CODE OF CONDUCT FOR SUPPLIERS OF ALBAUGH CHILE AGROCHEMICAL LIMITED
Albaugh Chile Agroquímica Limitada (hereinafter referred to as “Albaugh”) expects its suppliers, contractors, subcontractors, and third parties with whom it collaborates to comply with all applicable national, provincial, and/or municipal laws and regulations at the locations and workplaces where they operate and conduct their business activities. Likewise, such third parties must adhere to internationally recognized standards regarding labor, ethics, and environmental care.
Albaugh expects its suppliers, contractors, subcontractors, and third parties to comply with the following guidelines when providing their services:
(I) Human Rights and Labor Practices
• Support the protection of internationally recognized human rights, including respect for minimum wage, working hours, and freedom of association.
• Prevent forced labor, child labor, harassment, discrimination, and other unlawful workplace conduct.
• Refrain from retaliating against anyone who files a report or complaint or cooperates in an investigation related to a breach of this Code.
(II) Anti-Corruption, Ethics, and Transparency
• Respect and comply with prevailing regulations on competition and commercial loyalty, as well as all anti-corruption regulations, including the Penal Code, the United Nations Convention Against Corruption, and the United States Foreign Corrupt Practices Act (FCPA).
• Provide all documentation that ensures the safety of the products and/or services supplied to Albaugh, as well as their transport.
• Prohibit gifts, bribes, kickbacks, extortion, embezzlement, or other corrupt practices, whether directly or indirectly.
• Avoid engaging in money laundering or any other manipulation of illicitly acquired funds.
• Ensure that all components used in the products and/or services supplied to Albaugh are legally obtained.
(III) Occupational Safety, Health, and Environmental Protection
• Comply with all national, provincial, and/or municipal environmental, health, and occupational safety regulations applicable to their operations to ensure sustainable practices.
• Ensure that their activities are conducted under appropriate environmental permits and licenses, and maintain a safe work environment that minimizes accidents and workers’ exposure to risks.
(IV) Confidentiality and Intellectual Property
• Maintain the confidentiality of all transactions carried out with Albaugh, ensuring compliance—both directly and through their dependents—with all confidentiality agreements and other agreements signed with Albaugh related to the products supplied and/or services provided.
• Protect Albaugh's confidential information from unauthorized use.
• Respect Albaugh's intellectual property rights, including trade secrets, trademarks, product registrations, and patent rights, among others.
• Ensure compliance with applicable personal data protection regulations.
As a result, Albaugh will consider the continuation of the contractual relationship only with suppliers who fully comply with this Supplier Code of Conduct. The relationship may be terminated with those who knowingly violate the provisions of this Code and refuse to implement corrective measures.
Contact Information
Albaugh expects its suppliers, contractors, subcontractors, and third parties involved in its business development to promptly report any non-compliance with this Code. All communications related to this Code may be sent via email to: requerimientosclientes@albaugh.com.ar
Transparency Statement on Supply Chains
Introduction
Albaugh, LLC (“Albaugh”) issues this statement in compliance with Section 54(1) of the Modern Slavery Act 2015, the UK Modern Slavery Act 2015, and similar laws. This statement outlines the actions Albaugh and its subsidiaries take to identify potential risks of modern slavery in our business operations and the steps implemented to ensure the absence of slavery or human trafficking in our supply chains. Integrity and accountability are at the core of our values. We uphold high ethical standards and exemplary behavior in conducting business. Albaugh firmly opposes all forms of forced labor, human trafficking, and slavery and does not condone such prohibited and illegal practices by its employees, suppliers, vendors, or other business partners.
Organization of Albaugh, LLC
Albaugh is a privately-owned U.S.-based company specializing in the production and packaging of post-patent crop protection products. Albaugh’s U.S. operations include nationwide product sales. Albaugh operates as a global company with subsidiaries and manufacturing facilities located in the U.S., Mexico, Brazil, Argentina, and Europe, where it manufactures, distributes, and markets crop protection products.
Albaugh’s Supply Chain
Albaugh’s supply chain is managed by our Group Purchasing Department, which operates as a single global function structured across all business lines. We develop and implement the most appropriate strategies for each category to maximize value in cost and risk management, sustainability, innovation, and growth. In addition to adhering to Albaugh’s Supplier Code of Conduct, our key suppliers declare and warrant that they will fulfill their obligations to Albaugh in compliance with all applicable foreign, federal, state, and local statutes and regulations.
Relevant Albaugh Policies
Albaugh operates under several internal policies to ensure that we conduct business ethically and transparently. Our Code of Ethics ("Code"), an internal company policy, provides important guidelines for Albaugh’s interactions with customers, suppliers, and other business partners, as well as among employees. The Code summarizes the policies and principles that commit us to safe, honest, thoughtful, and responsible operations across all business and facility activities. Our commitment to ensuring the absence of modern slavery or human trafficking in our supply chains or any part of our business is also reflected in the following policies:
- Supplier Code of Conduct
- Responsible Conduct
Albaugh’s Due Diligence Processes
Albaugh’s Supplier Code of Conduct specifically addresses this aspect. The Code is communicated to all current and new direct suppliers, and most purchase orders and contract templates have been updated to include compliance with the Code as a contractual requirement.
Albaugh expects suppliers to implement systems and controls to promote compliance with applicable laws and the principles outlined in the Supplier Code of Conduct, including policies, training, and monitoring/audit mechanisms. Suppliers must also apply these principles to subcontractors and suppliers involved in providing goods and services to Albaugh. Albaugh reserves the right to assess and monitor compliance with this Supplier Code of Conduct. Suppliers failing to comply with the Code are expected to implement corrective actions or risk exclusion from future business opportunities.
Currently, Albaugh does not conduct compliance audits of its suppliers. However, we are evaluating the possibility of requiring compliance certifications, self-assessments, and/or audits.
Albaugh provides all employees and third parties with an anonymous reporting hotline operated by a third party (via phone and online, available in multiple languages). This hotline can be used to seek guidance on specific situations, report violations of Albaugh’s Code of Ethics, including the Supplier Code of Conduct, or other unethical business practices. Reports can be made anonymously in most countries, and callers are protected from retaliation.
Employee Training
Albaugh strives to maintain an internal training curriculum reviewed annually for new compliance topics. We conduct internal training on our Code of Ethics ("Code") to ensure employees understand our standards for conducting business with the highest ethical behavior and in compliance with the law. All Albaugh employees and subsidiaries, including those directly responsible for supply chain management, are expected to know and comply with this Code. Violations of the Code may subject employees to corrective actions, including termination. Albaugh takes all potential legal or Code violations seriously and investigates thoroughly, respectfully, confidentially, and fairly, taking actions proportionate to the severity of the infraction.
Approved by the Board of Directors on August 19, 2020
Signed by: Kurt Pedersen Kaalund, Chief Executive Officer and Manager
