab has ended, in accordance with applicable legislation and commitments.
COMPLIANCE, REPORTING AND SANCTIONS
Compliance with this Code of Ethics and Conduct is the responsibility of everyone who is part of Metalab. Each person must know its provisions, act in accordance with them, and contribute to promoting a culture of integrity and compliance within the organization.
This Code does not intend to cover every situation that may arise in the course of our activities. When there are doubts about how to act, we must seek guidance before making a decision that could contravene legislation, this Code, or Metalab’s internal provisions.
DUTY TO REPORT
Any person who has knowledge or a reasonable suspicion of conduct that may constitute a violation of this Code, Metalab’s policies, or applicable legislation has the responsibility to promptly report it through the channels established by the organization.
Reports must be made in good faith, providing the available information honestly and responsibly. It is not necessary to have all the evidence or certainty that a violation has occurred to communicate a reasonable concern.
CONFIDENTIALITY AND NON-RETALIATION
Metalab will treat reports received with due confidentiality and will protect the identity of the persons involved to the extent permitted by legislation and necessary to conduct an appropriate assessment or investigation.
We do not tolerate any type of retaliation against a person who, in good faith, communicates a concern, reports a possible violation, or participates in an investigation. Retaliation constitutes, in itself, a violation of this Code and may result in the corresponding measures.
The protection granted to good-faith reports does not cover deliberately false reports, information provided maliciously, or actions intended to unjustifiably harm another person.
EVALUATION AND INVESTIGATION
Reports will be evaluated objectively, impartially, and responsibly, in accordance with the nature of each case and the procedures established by Metalab. All persons involved must cooperate with the applicable internal reviews or investigations, providing truthful information and preserving the confidentiality of the process.
CONSEQUENCES OF NON-COMPLIANCE
Non-compliance with this Code, internal policies and provisions, or applicable legislation may result in disciplinary measures, according to the seriousness of the conduct, the circumstances of the case, applicable labor regulations, and the Internal Work Regulations.
Where applicable, Metalab may additionally take the legal, contractual, or administrative actions that may apply. Measures will be evaluated objectively and proportionally, respecting the applicable procedures and rights.
CSMS POLICY
Senior Management of METALAB S.A.C., a company engaged in the export of gold and silver bars, recognizes the security and integrity of its supply chain as fundamental elements for the development of its operations.
In this regard, it is committed to implementing, maintaining and continuously improving its BASC Control and Security Management System (CSMS) under a risk-based approach aimed at preventing illicit activities that may affect its operations, supply chain and international trade.
For this purpose, METALAB S.A.C. assumes the following commitments:
a) Supply Chain Security and Integrity: Establish and maintain guidelines, procedures and controls aimed at protecting the integrity and security of the processes that form part of the supply chain and gold and silver export operations.
b) Risk Management: Identify, assess, treat and monitor the risks associated with our operations and supply chain, establishing controls aimed at preventing and mitigating illicit activities, including corruption, bribery, money laundering, terrorist financing, drug trafficking, smuggling and other related crimes.
c) Regulatory Compliance: Comply with the legal, regulatory and other applicable requirements related to our operations and international trade, including those related to the prevention of money laundering and terrorist financing (SPLAFT).
d) Business Partners: Promote secure and reliable relationships with our business partners by applying selection, evaluation and monitoring criteria consistent with the identified risks and seeking their commitment to the principles of supply chain security and integrity.
e) Information Security and Cybersecurity: Protect the information and technological resources used in our operations through controls aimed at preserving their confidentiality, integrity and availability, as well as preventing and managing risks and incidents that may compromise information security.
f) Security Culture: Strengthen a culture of prevention and security through the training, awareness and participation of our employees and, where applicable, business partners and other relevant interested parties, regarding risks and controls related to supply chain security.
g) Objectives and Continuous Improvement: Establish, review and monitor measurable BASC CSMS objectives aimed at fulfilling the commitments established in this policy and continuously improving the effectiveness and performance of the Control and Security Management System.
This BASC Management Policy on Control and Security is communicated to all employees and is made available to business partners and other interested parties through the means established by the organization. It is also reviewed periodically to ensure its validity, suitability and alignment with the activities, risks and objectives of METALAB S.A.C.
