Code of Ethics

1.1 Scope of Application

The stipulations contained in this document establish the model of behavior expected from each of the collaborators belonging to Unibag, while setting the basic guidelines to be followed by managers, executives and workers in the performance of their duties.

This Code of Ethics does not intend to cover all possible situations that may arise in day-to-day business, and should therefore be considered as a guide that is complemented by common sense and the provisions of the laws, decrees, regulations and other legal instruments in force in each country where the Group operates.

1.2 Challenges

Unibag is a company that provides opportunities for decent work, which gives everyone the right to share in the progress and generation of quality jobs for the entire population, thus contributing to the reduction of the unemployment rate and improving productivity levels.

It also protects labor rights and promotes entrepreneurship, creativity and innovation, in addition to fostering the formalization and growth of micro, small and medium-sized enterprises.

To create an effective and transparent institution that promotes the reduction of corruption and bribery in all its forms.

Guarantee public access to information and protect fundamental freedoms, in accordance with national laws and international agreements, applying non-discriminatory policies in favor of sustainable development.

1.3 Complaints

Unibag has a whistleblower procedure that aims to provide information channels to its own employees, contractors, subcontractors, customers, suppliers, shareholders and any person who considers that he/she has witnessed the type of practices mentioned in the objective of this Procedure.

  • Mandatory

Reporting violations of the Code of Ethics or the Law is mandatory for all employees.

  • Immunity

Any reporting employee shall enjoy complete immunity from employment with respect to the matter reported, provided that he/she is not involved or implicated in the event.

  • Confidentiality

Any complaint or report will be guaranteed confidentiality and anonymity of the complainant by default, unless his or her identity is strictly necessary.

  • Resolute action

Unibag will act decisively with respect to any allegation of practices against the Code of Ethics or the Law.

  • Seriousness of the complaint

Unibag will not give rise to false allegations, reports or malicious disclosures of any kind and will take disciplinary action when this occurs, according to the seriousness of the allegation or malicious report.

1.4 Complaint procedure

If a whistleblower becomes aware of the occurrence of any fact that signifies a serious contravention or may violate or infringe Law No. 20,393, on Criminal Liability of Legal Entities, the Code of Ethics and/or any matter related to regulatory non-compliance, internal control and Financial Statements, the following procedure must be followed:

  1. The complainant, after careful consideration of the background information in his/her possession and in good faith, may file his/her complaint considering at least the following:
  • Description of the facts,
  • Place and reference dates,
  • Name or position of those involved.

  1. The complainant should use one of the following three options for reporting, taking into account considerations of confidentiality or anonymity:
  • Directly to the Ethics Committee
  • Through the anonymous form on the website, located at

  1. The Ethics Committee will receive complaints directly, by registered letter or by mail. If the complaint has merit, it is brought to the attention of the supervisor and/or management, and the investigation of the case is initiated. The maximum duration of this investigation shall be 1 month.

If the investigation has not been completed within one month, the Manager may request the Ethics Committee to extend the investigation.

If the Committee approves the extension of the investigation, it will be extended for a maximum of one more month. If it rejects the extension, it shall issue a report on the progress to date, stating its conclusions and recommendations.

  1. Once the time limit for the investigation has expired, the Ethics Committee shall issue a report with reasonable detail and a clear account of the facts.

This report should describe:

  • Complaint received;
  • Procedures used to conduct the research;
  • Documented research results;
  • Sanctions and/or proposed actions;
  • Recommendations to improve processes and procedures, as appropriate.

  1. The Ethics Committee will submit the reports to the Manager, who will review them and may approve or object to the recommended sanctions and/or corrective actions, which will be recorded in the final report.

  1. The Manager or the Controller shall submit the final reports to the Ethics Committee. The Committee shall sanction the cases and may approve or reject the proposed measures.
  • In case of approval, it will request the execution of the actions and/or sanctions indicated, or it may modify the sanctions or recommendations proposed.
  • In case of refusal, you may request that the investigation be restarted in whole or in part.

  1. Without prejudice to this procedure, the Ethics Committee or the Manager may always directly receive a complaint or order an investigation in relation to matters within its competence.

The complainant should consider the background carefully in order to present a description of the facts, place and dates of reference and the names and positions of those involved.

The ethics committee will define the corresponding sanctions and the General Manager will be notified.

The Committee shall sanction the cases and may approve or reject the proposed measures. If approved, it will request that the actions and/or sanctions indicated be executed, or it may modify the proposed sanctions or recommendations. In case of refusal, you may request that the investigation be restarted in whole or in part.

1.5 Ethics Committee

It will be constituted by 3 members which are the following: General Manager, Head of Human Resources, Commercial Manager, being part of its functions the:

  • To disseminate and promote the values and conduct set forth in this Code of Ethics.
  • Resolve any queries that may arise regarding its interpretation and application.
  • To hear, investigate and resolve any complaints that may be filed regarding actions that are not in accordance with its stipulations.
  • Propose to management the updating of its content.

1.6 Integrity

Always act in a responsible manner, especially preventing any form of corruption, bribery, extortion or bribery, whether by action or omission. In all circumstances, the interests of the company shall prevail over those of the individual.

1.7 Workers


Maintain a relationship with all employees based on mutual respect, deferential and non-discriminatory treatment, promoting professional development through merit recognition, competence assessment and objective performance evaluation.

Unibag recognizes the absolute freedom in the ideological, political, religious and philosophical aspects of each of its collaborators. However, respect for the dignity of all its collaborators and honest and measured conduct in their daily work will be required, not only in the exercise of their duties, but also in their social life as citizens.

Unibag employees must refrain from harassment or undue pressure on co-workers. This includes any kind of humiliating and humiliating treatment, without distinction.

Occupational Health and Safety

To recognize in Occupational Safety and Health values that must be safeguarded by practicing and promoting a preventive culture that stimulates prudent action and the habit of self-care, both for our own workers and those of collaborating companies.

Personal behaviors

The possession, sale and consumption of alcohol and illicit drugs on its premises is strictly prohibited. The toxic dependence is completely incompatible with the Company’s business activities, so it is an unavoidable obligation of all its members to contribute to prevent its penetration.

Harassment and Discrimination

Unibag is committed to not accepting sexual and/or labor harassment practices or conduct that leads to any type of discrimination.

Sexual Harassment

Labor relations shall always be based on treatment compatible with the dignity of the person. Sexual harassment, among other conducts, is contrary to this law. Sexual harassment is understood as when a person improperly makes, by any means, requests of a sexual nature that are not consented to by the person who receives them and that threaten or harm his or her employment situation or employment opportunities.

Mobbing or harassment at work

Unibag will not allow physical or psychological aggression practices, which can be devastating for the employees concerned.


Employees must not discriminate with respect to origin, nationality, political orientation, religion, race, gender, age or sexual orientation.

1.8 Anti-corruption

Unibag is against any kind of corruption, therefore, it does not make or accept bribes nor does it allow any other person to make or receive bribes on its behalf. Engaging in any form of corruption, including offering, promising, giving, accepting or soliciting payments for the purpose of obtaining commercial advantage is strictly prohibited.

Each employee is responsible for understanding and complying with all anti-corruption laws applicable to the activity performed.

  • Unibag payments will only be made for legitimate and legal purposes.
  • Money laundering will not be facilitated.
  • No business shall be conducted with a corrupt third party or one that is related to corrupt actions.
  • Violations, including case details, are reported to management.
  • The company terminates contracts with business partners who are in violation.
  • Influence peddling is strictly prohibited for all employees through gifts, trips or any other element considered bribery.
  • Financial and in-kind contributions to politicians, lobbying groups, donations for political purposes and sponsorships to groups pursuing political objectives are prohibited.
  • In the case of donations or community investments to charities or advocacy groups, all relevant stakeholders will be informed and publicly disclosed.
  • The company makes improvements to the anti-corruption program based on the cases reported.

1.9 Respect for the law in force

Unibag ensures that it complies with the laws and regulations in force in each of the countries where it operates.

Comply with and respect current legislation, as this is the fundamental reference framework for the actions of companies and individuals.

In particular, it must ensure respect for the provisions of the law on free competition, refraining from executing or participating in actions of any kind that hinder, alter or involve conduct that may be considered monopolistic in nature.

1.10 Conflict of interest

Avoid any situation that constitutes or may constitute a conflict of interest between the parties involved in an action or decision.

A conflict of interest occurs when the personal interests of an employee or the interests of a third party actually, potentially or apparently compete with the interests of the company.

Some of the areas in which a conflict of interest may arise are: Conflict of interest due to personal relationships with suppliers, with competitors, participation in other businesses that compete or collide with the company’s interests, accepting remuneration from third parties for professional consultancies not communicated to their superiors, etc.

Situations such as those described above may unduly influence the necessary objectivity and integrity in their decision making, as there is a clash between their own interests and those of the institution.

In the event that a conflict of interest is identified, the exposed person must immediately report it, in writing, to his or her superior and refrain from participating in any act that could potentially be affected by such condition.

1.11 Relationship with Customers and Suppliers

To offer excellent quality services in a competitive manner, guaranteeing customer satisfaction. To build long-term relationships based on trust and to identify opportunities for future development and growth for mutual benefit.

Establish cooperative relationships with suppliers and external collaborators, promoting full transparency in business practices. To give priority to objective technical and commercial criteria for their selection, free from any partiality or favoritism.

Permanently guarantee the confidential handling of all commercial and business information generated in the relationship with customers and suppliers.

To base commercial competition on fair and equitable treatment, avoiding any possibility of abuse of a dominant position.

  • Attentions and gifts

Not to offer or receive hospitality or gifts when these could constitute a commitment, influence or be reasonably perceived as incentives that could deliberately interfere with the independence, impartiality or judgment of the person who must make a decision related to the interests of the company.

Exceptions are corporate gifts and presents that companies have selected to give to their customers or suppliers.

– Do not accept or solicit gifts in exchange for doing something or making promises for a customer or supplier.

– Do not accept gifts of cash or cash equivalents, e.g. gift cards.

– Do not accept gifts valued at more than USD $50. Examples of acceptable gifts include a pencil or T-shirt with a logo, a notebook or similar. In the case of larger gifts, it is the employee’s obligation to explain this company policy to the giver and to decline the gift.

– All monetary gifts under USD $50 will be raffled at year-end activities.

– Gifts of symbolic value, e.g., trophies and statuettes, bearing inscriptions in recognition of a business relationship, may be accepted.

– Gifts or discounts offered to a large group of employees as part of an agreement between the company and a customer or supplier may be accepted and used as intended by the customer or supplier.

– Not to accept or solicit money or loans of money from customers or suppliers. Likewise, employees must not give gifts to their dependents to the extent that they generate an undue commitment or loyalty.

  • Meals and hospitality

– Do not accept meals or other types of hospitality in exchange for doing something or making promises for a customer or supplier.

– Do not ask for meals or any other type of attention from a customer or supplier.

– May accept meals and other occasional hospitality from customers and suppliers if the event is attended by the customer or supplier and the costs involved are in accordance with local custom for business-related meals and hospitality. For example, regular business meals and attendance at local sporting events are generally acceptable.

– All edible gifts will be consumed by all employees during year-end activities.

– If you are offered a meal, gift or other type of hospitality that exceeds the above limits, politely decline and explain the company’s rules. If the return of a gift could offend the person who gave it or the circumstances under which it was given prevent it from being returned, the employee may accept it, but must notify his or her direct superior, the person in charge of the Legal Area or the Comptroller’s Office. The latter will work with the contributor to either donate the item to a charity or distribute or raffle the item among all contributors.

  • Travel and important events

Invitational trips are expressly forbidden, since they generate an attitude of commitment to third parties that is totally undesirable. Exceptions will be analyzed and authorized by management.

1.12 Unibag assets

Protect Unibag’s assets, which may only be used for the development of legitimate activities and business.

1.13 Opportunities for Unibag

Business opportunities arising from knowledge or information obtained in the performance of the different positions are the property of the company and, therefore, will not be used for personal gain or used to compete with the company’s interests.

Employees shall not compete with the Company or take personal advantage of business opportunities presented to them during the course of their employment relationship, unless the Company has expressly abandoned its interest in pursuing such an opportunity, and the employee resigns from the Company in order to pursue it.

Personnel are not permitted to engage in other professional activities, unless they have been expressly authorized to do so.

Company personnel may not engage in gainful employment or work outside of Unibag, unless expressly authorized by management and as long as their outside employment does not interfere with their ability to perform their work with Unibag and they have consulted on employment policies and contracts, which may impose additional restrictions.

In particular, you may not collaborate with or otherwise provide services to, or receive payment from, any customer, supplier or competitor of the Company. Any exceptions must have prior written approval from your direct supervisor and management before any payment and/or reimbursement of expenses can be accepted.

1.14 Representation

Only those persons who have received formal power of attorney to do so, either by the nature of their position or by express delegation, may act on behalf of the company.

When personal actions may be confused with those of representation of the company, the person involved must make express and timely clarification of the nature of the same.

1.15 Quality of Information and Transparency

Maintain reliable and updated financial accounting records, in accordance with the principles, regulations and legal practices in force in each of the countries in which we participate. The information provided to management, administration, internal and external auditors, audit institutions, public and private organizations must be timely, truthful, understandable, serious, reliable and complete.

  • Fraud and Integrity of Financial Information

Fraud is the action by means of deceit or taking advantage of the error in which the other party finds himself, unlawfully appropriates a thing or obtains an undue profit.

Employees must never engage in fraudulent or other dishonest conduct involving the property, assets or financial records and accounting of Unibag or a third party. This may not only result in disciplinary sanctions but may also result in criminal charges.

  • Confidential information

Confidential information is information that, due to its characteristics, is not public knowledge. This includes trade secrets, business, marketing and service plans, engineering and construction ideas, designs, databases, records, salary information and any other commercial, financial or other information not generally published or reported to the market.

An important part of Unibag’s business management is based on the proper use of its confidential information and its non-disclosure to third parties. Unless required by law or authorized by management, employees shall not disclose or permit the disclosure of confidential information. This obligation subsists until one year after the termination of the employment relationship. In addition, employees must use their best efforts to prevent unintentional disclosure of information, taking special care when storing or transmitting confidential information. This includes the precaution of leaving or keeping in view on printers and desks, documents whose information requires confidential treatment and requiring confidentiality agreements in cases of delivery of information to third parties for professional services or consultancies.

The company respects the fact that third parties have a similar interest in protecting their confidential information. In the event that third parties such as business alliance partners, suppliers or customers share confidential information with the company, such information will receive the same care as the company’s confidential information. In the same vein, employees shall protect confidential information obtained during their previous employment.

With regard to the provision of information, whether to the media, customers, suppliers, etc. This must present total adjustment to reality and comply with the conditions and restrictions that Unibag has established for it and may only be carried out by personnel expressly authorized to do so.

Company employees shall take special care to maintain confidentiality with respect to all matters and sensitive information known to them by reason of their position, and may not under any circumstances discuss it – formally or informally – with co-workers, family members or outsiders. The dissemination of rumors, personal judgments, slander and any other type of incorrect information that may damage the image of the Group or any of its member companies, their employees or third parties will be investigated and the person or persons responsible will be sanctioned accordingly.

Persons having access to and working with sensitive information shall take special care to handle it with the discretion and care required, especially with regard to its storage and custody in secure locations (Data Privacy Policy).

1.16 Dissemination and Compliance

Unibag’s management will coordinate the necessary actions for the proper dissemination of the contents of this Code of Ethics among its employees, who must sign a Letter of Commitment to respect and comply with its stipulations.

Formal and regular instances will be provided to clarify doubts and discuss situations where ethical conflicts may arise. Unibag’s Internal Regulations shall make express reference to this Code of Ethics.

1.17 Commitment to the client

Unibag is committed to being transparent and ethical in the relationship with its customers, precautions will be taken with the following points:

  • All information disclosed by the organization will comply with high ethical standards, providing truthful and timely information about products and/or services.
  • Only products and/or services that fully comply with the services offered will be offered.
  • Be transparent and timely with the communication of prices, premiums, taxes and others.
  • Seek equality in the treatment of customers, without incurring in any type of discrimination.
  • Confidential customer information will be preserved with responsibility and protection. Confidential information will not be shared with anyone outside the organization, except for legal reasons.
  • Unibag is committed to conduct its marketing activities with integrity and probity, so no false comparisons will be made, no promises will be made that the organization cannot fulfill later, no misleading advertising will be made, no discrimination or stereotypes will be shown when advertising the product and/or service, the possible risks that the product and/or service may generate to the user will be informed and, as far as possible, good socio-environmental practices will be promoted.


Modifications to the Unibag Code of Ethics may be suggested by any member of the Ethics Committee at ordinary meetings and may consider the incorporation of new principles or the modification of any already established. The motion must be discussed by the Ethics Committee and, in order to be approved, it must be submitted to a vote and have the acceptance of at least 2/3 of the members of said body.

Once the modification has been approved, the code must be adjusted within a period of no more than one month and in order for it to enter into force, it must first be communicated internally to Management and the Heads and then to the other levels of the company through the channels deemed appropriate. In addition, the Code of Ethics induction for newly hired personnel should be modified to include the approved changes.


Definition of terms and how they are to be interpreted in this procedure

  • Crime:

In the legal sense, criminal codes and doctrine define “crime” as any conduct (action or omission) contrary to the legal system of the country where it occurs. The word crime derives from the Latin verb delinquiere, which means to abandon, to depart from the right path, to stray from the path indicated by the Law. It is sufficient that the action of “offering”, “promising” or “giving” takes place for the crime to be deemed consummated.

  • Bribery:

It consists of intentionally offering, promising or making an undue payment to a public official, with the purpose that he/she performs or omits to perform a certain official action.

  • Active Bribery: Person who offers payment or other advantage.
  • Passive Bribery: Public official who accepts this payment or advantage.

  • Terrorist financing:

Refers to the person who, by any means, solicits, collects or provides funds for the purpose of being used in the commission of any of the terrorist crimes set forth in Law 18.314 (Article 2°). Among the offenses included in this article are, among others:

  • Seizing or attacking a means of public transportation in service.
  • Attack against the head of state and other authorities.
  • Unlawful association for the purpose of committing terrorist crimes.
  • Money Laundering:

Operations that seek to conceal or disguise the nature, origin, location, ownership or control of illegally obtained money and/or goods. It involves introducing assets of illicit origin into the economy, giving them the appearance of legality by using licit activities, which allows criminals and criminal organizations to disguise the illegal origin of their proceeds without jeopardizing their source.

The UN defines money laundering in the Vienna Convention as “a subterfuge for formalizing informal financial flows of illicit origin, particularly drug trafficking, or as the surreptitious introduction of assets of illicit origin into the legitimate channels of the formal economy”. The predicate offenses for money laundering include, among others, drug trafficking, corruption, bribery, embezzlement and insider trading.

Offenses related to money laundering are included as those whose origin derives from:

o Drug trafficking activities.

o Illegal sale of weapons.

o White slavery.

o Child prostitution networks.

o Embezzlement of public funds.

o The malicious use of privileged information.

o Bribery.

o Computer fraud.

o Terrorism.

o Others.

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