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AGP GROUP COMPLIANCE POLICY

Ethics and Grievance Committee

Created by:

Daniele BordignonLegal Manager AGPB

Andrés MayorgaInternal Corporate Auditor

Compliance Officer:

Javier Vasquez MejíaCFO

Daniel UrdanetaCorporate Legal Area

Aprobado por:

Arturo MannheimCEO

Note: The printing of this document is considered an uncontrolled copy. It is not guaranteed that this is the latest version of it. Please, find the latest version of AGP Group Compliance Policies at www.agpglass.com.

September, 2018.


Index

What Is Compliance?..........................................................................................................3

Purpose Of AGP Group Compliance Policy.....................................................................3Word of the CEO.................................................................................................................3

Anti-Bribery and Anti-Corruption Policy...........................................................................4Purpose.................................................................................................................................4

Scope....................................................................................................................................4Applicability...........................................................................................................................4

Local Law..............................................................................................................................4Definitions.............................................................................................................................4

Briber.....................................................................................................................................5Employees Personal Profit....................................................................................................6

Gifts From Third Parties and others......................................................................................6Gifts To Third Parties and others..........................................................................................6

Racketeering and Corruption................................................................................................7Donations to Political Parties, Political Organizations, Interest Groups and Public Entities. 7

Grants, Donations to Non-Profit Institutions and/or Social Institutions/Governmental Entities 7Integrity With Third Parties....................................................................................................7

With State Entities..............................................................................................................7With Customers 8

With Suppliers 8With Competitors................................................................................................................8

Facilitation Payments............................................................................................................8New Business and Joint Ventures........................................................................................8

Books and Records / Internal Control...................................................................................8Implementation......................................................................................................................8

Breach of Policy....................................................................................................................9Sanctions and Export/Import Control Policy.................................................................10

Purpose...............................................................................................................................10Applicability.........................................................................................................................10

Definitions...........................................................................................................................10Restricted Countries............................................................................................................11

Know Your Partner..............................................................................................................11Due Diligence 11

Red Flags 11


End User Certificate.........................................................................................................12

Agreements With Third Parties and Compliance................................................................12Policy Scope and Governance............................................................................................12

Confidentiality Policy........................................................................................................13Policy Brief & Purpose........................................................................................................13

Scope..................................................................................................................................13Policy Elements...................................................................................................................13

What Collaborators Should Do............................................................................................13What Collaborators Shouldn’t Do........................................................................................13

Confidentiality Measures.....................................................................................................14Exceptions...........................................................................................................................14

Consequences of Non-Compliance....................................................................................14Annex I – Identification Form...........................................................................................15

Annex II – Embargo Countries.........................................................................................17


What Is Compliance?Compliance means to comply/adapt and, consequently, to treat deviations of

nonconformity, based on Compliance with rules, regulations and the law. It aims to guide and

discipline the behavior of employees and all the people involved in the company, so that they

comply with the legal norms, business policies and guidelines, social rules and the company's

code of ethics, avoiding, detecting and treating any deviations or nonconformities that may

occur.

Purpose of the AGP Group Compliance PolicyThe Compliance Policy is a way to achieve the protection of intangible values of AGP

Group, based on the respect for legal norms, social conduct and business guidelines, avoiding

bribery and corruption, respecting export policies and protecting confidential information.

This policy is targeted to all collaborators of AGP Group, regardless the position or

function within the company, in order to become a standard of conduct and relationship

between employees, customers, partners, suppliers, service providers, competitors, society

and public services, because our conduct is just as important as our products.

Word of the CEOThe success of longevity has always been based on techniques to preserve the viability

and profitability of the business, but they can’t be materialized if Compliance policies are not

respected, because they are the guarantee that the company walks within the legality and

good social practices. Compliance policy is a means to achieve our goals in an ethical and

transparent way, seeking to investigate, avoid and solve any deviation, risk or nonconformity.

Therefore, I invite all of you that are directly or indirectly related to AGP to read our

Compliance Policy and, together, enhance the effectiveness, productivity and trust of AGP

Group, based on ethics, legality and protection of confidential information that is our company's

intangible assets.

Thank you all.

Arturo MannheimCEO AGP Group

AGP GROUP COMPLIANCE POLICYANTI-BRIBERY AND ANTI-CORRUPTION POLICY

ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

Purpose AGP is committed to maintaining the highest level of professional and ethical standards in the conduct in all countries in which AGP operates or otherwise have business connections. This policy describes the Company´s commitment to this effort and describes its obligations to conform its activities to all applicable anti-bribery and anti-corruption laws and regulations.

ScopeThis policy applies to:

(i) All officers, directors and employees of AGP;

(ii) Affiliates and subsidiaries of the AGP Group;

(iii) Customers and suppliers of AGP; and

(iv) Third-parties (including distributors, sales agents and vendors) that may interact on behalf of AGP before governmental entities or other Third- parties.

Applicability This Anti-bribery and Anti-corruption Policy (hereinafter “Policy”) is effective for prevent acts of bribery and corruption within AGP Group.

From the date of entry into force this Policy every customer, supplier or third-parties with whom AGP will begin a commercial relationship, must have a preliminary vetting to verify if they have any kind of interaction before governmental entities. The verification must be done by a written form (Annex I) signed by the legal representative of the customer, supplier or third-party.

In case of new customers the written form must be attached in the documents processes to create a new customer and after it will be sent to the legal area for Compliance procedure.

From the effective date all terms and conditions of purchase orders, reseller/distributions agreements and any other third-party agreements shall include anti-bribery and anti-corruption proceedings.

Local LawThis Policy contains AGP global standards. However, in some countries, more stringent applicable laws, regulations or industry codes supersede the principles set out in this Policy. In those cases the local law will be respected and applied in the respective area.

DefinitionsBribery: Means offering, giving, accepting or promising (or authorizing someone to offer, give, or promise) an improper benefit, directly or indirectly, with the intention of influencing or rewarding the behavior of someone to obtain or retain a commercial advantage against this Policy.

Bribery can take a variety of forms, such as offering, accepting, giving or receiving money or anything else of value. In fact, even common business practices or social activities, such as the provision of gifts and hospitality can constitute bribes in some circumstances.

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Corruption: Corruption means the misuse of entrusted power for improper private gain or improper gain for the company.

Public Official: The term ‘public official’ has been extensively interpreted by regulators and includes:

• Any elected or appointed officer or employee of a government or government department, government agency, or of a company owned or partially owned by a government.

• Any elected or appointed officers or employees of public international organizations, such as the United Nations.

• Any person acting in an official capacity for or on behalf of a government or a government department, government agency, or of a public international organization.

• Politicians and candidates for a political office.

Political contributions: Political contributions are monetary or non-monetary (e.g., resources, facilities) contributions to support political parties, politicians or political initiatives.

Facilitation Payments: Facilitation payments are payments to public officials to expedite the performance of duties of a non-discretionary nature. These payments are intended to influence only the timing of the public officials’ actions (e.g., payments to expedite the issuance of a visa or clearing goods through customs), but not their outcome.

Gifts: Gifts are benefits of any kind given to someone as a sign of appreciation or friendship without expectation of receiving anything in return. They include ‘courtesy gifts’, which are small gifts given at culturally recognized occasions (e.g., weddings, funerals) or special times of the year (e.g., Christmas, New Year). Hospitality generally includes refreshments, meals, and accommodation. Entertainment generally includes attendance at plays, concerts, and sports events.

Third party: A Third Party is any natural person or legal entity with whom AGP interacts and who poses, due to the nature of their business. AGP affiliates are not considered Third Parties in this Policy.

New Business: New business means any transaction with another company or business from the effective date.

Racketeering: Obtaining or extorting money illegally or carrying on illegal business activities, usually by Organized Crime. A pattern of illegal activity carried out as part of an enterprise that is owned or controlled by those who are engaged in the illegal activity.

Joint Venture: Joint venture means any type of joint agreement or arrangement between AGP and one or more third parties to own and operate an enterprise as a separate business for the mutual benefit of AGP and the third party or parties.

Books and Records: Books and records include accounts, invoices, correspondence, papers, digital files, tapes, memorandum and any other document or transcribed information of any type.

EGC: Ethics and Grievance Committee.

BriberEmployees, controlled affiliates, subsidiaries, customers, suppliers and third-parties must not bribe or use intermediaries, such as agents, consultants, advisers, distributors or any other business partners to commit acts of bribery.

AGP does not distinguish between public officials and private persons so far as bribery is concerned: bribery is not tolerated, regardless of the status of the recipient.

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Employees personal profitEmployees should not personally profit from the functions performed within the organization. Therefore, AGP employees should not accept any remuneration or compensation that is offered by companies with whom AGP has business relations or may subsequently have in the future. Also, they’re not allowed to offer benefits or advantage that may be contrary to the local law, to the AGP Policy and which may affect AGP and its business activities.

Gifts from Third Parties and othersNo employee of the AGP Group, neither their families and people with who they maintain personal relationships, are allowed to accept benefits such as gifts, payments of leisure activities, travel, accommodation for recreational use, training tips, use of vehicles not authorized by the AGP Group banks loans which are not covered in the agreements signed by AGP and any other that has a higher value than a routine courtesy such as lunch, a calendar, a publicity article, or the like offered by customers, suppliers, competitors, business partners or companies with which we can come to have a business relationship, and other marketing items with a maximum value equivalent to USD 100. If you receive courtesy items or attention prohibited in the aforementioned terms, above these values, you should contact the EGC Committee to seek their recommendation. The EGC Committee will assess the intentions of that customer or prospective client.

The employee must show caution when participating in business meals or entertainment activities, since such activities should be focused on the development or improvement of business relations. Other privileges such as discounts offered to employees of AGP in the context of trade negotiations can only be exploited if they are available to all employees of AGP in the same business unit and approved by the EGC.

The Human Resources Department in conjunction with the Purchasing area may request support from providers through gifts to cultural events of the Group, with the approval of the EGC Committee, without compromising the normal and transparent relationship.

Gifts to Third Parties and othersAGP employees should refrain from offering any payment or gift to customers, suppliers or business partners and should only offer marketing items, entertainment gifts without economic value and other benefits paid by AGP which are aimed at customers, suppliers, business partners, provided that the items to give away comply with the following parameters:

• Be clearly and exclusively associated with some planning, termination and / or implementation of business (in marketing activities).

• Adhere to general business practices, have a value framed within the budget plan and are approved by the General Management and the Director.

• Do not violate any law, regulation or national ethical principle of general application.

• Have a maximum value equivalent to USD 100.

Gifts, hospitality, and entertainment must be modest, reasonable and infrequent so far as any individual recipient is concerned. Gifts, hospitality, and entertainment must never be promised, offered, or provided with the intent of causing the recipient to do something favoring AGP illegally, to reward such behavior, or to refrain from doing something disadvantaging AGP.

Cash and gifts that are cash equivalent (e.g., shopping coupons) must never be given. Do not provide entertainment to any participant to AGP business meetings or comparable events, unless the entertainment is a part of the schedule previously approved by the board of Directors. Do not pay for any side or extended trips. In case of exist any doubt to give gifts please consult and request authorization from the Legal Area.

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Racketeering and CorruptionIt is prohibited by this Policy to ask or accept, offer or give any kind of bribery, blackmail or any illegal / unethical gain to employees or other representatives or AGP Group partners, government representatives and /or public officials, any non-compliance must be informed immediately to the EGC Committee through the email: [email protected].

AGP only accepts, signs / authorizes and participates in contracts that are adjudicated in processes adjusted to the legal and ethical parameters awarded in transparent processes and will never agree to offer, give or receive undue or fraudulent fees in exchange for such awards.

Employees in the service of AGP must refrain from acts that violate free competition, such as: Disrepute, deviousness, customer confusion, illegal imitation, unfair exclusivity agreements, and the illegal acquisition of classified information, among others. Nor may anyone transmit or leak information to enable them to take undue advantage in their business or personal interest and / or that of family and friends.

Donations to Political Parties, Political Organizations, Interest Groups, Public EntitiesAGP Group does not provide money or contributions in kind to any party or political organization or interest groups, likewise it does not compensate or reimburse employees for donations or other contributions made by the latter to political entities of any kind. No employee may make contributions on behalf of AGP to such organizations or through the use of their own funds or those of the company.

Grants, Donations to Non-Profit Institutions and / or Social Institutions / Governmental entitiesAll donations whether in finished products, materials, articles, in kind or in cash, must be channeled through the appropriate EGC Committee. Therefore, it will be verified if the institution has the requirements of a recognized nonprofit institution, working to develop social objectives not linked to political parties and / or similar groups, to make the application agreeable with compliance rules. In turn, the beneficiary shall grant the certificates or equivalent documents to support the donation for presentation to the relevant authorities in order to process applications for tax exemption.

Grants and donations may only be given if AGP does not receive (and is not perceived to receive) any tangible consideration in return. At the same time, grants and donations must never reward (or be perceived to reward) any tangible consideration.

Requests for grants or donations must be handled with special caution, in particular those from requesters who are able to affect the sales of AGP or may benefit personally if the request is granted. For instance, grants or donations must not be given to obtain a marketing authorization or any other approval, or to directly increase the sales of a AGP product in return.

Integrity with Third PartiesAGP must only engage Third Parties if all of the following requirements are met:

• There is a legitimate need for the services or the goods that they provide.

• The services and goods are priced reasonable market value.

• The Third Party is suitable from an anti-bribery perspective after assessment in a robust due diligence process.

• There is a written contract or other written document with a similar legal effect (e.g., Purchase Order).

With State Entities

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AGP disapproves the offer or the issue of payments in cash or in kind, at the initiative of its own employees or public officials to obtain or expedite decisions favorable to it and does not allow the delivery of gifts or incentives of any kind.

With Customers

Before establishing a business relationship with a customer, the Legal Representative of each Company of the AGP Group should collect the documents to conduct a due diligence in accord with AGP Sanctions Screening Procedure.

With Suppliers

Employees must ensure that suppliers comply with all requirements set by the laws of the country where sales take place and written confirmation of compliance with the requirements set by the purchasing department for suppliers to handle a substantial volume of business AGP.

With Competitors

Any dealings with competitors for the purchase or sale of product must have the approval of the Corporate Legal Department and one of the following: Executive Director, General Director, Commercial Manager.

During any contact with competitors, employees should refrain from discussing AGP internal affairs, such as

price lists and sales conditions, costs, market overview, organizational processes or other confidential information, from which such competitors could take advantage of AGP or could set up an attempt to tabulate prices.

With SponsoredAGP will allow the granting of sponsorship, as long as it has previously been approved by the legal department, together with the General Director.

Facilitation paymentsFacilitation payments are expressly forbidden.

New Business and Joint VenturesBefore entering into an agreement for new business or entering into a joint venture, adequate anti-bribery due diligence must be completed. Please contact the Legal Department for further information on how to perform the due diligence.

Books and Records / Internal ControlsAGP must prepare and maintain books and records that accurately and in reasonable detail document the source and use of AGP revenues and assets.

‘Off-the-books’ accounts and false or deceptive entries in AGP books and records are strictly prohibited. All financial transactions must be documented, regularly reviewed and properly accounted for in the books and records of the relevant AGP entity.

All relevant financial controls and approval procedures must be followed. The retention and archive of AGP records must be consistent with AGP standards and tax and other applicable laws and regulations.

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Implementation Training

Employees, controlled affiliates, subsidiaries, customers, suppliers and third-parties must familiarize themselves with this Policy. These parties must be trained per the AGP wide compliance training curriculum. Local AGP organizations may define additional training requirements.

External contractors and external service providers other than Third Parties shall be trained according to the Framework Guideline described in the item: “Diffusion of Compliance Policies between Employees, Customer, Suppliers and Third-parties”.

Responsibilities and Implementation It is the responsibility of General Managers to implement this Policy within his or her area of functional responsibility, lead by example, and provide guidance to the employees, controlled affiliates, subsidiaries, customers, suppliers and third-parties reporting to him or her. AGP managers must also seek to structure incentives and conduct performance assessments accordingly.

Breach of PolicyReporting Potential Misconduct/Non-Retaliation Any employee, controlled affiliates, subsidiaries, customers, suppliers and third-parties who learns of a potential violation of applicable laws or this Policy is required to report his or her suspicion promptly in accordance with the AGP Code of Conduct.

Employees, controlled affiliates, subsidiaries, customers, suppliers and third-parties who, based on good faith, report potential misconduct or who provide information or otherwise assist in any inquiry or investigation of potential misconduct will be protected against any kind of retaliation.

Consequences Breaches of this Policy will not be tolerated and can lead to disciplinary and corrective actions including termination of employment, contract or commercial relationship without prejudice to the applicable legal measures.

Exceptions No exceptions can be granted from compliance with applicable laws, regulations and industry codes. The EGC local Committee and EGC Corporate Committee decide on anti-bribery related matters not addressed by this Policy.

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AGP GROUP COMPLIANCE POLICYSANCTIONS AND EXPORT/IMPORT CONTROL POLICY

SANCTIONS AND EXPORT/IMPORT CONTROL POLICY

Purpose The objective of this Policy is to ensure that all international business transactions of AGP are made in compliance with applicable trade compliance regulations.

The regulations which the AGP Group must follow, for example, are international trade sanctions, export controls and anti-boycott regulations that are enforced by the U.S. Department of the Treasury’s Office of Foreign Assets Control, the U.S. Department of Commerce’s Bureau of Industry Security, the European Union and the United Nations (“UN”), among others.

This Policy sets out the minimum standards for compliance with sanctions.

This Policy applies to all international operations and personal contacts of the AGP Group including its agents, distributors and sales representatives. Hence all Group Companies within AGP Group and their employees are obliged to comply with the applicable export/import control regulations notwithstanding any contractual requirement.

Failure to comply with the requirements and restrictions of the various regulatory programs summarized in this Policy can expose the Company and the individuals involved to severe sanctions, including: (i) criminal and civil fines; (ii) imprisonment for individual violators; and (iii) restrictions on the ability of the company to engage in international business transactions.

Accordingly, under no circumstances may any international business transaction be conducted in a manner contrary to this Policy.

Applicability This Sanctions and Export Control Policy ( “Policy”) is effective to maintain the highest level of professional and ethical standards in the conduct of AGP’s international business transactions.

DefinitionsSanctions: Sanctions are measures taken by international bodies (such as the United Nations (UN) or the European Union (EU)) or countries (such as the United States (US)) that restrict or prohibit trade with certain countries, organizations and individuals. Sanctions can target:

1. Countries or regions: Sanctions targeted at countries or regions can restrict AGP Group from conducting business in those areas. For example, we may be prohibited from traveling to or making investments or creating joint ventures in the affected territory. The movement of certain goods to these countries may also be restricted.

2. Organizations and individuals: Sanctions targeted at organizations and/or individuals can restrict AGP Group from doing business with these organizations and/or individuals.

3. Goods: Sanctions can restrict the export of goods (including technology and software). The detailed specifications and potential use of these products (such as whether or not they include cryptography) and their end‐use determine whether they may be exported (at all) and, if export is permitted, whether a license is required.

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Restricted countriesForeign trade regulations recognize restrictions and prohibitions on cross-border movements (exports/imports) of items (goods) to other countries (including the making of binding offers and the transfer of economic resources with and to embargo countries (as listed in Annex II) and/or "listed" individuals.

Know your Partner “Know Your Partner” is a short-hand way of describing a basic due diligence standard that must be exercised when conducting business internationally.

The application of this process involves, at a minimum, the three-step process defined below:

1. Due Diligence In order to create a new business relationship it must be provide the following information as a minimum standard:

Counter-party name (legal entity and legal representative);

Registered address and telephone number;

Tax identification number;

Registration Certificate including company’s registry number;

Main business activity; and

Bank details when applicable for payment purposes.

The information described above will be given trough a written form (annex I) answered by the new supplier, customer or third-party and signed by the legal representative of the respective person. After signed, the form must be sent to the legal area for Compliance procedure and archive.

2. Red FlagsIn the process of conducting the “Know Your Partner” due diligence, it´s possible to discover or to face some of the following facts or scenarios:

The customer was previously entirely unknown to you or your contacts in the industry;

The customer or purchasing agent is reluctant to offer information;

The capabilities or potential uses of the product being sold do not fit the buyer’s line of business.

The customer is willing to pay cash for expensive items;

The delivery destination is unrelated to either the customer or it´s purchasing agent;

The customer has little or no business background;

The customer is unfamiliar with the products performance or characteristics but still wants the product;

A freight forwarding firm is listed as the product’s final destination;

These situations demonstrate alerts that may receive special attention for continuing process and they need to be reported to the Legal Department immediately.

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3. End user certificate The customer or third-party with which AGP will establish a new relationship, will sign a statement along with the Due Diligence form in Annex I, ensuring that they won't sell, give, transfer-ship or donate any product of AGP's enterprises to any person located in a restricted/forbidden country or that may be contrary to this policy, under the penalty of termination contract and/or commercial relationship without prejudice to the applicable legal measures.

Agreements with third parties and complianceThe Company’s terms and conditions of purchase orders, reseller/distribution agreements and other third-party agreements shall include language on counter-parties’ requirement to comply with export controls and sanctions and non-diversion to prohibited or restricted countries in accordance with this Policy. The dispositions shall be prepared by an authorized member of Legal Department and shall attend to relevant regulations as the case may be in order to make them enforceable in the affected jurisdictions.

Policy Scope and GovernanceAll companies in the AGP Group must comply with these minimum standards. The prior written approval of the Legal Department is required for any deviation from this policy. Executive management is responsible for the development and implementation of sanctions programmed that covers the AGP Group.

The Legal Department is responsible for the implementation of this policy in the entities for which they are responsible.

The Legal Department is the ultimate owner of this Policy (and related documents) and has overall responsibility for the implementation of this Policy in the AGP Group. This Policy will be reviewed on an annual basis and, in addition, may be reviewed from time to time to take account of, for example, changes to sanctions legislation, regulatory developments or organizational changes.

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AGP GROUP COMPLIANCE POLICYCONFIDENTIALITY POLICY

CONFIDENTIALITY POLICY

Policy brief & purposeAGP designed this company confidentiality policy to explain how its Collaborators (as defined below) are expected to treat confidential information as a sender or recipient. AGP Group expects all of its Collaborators to handle all confidential information in a sensitive and professional manner. AGP Group Collaborators are under an obligation not to gain access or attempt to gain access to information which they are not authorized to have. The AGP Group, however, recognizes the importance of an open culture with clear communication and accountability. The AGP Group wishes to maintain personal and organizational safety and expects all Collaborators to handle confidential information in a way which protects organizational security.

In case of doubt please contact your area manager or a representative of the Legal Area.

ScopeThis policy affects all employees and personnel, this including board members, investors, contractors and volunteers, partners, independent contractors, agents, sales representatives (“Collaborators”) who may have access to confidential information.

Policy elementsConfidential Information means all and any information concerning the Company’s business and finances, including without limitation, technical procedures and intellectual property rights, its customer, client and supplier lists, including details of prospective clients; its dealings, transactions and affairs; its products and services; contact details of clients, customers and suppliers; information about individuals within clients, customers and suppliers; financial projections, targets and accounts; pricing policies and pricing statistics; commercial activities, product development and future plans; and similar information concerning the AGP’s clients and any other information instructed by AGP to be considered confidential information.

Collaborators may have various levels of authorized access to confidential information, in case of doubt please contact your area manager, main AGP contact or a representative of the Legal Area for further clearance.

What Collaborators should do: Lock or secure confidential information at all times. Make sure they only view confidential information on secure devices. Only disclose information when it’s necessary and authorized. Keep confidential documents inside our company’s premises unless it’s absolutely

necessary to move them. When Collaborators stop working for our company, they’re obliged to return any

confidential files and delete them from their personal devices.

What Collaborators shouldn’t do: Use confidential information for any personal benefit or profit. Disclose confidential information to anyone outside of our company without the due

authorization. Replicate confidential documents and files and store them on insecure devices.

Confidentiality Measures

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AGP GROUP COMPLIANCE POLICYCONFIDENTIALITY POLICY

AGP will take measures to ensure that confidential information is well protected. The Collaborators will:

Store and lock paper documents. Sign non-compete and/or non-disclosure agreements (NDAs) Ask for authorization by senior management to allow their access to certain confidential

information. Mark up confidential information and every email using the following legends:

“The information contained herein is for the exclusive use of the personnel authorized by AGP and contains information classified as confidential property of AGP. Any use, review, copy, diffusion, broadcast, retransmission, etc., by any media to different people is not authorized and therefore, is forbidden. All and any misuse of this information may cause criminal actions and liability for civil actions.If you aren’t the appropriate recipient of this email, please inform the sender immeiatly”.

Copyright (2018) – AGP America S.A. – Proprietary and Confidential Information disclosed under NDA.

When sending emails, always use the authorized signature disclaimer as provided by the Marketing Department and in the subject write [Confidential] when sending confidential information.

ExceptionsConfidential information may occasionally have to be disclosed for legitimate reasons. Examples are:

If a regulatory body requests it as part of an investigation or audit. If our company examines a venture or partnership that requires disclosing some

information (within legal boundaries).

In such cases, Collaborators involved must document their disclosure procedure and collect all needed authorizations before any disclosure. In any case, avoid disclosing more information than needed.

Consequences of Non-ComplianceCollaborators who don’t respect our confidentiality policy will face legal action this may include civil or criminal procedures, labor disciplinary action and/or termination of contracts at decision of AGP.

The company will investigate every breach of this policy and may also have to punish any unintentional breach of this policy depending on its frequency and seriousness.

The collaborator is committed to this confidentiality policy even after the termination of employment, contract or commercial relationship.

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AGP GROUP COMPLIANCE POLICYANNEXES

ANNEX IIDENTIFICATION FORM

This request form is the first step for the supplier, costumer or third-party additional process in the AGP system. In order to add your company in AGP Group management system of customers/suppliers/third-parties, please share the following details:

Classification: ( ) Supplier ( ) Customer ( ) Other

GENERAL INFORMATIONLegal Name of the company: ______________________________________________________________________Nationality: __________________________________ National Registration Number: _________________________Economy Activity: _______________________________________________________________________________Bank Details: ___________________________________________________________________________________Address: ________________________________________________________________________________________City: ______________________________ Country: __________________________ Postal Code: ________________Contact Name: _________________________ Email: _________________________ Phone Number: _____________

SUBSIDIARIESIf there’s any company subsidiary, please inform the name, complete address, national registration number:____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

SHAREHOLDERS1) Name: ________________________________________________ Nationality: ________________________National Registration Number: ____________________________________ Shareholder > 25%: ( ) Yes ( ) No2) Name: ________________________________________________ Nationality: ________________________National Registration Number: ____________________________________ Shareholder > 25%: ( ) Yes ( ) No3) Name: ________________________________________________ Nationality: ________________________National Registration Number: ____________________________________ Shareholder > 25%: ( ) Yes ( ) NoOthers: _______________________________________________________________________________________________ _______________________________________________________________________________________________

LEGAL REPRESENTATIVES1) Name: ____________________________________________________ National ID Number: ____________________________ Nationality: _________________________________ Considered PEP (Politically Exposed Person): ( ) Yes ( ) No2) Name: ____________________________________________________ National ID Number: ____________________________ Nationality: _________________________________ Considered PEP (Politically Exposed Person): ( ) Yes ( ) No3) Name: ____________________________________________________ National ID Number: ____________________________ Nationality: _________________________________ Considered PEP (Politically Exposed Person): ( ) Yes ( ) No4) Name: ____________________________________________________ National ID Number: ____________________________ Nationality: _________________________________ Considered PEP (Politically Exposed Person): ( ) Yes ( ) No

Does the company or its representatives have any interaction with governmental entities? ( ) YES ( ) NO

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If yes, please describe: _____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

The establishment of a commercial/business relationship with any company of AGP Group depends on the reading and acceptance of AGP´s Compliance Policy. By confirming this statement, you warrant that you have read, understood and agreed to the Policy, and you allow AGP to conduct searches and queries of your name/company to verify that the data complies with the compliance policy of AGP. By this form, you consent to the collection and processing of personal data relating to the aforementioned Company and you declare that you have the authority to give these authorizations. This data will include, but may not be limited to: data about names, ID documents, emails, phone numbers with the purpose of validating your information and procuring the normal business communications in the frame of the agreement entered with AGP.

( ) I confirm the above statement.

By confirming this statement you warrant that, having contact with or buying the products of any company of AGP Group, you won't sell, give, transfer-ship or donate any of those products to any person located in a restricted/forbidden country or that may be contrary to AGP Group Compliance Policy, under the penalty of termination of contract and/or commercial relationship without prejudice to the applicable legal measures.

( ) I confirm the above statement.

The information provided in this form is true, under penalty of the applicable legal measures.

_______________________________________________Local and date

________________________________

Legal Representative Signature

Name: ______________________________

_______________________________Legal Representative Signature

Name: ______________________________

Please, provide one of the following documents that contains a legal name and address of your organization: business license, tax registration certificate or national registration certificate

ANNEX II - EMBARGO COUNTRIESProhibited conditionsAGP Group prohibits any transaction with any company, entity or resident based in or organized under the following conditions:

a. Any person that is the subject or target of sanctions administered by the Office of Foreign Assets Control (OFAC) including the “Specially Designated Nationals and Blocked Person List” as set forth on http://www.ustreas.gov/offices/enforcement/ofac/sdn/, the United Nations (UN), the European Union (EU), Her Majesty’s Treasury (UK HMT), the Swiss Secretariat of Economic Affairs (SECO), the Hong Kong Monetary Authority (HKMA), and the Monetary Authority of Singapore (MAS) (hereinafter, the “Sanctions Programs”),

Any person owned, partially owned or controlled by a person that is the subject or target of sanctions imposed by the Sanctions Programs,

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b. Any person domiciled, resident, or located in Iran, Sudan, Syria, Cuba, North Korea, or Crimea (hereinafter, “Sanctioned Jurisdictions”) or

c. Any other person with whom a U.S. Person may not engage under any Prohibited Nations Act in the absence of specific governmental authorization.

AGP Group utilizes a number of internal procedural and financial controls to help ensure our compliance with these prohibitions. However, every employee involved with international transactions has the obligation to monitor for potentially prohibited transactions and “speak up” and immediately contact the Legal Department if they become aware of a transaction they believe may violate these restrictions.

Restricted countries and restricted partiesThe following countries are considered “Restricted Countries”:

Afghanistan Armenia Azerbaijan Belarus Burundi Central African Republic Myanmar

(Burma) Democratic Republic of the Congo Egypt Eritrea Guinea Guinea Bissau Ivory Coast

Iraq Lebanon Liberia Libya Myanmar Moldova Russia Somalia Tunisia Ukraine Venezuela Yemen Zimbabwe

These countries are subject to sanctions primarily targeting individuals or entities that are defined as “Restricted Parties” or “Specially Designated Nationals” (“SDNs”). In other words, while we can conduct business in a Restricted Country, we cannot do so if it would entail doing business with a Restricted Party or SDN.

Restricted Parties or SDNs involve the following categories: o individuals or entities associated with restrictive regimes or undermining democracy, terrorists, narcotics traffickers, proliferators of weapons of mass destruction, transnational criminal organizations and foreign sanctions evaders wherever located.

A strong due diligence process is required before transacting any business in a restricted country (Annex II). In the process of the due diligence, you must stop and ask for further guidance from the Legal Department before proceeding.

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Documents

Política Corporativa de Inventario de Producto Terminadoagpglass.com/wp-content/uploads/2017/06/Compliance-… · Web viewWord of the . CEO. The success of longevity has always