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Polymer Char Compliance Policy


1. INTRODUCTION

1.1 Company Overview

Polymer Char is dedicated to the development of state-of-the-art instrumentation for Polyolefin Analysis.

The company offers the broadest and most modern range of instruments and services for structural characterization of polyolefins, such as Gel Permeation Chromatography (GPC/SEC), Chemical Composition Distribution, Bivariate Distribution, High Temperature HPLC, Soluble Fraction determination, Quality Control, Intrinsic Viscosity measurement, Preparative Fractionation, and Infrared Detection.

Polymer Char is also well-known for its advanced approach into Virtual Instrumentation Software Architecture (VISA) which, together with excellent remote control capabilities and strong commitment to Customer’s success, places the company at the leading edge on instrumentation diagnostics and technical support.

Together with its network of partners and distributors, Polymer Char supplies, trains and supports Customers worldwide. The company provides analytical services to more than 35 countries, and its instruments are present today in over 25 countries within the Americas, Europe, Africa, Middle East and Asia Pacific, predominantly serving to Polymer Producers and Processors, Government and Contract Research Laboratories, and Universities that work on polymer research.

Over the last 27 years, and with an average annual investment of 26% of its manpower resources in R&D, Polymer Char has played a key-role in the development of most of the existing polyolefin characterization technologies, such as CRYSTAF, CRYSTEX, CEF, automated CFC and TREF, and GPC with IR detection. Each new project, and each new analysis, consolidate Polymer Char as The Polyolefin Characterization Company.

Today, in the area of polyolefin analysis, Polymer Char is recognized by its technical excellence, expertise and overall Customer commitment, together with high-quality solutions, transparency, integrity and good service.


1.2 Vision and Values

Polymer Char was born in the early 90s with a clear vision to become a best-in-class player in the polyolefin characterization field, by offering advanced and reliable instrumentation, analytical services and technical support. We carry out this pursuit of our vision with integrity, commitment to excellence, with innovation as driving force, and high respect to our employees, customers, suppliers, and the environment.


1.3 Quality Management Policy (summarized)

Polymer Char is a client-driven company. We know the purpose we serve: to provide advanced analytical solutions to the petrochemical and polymer research industries, so that they can get a deeper understanding of their products and processes, and develop more suitable polymers for each market application.

Polymer Char operates under a Quality Management System that incorporates ISO 9001 regulatory requirements, and provides a framework for measuring and improving our performance every day to result in products and services that meet or exceed customer expectations. To achieve and maintain this status, Polymer Char pursues excellence in all tasks and processes. Polymer Char employees take ownership of this behavior and are the integral members of a close team whose efforts are on continuous improvement.


2. CODE OF ETHICS

2.1 Message from Polymer Char’s Management

"Polymer Char was born by the end of 1992 to develop and commercialize innovative polymer characterization instruments.

Estabishing a company for the first time in my career, which has been devoted to science and technology, demanded from me quite some thoughts on what, and how I wanted to proceed. Following are the answers/values I felt would motivate me to lead this entrepreneurial journey:

  • 1) To operate with ethics, integrity, and fairness.
  • 2) Respect to individuals.
  • 3) Innovation-driven.

These values should be addressed with, what I consider, the most valuable tool: Commitment to a Continuous Improvement Process,applied in all projection areas of a company.

Along these 27 years of existence, Polymer Char has paid significant attention to the incorporation of new employees to the company, demanding integrity and responsibility above any other qualities of the individuals; this hiring effort resulted in an outstanding team, which has contributed to the development of a Culture of Ethics and Respect.

Today Polymer Char, being a well-established and respected company in the field of instrumentation, is proud of the ethical way in which it operates, the respect is shown to people and the environment, and still demand on doing things better every day. I can say the all of our employees are proud of this culture and we feel that our customers, distributors and providers, are also proud of participating in this with Polymer Char."

Dr. Benjamín Monrabal
Director and Founder

2.2 Scope

Our Code of Ethics is mandatory for all Polymer Char employees and also for Polymer Char official distributors, as they are representing Polymer Char in their countries.

The term “employee” also includes temporary staff and interim students. Exemptions from this scope are only permitted if specifically mentioned.


2.3 Commitment to Integrity

The policy of Polymer Char is to comply with all governmental laws, rules, and regulations applicable to its business, but not only limited to that; Polymer Char has a solid philosophy of integrity, honesty and transparency, and it is proud of having this reputation among its network of customers, partners and suppliers. In Polymer Char‘s internal culture, bribery, corruption or any other non-ethical practice will never be tolerated, and no Polymer Char employee will suffer demotion, penalty, or other adverse consequences for refusing to pay bribes, or acting out of this code of Ethics, even if such refusal may result in the enterprise losing business.


2.4 Competition Laws (Antitrust)

One of the most fundamental competition law principles is that all companies in the marketplace act independently of their competitors. Polymer Char or its Official Distributors will not enter into any agreements or understandings with competitors to:

  • Fix sale or purchase prices (“price-fixing”);
  • Fix other terms of sale or purchase;
  • Restrict capacity or output;
  • Refrain from supplying a product or service;
  • Limit quality competition or research;
  • Divide markets or customers; or
  • Exclude competing firms from a market.

All Polymer Char employees and Official Distributors are expected to comply with the antitrust and competition laws of the European Union and with those of any other country or group of countries that are applicable to Polymer Char‘s business.

It is recognized that, on occasion, there may be legitimate doubt as to the proper interpretation of the law. In such a circumstance, it is required that employees or Official Distributors report the case to the company‘s management for advice.


2.5 International Trade Controls and Official Distributors Dealing

Polymer Char handles its sales and exportations directly in most of the countries worldwide, without any intermediate or third party in between our company and the end-user of our products. Therefore, Polymer Char takes full control of shipment documentation, end-user contacts, installation addresses, tariff codes, and all applicable regulations related to export/import in Spain and European Union (EU).

Polymer Char counts on Official Distributors in specific countries in the world. These distributors are aware of Polymer Char‘s compliance policy through a distribution agreement signed by both parties. In such agreement, Polymer Char‘s Official Distributors commit to complying with applicable Spain, European Union (EU) and other international laws and regulations for export and import.

Polymer Char third parties‘ relationships are based on lawful, ethical and fair practices. Polymer Char will do business only with those distributors who comply with applicable laws, including employment, environmental, and health and safety laws. The integrity of our distributors‘ dealings is fundamental to building and preserving the reputation of Polymer Char.


2.6 Anti-Corruption Code of Conduct

Definition of Bribery
Bribery is offering, promising or giving, as well as demanding or accepting any pecuniary or other advantage, whether directly or indirectly, in order to obtain, retain or direct business to a particular enterprise or to secure any other improper advantage in the conduct of business. Instances of bribery which are the subject of these principles may involve transactions by, or in relation to, subsidiaries, joint ventures, agents, representatives, consultants, brokers, contractors, suppliers or employees with (including but not limited to) a public official, family members and close associates of a public official, a political candidate, party or party official, any private sector employee (including a person who directs or works for a private sector enterprise in any capacity), or a third party.

Definition of money laundering:
Money laundering can take several forms:

  • Handling the proceeds of crime (e.g. tenancy, Welfare Benefit and Right to Buy fraud).
  • Direct involvement in criminal or terrorist property activity.
  • Entering into arrangements that facilitate other people to commit laundering of criminal or terrorist property, money or assets.
  • Investing the proceeds of crime into other financial products or into the acquisition of other property/assets.

Polymer Char is committed to the highest ethical standards and good governance. It has adopted a zero-tolerance policy to all forms of fraud, bribery and corruption, including money laundering. Polymer Char prohibits those conducts in any form and in all business transactions that are carried out directly or through third parties, including official distributors, consultants, brokers, contractors, suppliers or another intermediary under its effective control.

All Polymer Char employees must report about any of these conducts, bribes or other improper payments for the purposes of promoting Polymer Char Products sales to any individual, corporation, government official or agency, or other entity. No gift, benefit or contribution in any way related to Polymer Char or the sale of Polymer Char Products shall be made to political or public officials or candidates for public office or to political organizations, regardless of whether such contributions are permitted by local laws.


2.7 Polymer Char and its employees

Polymer Char encourages and supports its employees to maximize their talents and be fully-committed to the Company‘s mission while offering a collaborative and challenging work environment, where everyone can breathe from the philosophy of feeling and acting as a team and helping each other. Human capital is one of Polymer Char‘s pillars, actively supported by the company‘s management, which promotes a communicative, transparent, and ethical working environment.

Polymer Char values social diversity and acts as an equal opportunity employer. Employees have the right to work in an environment free of harassment or any other form of behavior that violates personal integrity. Any kind of harassment must be reported to management members, who will determine the penalties to be applied.


2.8 Proper use and protection of Polymer Char‘s assets and Polymer Char‘s information

All Polymer Char employees are responsible for using Polymer Char‘s assets appropriately and protecting them against careless or wrong use, theft, loss, damage, waste, misappropriation and infringement. Assets, both tangible and intangible, are to be used only by authorized persons. Intangible assets include intellectual property, such as research and development information, commercial information, patents, trademarks and copyrights. Tangible assets include buildings, equipment, communication facilities (personal computers, telephones, …) and supplies.

Employees and Official Distributors must safeguard confidential, proprietary or material information about Polymer Char, and information that any partners, customers, providers or other contracting parties may have supplied.

The obligation to protect confidential and proprietary information extends beyond the workplace and also includes communications with friends or family members, and continues to apply even after the membership of employment or distribution with Polymer Char has been terminated.


2.9 Conflicts of Interest

Conflicts of interest may arise when private interests of an individual or of his/her close relatives, friends or business contacts diverge from those of the Enterprise or organization to which the individual belongs. These situations should be disclosed and, whenever possible, avoided because they can affect an individual‘s judgment in the performance of his/her duties and responsibilities.

Polymer Char monitors and regulates actual and potential conflicts of interest, and the appearance thereof, of their employees and does not take advantage of conflicts of interest of others.

Polymer Char‘s Official Distributors have signed an agreement in which they state that they will always reveal all information pertaining to possible conflicts of interest created by the sale of competing products or services, or arising from other positions or contracts and represent that no conflict of interest exists. Distributors are obliged by contract to disclose to Polymer Char any future circumstances which could create possible conflicts of interest as soon as they become known by the Distributor. Without limiting the generality of the foregoing, Distributors are required to inform Polymer Char of any business relationship, circumstance, or situation which prejudices in any way the conduct of gateway marketing activities according to the highest ethical and business standards, or place Distributor or Polymer Char in any kind of disreputable or embarrassing situation.


2.10 Reporting Compliance Concerns

Polymer Char employees and Polymer Char Official Distributors are committed to integrity and to the best business practices, and must report immediately about any violation of this code. Polymer Char employees and Polymer Char Official Distributors shall abide by all Polymer Char policies and standards regarding conflicts of interest and ethics as may be adopted by Polymer Char.

Polymer Char is in compliance with the FCPA, the UK Bribery Act and/or any other local law pertaining to anti-bribery or anti-corruption in Spain and the European Union. Polymer Char Official Distributors are subject to compliance reviews to ensure that they fulfill the compliance standards and export control requirements.


2.11 Financial and Accounting

Polymer Char ensures that:

  • All financial transactions are adequately identified and properly and fairly recorded in appropriate books, and accounting records are available for inspection by Management as well as by auditors.
  • There are no “off the books” or secret accounts.
  • There is no recording of non-existent expenditures or of liabilities with incorrect identification of their objects or of unusual transactions which do not have a genuine, legitimate purpose.
  • Cash payments or payments in kind are monitored in order to avoid their use as bribes.
  • No bookkeeping or other relevant documents are intentionally destroyed earlier than required by law.
  • All provisions of national tax laws and regulations are complied with, including those prohibiting the deduction of any form of bribe payment from taxable income.

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“Innovation, Quality and Continuous Improvement have been at the Polymer Char vision from the early days. Polymer Char pursues excellence in all tasks and processes. Polymer Char employees take ownership of this behavior and are the integral members of a close teamwork effort towards continuous improvement and we are proud to have made a culture out of it.”


Dr. Benjamín Monrabal
Founder and Managing Director