1. MESSAGE FROM OUR PRESIDENT

Our commitment to customer satisfaction is guided and inspired by our core values. We recognize the importance of promoting ethical conduct in every step we take. The Board of Directors of "Del Plata Ingeniería (DPI) asume el compromiso de liderar el camino y promover una cultura ética, y lo mismo buscamos por parte de nuestros colaboradores y socios de negocios con los que nos relacionamos. Queremos que todos se sientan orgullosos de reflejar a diario los valores éticos corporativos que definen nuestra Compañía. En DPI nos esforzamos por hacer siempre lo correcto, sin importar las circunstancias. Estamos aquí para escucharte y apoyarte en cualquier momento en el que te enfrentes a decisiones éticas difíciles y, en caso de enfrentar un dilema ético, nuestro Código de Ética y Conducta contiene valores, principios y normas que nos guiarán para tomar decisiones responsables. Consideramos a DPI valiosa para el desarrollo de la Nación, buscando maximizar la productividad de nuestros procesos, siempre operando de manera responsable y segura y manteniendo en el centro la seguridad de las personas, el equipo y el entorno. Por ello, fomentamos una cultura organizacional basada en la cooperación y el respeto mutuo, donde cada individuo desempeña un papel esencial en la construcción de una cultura ética. Por eso, alentamos a cada colaborador y socio de negocios a leer, comprender y cumplir con los principios establecidos en este Código de Ética y Conducta. Juntos sigamos construyendo cultura ética en DPI.

Ing. Santiago Cerviño

Chairman of the Board

2. SCOPE

Este Código de Ética y Conducta es aplicable a todos los que hacemos DPI, sin importar su rol o responsabilidades, desde colaboradores y directores hasta proveedores,consultores, contratistas y socios de negocios, todos están sujetos a este Código y a nuestras políticas. La ética es el pilar fundamental que guía nuestras acciones, y es responsabilidad de cada individuo cumplir con este Código, así como con las leyes y regulaciones aplicables. Si bien el Código no contempla todas las situaciones posibles, ofrece pautas claras de conducta esperada en cada interacción.

3. OUR MISSION

En DPI generamos valor brindando servicios y ejecutando proyectos, con ingeniería y tecnología para las industrias de Oil & Gas, Energía, Petroquímica y Alimentos. Formamos un equipo especializado en ingeniería Mecánica, Instrumentación y Control, Eléctrica y Sistemas orientado a aumentar la seguridad de las operaciones y eficiencia de los procesos.
We offer agile solutions designed according to the needs of our Clients, with national and international execution, from our operational center in the province of Buenos Aires, and bases in Neuquén, Chubut, Santa Cruz and Tierra del Fuego.
Our most important resource is people. We work as a team, in an atmosphere of cooperation and respect.
We focus on honoring agreements and meeting the needs of our clients.
We are committed to the health of our employees; safety in operations; the quality of its processes and the care of the environment, respecting government regulations and those of our Clients.

4. OUR VISION

To be recognized as a reference

of the businesses we run.

5. OUR VALUES

Integrity

We operate ethically and transparently in all aspects of the business. We promote honesty, responsibility and respect in our relationships with employees, customers, partners and the communities where we operate.

Teamwork and collaboration

We encourage collaboration between employees, customers and partners, recognizing that teamwork is essential for the success of the Company.

Customer-centric performance

We offer safe, efficient and quality solutions, designed and customized for the needs of each client. We maintain strong and long-lasting relationships with customers, based on mutual trust.

Innovation and operational excellence

To foster a spirit of innovation and constant search, to improve safety and quality in processes, applying cutting-edge techniques.

Respect for people

We value and respect diversity, human rights and the dignity of people. We promote a diverse, inclusive and safe work environment, where the professional and personal development of employees is encouraged.

Security

We are committed to the protection and well-being of people, the environment in which we operate and the assets.

Sustainability

We promote sustainable practices for all the activities we carry out, taking care of the environment, and minimizing its negative impact.

6. INTEGRITY

Zero tolerance for corruption and bribery.

En DPI tenemos tolerancia cero ante sobornos y corrupción. Conocemos y cumplimos la Ley Anticorrupción, la Ley de Responsabilidad de la Persona Jurídica y la legislación aplicable. Está prohibido ofrecer, pagar, prometer, entregar, autorizar, recibir o aceptar sobornos o comisiones ilegales. Se entiende por corrupción la oferta, entrega y/o recepción de algo de “valor" (ya sea dinero, comidas, regalos, entretenimientos, donaciones, favores, servicios, viajes, empleo; entre otros) para influir indebidamente en una decisión u obtener una ventaja indebida, retener o hacer un negocio. También están prohibidos los pagos de facilitación realizados a funcionarios públicos para asegurar, avanzar o acelerar una acción o trámite público de rutina, independientemente de su cuantía. Todos los que hacemos DPI debemos rechazar y reportar todo hecho de corrupción. Nuestros socios de negocios y colaboradores deben adherir y cumplir con nuestra Política anticorrupción.

Some examples of corruption can be:

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  Advance the certification of services in exchange for an undue benefit.

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  Falsifying information in a technical report of work carried out on a client in exchange for an undue benefit.

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  Make payments to customs agents so that certain equipment enters our country and our operations more quickly

Interaction with the public sector

When we interact with public officials or representatives of the National, Provincial or Municipal State, or with state-owned companies, we do so only in accordance with the rules and principles of our Company and in accordance with our Protocol of interaction with the public sector. All interactions are conducted in an ethical, legal, and transparent manner in order to prevent any situation of bribery, conflict of interest, or violation of applicable laws and regulations.
At DPI, we define the valid interlocutors to interact with the public sector. Our business partners must also adhere to and comply with our Policy of interaction with the public sector.

To guarantee it:

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  Only personnel authorized by the Company may meet with public officials.

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  We will carry out the meetings in the offices of public officials or in our facilities, with due registration.

Political Contributions

DPI prohibits the financing of electoral campaigns and/or contributions to political parties in any form, in the name of or with the Company's resources.
Employees can do it in person.

For example:

• 

  It is prohibited to make a contribution on behalf of the Company to the candidate for Mayor of the city where we operate.

Conflict of interest

A conflict of interest occurs when a direct or indirect personal interest could affect or give the impression that it is affecting our objectivity or independence in making decisions in favour of IPR. Therefore, DPI employees must refrain from incurring in situations that could give rise to a conflict of interest.
Any conflicts of interest have to be reported. In case of doubt about whether a person is going through a conflict of interest situation, we suggest that you let it know immediately to avoid inconvenience. Any omission may be detrimental to the Company and the person responsible will be subject to a sanction for non-compliance with this Code.
Conflicts of interest must be declared in accordance with the process established in the Conflicts of Interest Protocol

For example:

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  Suppliers who have a sentimental, family or any other type of relationship with a collaborator who is going to work in the same area, for that area or under their responsibility should not be hired.

Gifts, Gifts & Entertainment

At DPI we have clear and transparent guidelines for the exchange of gifts, gifts and entertainment in our Company. Our goal is to ensure that all interactions are ethical, respectful, and comply with applicable legal and compliance regulations.

Gifts and gifts may influence business decisions or compromise the impartiality of our collaborators or business partners in the wrong way, creating the expectation of preferential treatment or improper favors.

For this reason, and taking care of the relationship with our business partners, as well as the image of our Company, we do not accept or make gifts of value.

All our collaborators and business partners must adhere to and comply with our Gifts, Gifts and Entertainment Protocol. In the event that, for cultural reasons, we decide to make or receive corporate or business gifts, these must not exceed the fair value defined in the Gifts, Gifts and Entertainment Protocol (USD 100 or its equivalent in national currency), on an annual basis, by source and must never affect objectivity or create a conflict of interest.

In the case of receiving commercial entertainment or invitations to congresses, courses or conferences that exceed the referred value, they must be authorized by the higher hierarchical level.

Gifts to public officials are prohibited, unless they are of courtesy or diplomatic custom and are registered and authorized by the higher hierarchical level, and must comply with the provisions of the Public Ethics Law.

Always refuse Gifts and Gifts that:

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  Are cash.

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  Are illegal or violate the law.

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  Make you feel obligated.

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  Create the expectation of preferential treatment or improper favors.

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  Are given as part of any agreement to do something

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  Are greater than USD 100 or its equivalent in national currency

Undue Influence

Any form of undue influence for the purpose of personal gain, either directly or indirectly, should be avoided. Our authority, hierarchical position, or access to privileged information should not be used for personal advantage.

For example:

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  If a DPI employee receives discounts or services from business partners that are not available to the rest of their colleagues.

7. TEAMWORK AND COLLABORATION

Business Partner Program

We know the importance of maintaining relationships with customers, vendors, suppliers, contractors or other business partners with whom we interact.

We encourage teamwork and an ethical culture. Our business partners must comply with applicable laws, our Code of Ethics and Conduct and corporate policies and share our ethical standards because, in their actions, they may generate responsibility or co-responsibility to our Company and, therefore, we must evaluate the integrity of our business partners.

Leaders

Each of us who do IPR must adopt the attitude of a leader, leading the way to do the right thing, complying with and enforcing this Code.

Each member of the Company must exercise his or her responsibility and initiative individually and jointly.

To this end, we must transmit values and good practices to those who join the Company and report conduct that is incompatible with our values and the content of this Code, its policies and applicable legislation

Compliance Manager

At DPI we have a Compliance Officer, who is responsible for promoting compliance with the content of this Code, the Company's policies and applicable legislation, as well as listening to and guiding you at any time when you are faced with difficult ethical decisions.

Among the specific functions of the Compliance Manager are:

1. Publicize this Code, policies, procedures, and other documents related to the Integrity Program;

2. Design and propose the implementation of policies, procedures and/or mechanisms to improve compliance with the objectives established in the Code of Ethics and Conduct;

3. Act as a consultative and advisory body to resolve concerns about ethical behaviour;

4. To deal with the complaints received, manage the investigation procedure and plan actions to mitigate or eliminate their impact.

Ethics Committee

At DPI we have an Ethics Committee whose objective is to promote the ethical culture in the Company, monitor compliance with this Code and ensure its implementation and periodic updating.

The committee is composed of:

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  Director

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  People Manager

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  General Manager

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  Legal Advisor

Among the specific functions of the Ethics Committee are:

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  Promoting an ethical culture

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  Oversee compliance with this Code and Company policies as well as the complaints and investigations process

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  Review and approve the Code, as well as policies, protocols, standards, and procedures

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  Deal with situations that, due to their characteristics, cannot be resolved by the Compliance Manager alone

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  Determine the penalties for detected non-compliance.

8. CUSTOMER-CENTRIC PERFORMANCE

Customer satisfaction

We focus on generating value for our customers, planning, executing and controlling our activities and PROCESSES, so that the products and services we provide meet the legal REQUIREMENTS and those of our customers.

It is the responsibility of each employee to comply with the company's processes and to send any opportunity for improvement, complaint or claim through internal processes, in accordance with our Integrated Management System manual.

On the other hand, our customers can express themselves through our satisfaction surveys or through our website, in the Queries, Suggestions and Complaints section.

INNOVATION AND OPERATIONAL EXCELLENCE

Improving the efficiency of processes and the performance of our products and services is one of the pillars of our Integrated Management System.

Innovation is present in our products and services, as we have a Design and Engineering area with specialized personnel, always at the forefront.

We encourage and encourage our employees to continuous improvement, through the recognition and participation of improvement projects.

9. RESPECT FOR PEOPLE

Workplace Free of Harassment and Violence

At DPI we are convinced that teamwork enhances our results, which is why we promote and are committed to maintaining a work culture based on mutual respect and the dignity of the human being, to prevent violence and harassment.

We promote a friendly workplace that generates trust and in which there are no situations of discrimination, mistreatment or any form of harassment or abusive and offensive behavior.

We are prohibited from behaving in a violent, threatening or intimidating manner towards colleagues or third parties, either individually or in groups. Whoever acts in this way shall be deemed to have failed to comply with this Code, with the consequences provided for.

This culture extends to our employees, regardless of their contractual situation, to employees who have been laid off and to our business partners.

For example:

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  Any violent behavior, including threats or intimidation, whether individual or group, and whether from collaborators or external, is prohibited.

Diversity & Inclusion

We are committed to providing respectful work that supports the diverse needs of collaborators and business partners. We value the many ways in which the Company differs. To do this, we comply with laws that prohibit discrimination and support equal employment opportunity requirements.

For example:

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  In DPI, it is guaranteed that there are no differences in salary or opportunities according to gender.

10. SECURITY

At DPI we are committed to ensuring compliance with health and safety standards and good practices within the current legal framework, so that we ensure the health and safety of the general public.

We must all know, understand and comply with our Company's security policies, regulations, protocols and standards, in order to manage risks with a commitment to eliminate associated hazards. Violation of these rules may cause damage to you, your colleagues, third parties or company assets.

11. SUSTAINABILITY

At DPI we are committed to making our business sustainable, which significantly reduces environmental impact throughout the entire supply chain. In our operations we seek to improve the way we manage and use natural resources, and for our clients we seek to provide services and products that promote the environmental sustainability of their businesses.

Our efforts are focused on offering solutions that minimize environmental impact, promote energy efficiency, and support responsible practices.

12. OUR RESOURCES

Use of Company Resources

All of us who do IPR are responsible for the protection and use of the resources we have at our disposal to meet our objectives, adopting criteria and preventive actions of custody and integrity. We protect and take care of all our work material such as physical resources (tools), intangible resources (industrial secrets, software) and economic resources (representation expenses according to the purpose that generates them). These resources include things like computers, internet access, email, software, tools and equipment, corporate credit cards, or shopping cards.

Similarly, the Company's resources must be used exclusively for legitimate purposes and not for personal gain. You must never use Company resources for illegal or inappropriate activities.

For example, is prohibited:

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  Use the corporate Credit Card for personal expenses and declare them as operating expenses.

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  Manipulate data to meet objectives.

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  Use Company assets for personal activities.

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  Using an NB/vehicle/tool to do work for others and/or for one's own benefit

Reliable Records

We prepare our accounting records, balance sheets and documents in accordance with legal provisions, with truthfulness and accuracy with respect to the reality of our operations.

We prohibit data manipulation. As a DPI contributor you must ensure that you create and maintain reliable records and that all reports, financial statements, legal records and other business records are accurate.

Confidentiality of Information

At DPI we understand that information is one of the main assets for the development of our operations.

We are committed to maintaining the confidentiality of the information we access in the performance of our IPR activity. Therefore, we prohibit the dissemination by any means, written or oral, of all non-public information belonging to our business partners, collaborators or our Company.

It is necessary to be careful and considerate when sharing information in writing, including emails. You should not share information with unknown sources and should avoid discussing confidential topics in public places or during phone conversations.

We have information security practices in place to preserve the integrity, availability, and confidentiality of information through correct identification and classification in order to prevent its exposure, loss, and/or corruption.

Failure to comply with the provisions herein will give rise to the Company to promote the corresponding sanctions according to the Sanctions and Recognition Policy and/or legal actions that may correspond, including those provided for in Law 24,766.

For example:

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  If we receive basic engineering data from a product to make a quote, we should not disclose and/or share such information with third parties.

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  When developing a product, the information generated is confidential and cannot be used for personal gain.

What is sensitive information?

Confidential information may include:

1.Personal Data:

Private information about individuals, such as addresses, ID numbers, medical data, among others.

2. Trading Strategies:

Information on processes, methods, techniques, strategies or business plans that confer competitive advantage on the Company.

3. Financial Information

Details on revenues, expenses, investments, financial statements, and other related data.

4. Private Information of Collaborators

Protection of Our Customers' Privacy

We are committed to taking all necessary measures to protect the privacy of our customers' information.

Access to our clients' documentation is restricted to authorized persons. We define profiles with different levels of access as required by the role that each one performs in the Company.

To ensure this, for example:

*We publish and/or upload documents of operations and/or photos in exhibitions, digital and graphic media, etc., according to the internal publication guidelines of Marketing.

Contributor Privacy Protection

We care about protecting the personal information of our employees in accordance with current legislation. Information about our collaborators is confidential and should only be provided to those who are expressly authorized and for legitimate purposes. We must all keep our personal information up to date, and must report any changes that may occur in a timely manner.

13. EXTERNAL COMMUNICATION

Speaking on behalf of the Company

At DPI we are committed to providing timely, reliable, accurate and understandable public information. Corporate information may only be disclosed by those who have the specific permission to do so or after verification with the hierarchical superior.

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  For example, is prohibited:

Publish trading strategies or pricing policies.

Responsible Use of Social Networks

DPI uses social media safely and responsibly.

1. Communications from DPI

Those collaborators who participate or are part of any social media, website and/or application in which DPI has an official profile, must comply with the following guidelines:

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  Do not publish strategic equipment information.

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  Do not disclose confidential information.

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  Carry out a check of compliance with safety and environmental regulations.

For example:

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  If at the end of a project or an assembly of a service, an image is uploaded, it must be verified that they comply with the guidelines listed. In the event that any of them are not met, these images should not be uploaded.

2. Communications from Collaborators or other Business Partners:

When posting information or feedback on your own behalf unrelated to IPR, you must not use contributor status or any other reference that would allow the posted content to be attributed to IPR. Do not publish, under any circumstances, confidential information.

Cuando publiques información en relación a DPI, debes realizarlo de acuerdo a nuestro procedimiento interno de Publicación en Redes Sociales. Debes comunicarte de maneraconsiderada y nunca publicar contenido que sea irrespetuoso, acosador o discriminatorio en ningún mensaje o publicación relacionados con DPI, nuestro negocio, nuestros clientes, nuestros socios comerciales o nuestra gente.

Responsible Advertising

At DPI we encourage the advertising of our commercial activities (services/projects/works) in a transparent, clear, coherent and non-misleading way.

14. REPORTING CHANNELS

All of us who do IPR have the duty to report if someone is not complying with current regulations, laws, the Company's policies or the provisions of this Code of Ethics and Conduct.

We promote the use of internal channels to be able to make complaints in good faith, in a secure, completely confidential manner and with the option of anonymity.

We prohibit retaliation against anyone who comes forward in good faith to express a concern or report to available channels.

There are several channels or means available to file your complaint:

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  Ethics Hotline: telephone line +54 9 11 5894-4375

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  Email: lineacodigoconducta@dpisa.com.ar

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  Mail: Av. Fortunato de la Plaza 5374 - (7600) Mar del Plata

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  In person: you can report to your hierarchical superior or compliance manager.

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  From our website, in the complaints option.

It should be noted that providing contact information is optional. DPI members are expected to do everything in their power to assist with the reported situation, including providing full and genuine information through available channels.

All complaints received will be managed by the Ethics and Compliance Committee. We guarantee that all complaints that are filed will be investigated in an objective, fair and confidential manner.

In cases where there are possible violations of the law, the Company may require that the matter be reported to the competent authorities, including the identity of the persons known to be aware of the facts.

15. SANCTIONS

Compliance with the provisions of the Code of Ethics and Conduct, applicable laws and regulations, as well as the internal policies of our Company, and participation in the training convened for the adequate knowledge of this Code, are a necessary condition to continue the employment or contractual relationship with DPI.

Failure to comply may result in disciplinary sanctions such as verbal or written warning, suspension, or any other that is deemed applicable, including, but not limited to, the termination of the employment or contractual relationship, and if warranted, the initiation of legal action. Likewise, the complaint of bad faith or obstruction of a complaint investigation or an ethical case shall be considered a breach of the provisions of this Code, making the aforementioned sanctions liable.