Frutura Uruguay is a proud member of the Frutura family of companies, a global sales and marketing network dedicated to bringing customers the premium fruit they need, 365 days a year.
We are an organization dedicated to the production and commercialization of citrus fruit and food products derived from it.
Our objectives are oriented to the satisfaction of our current and future customers. The challenge is to achieve quality and food safety that satisfies each of them.
We are committed to complying with the legal requirements of our country and those for whom our products will be destined.
Our aspiration is to continue growing and diversifying our products while maintaining the quality and safety of these, through a commitment to continuous improvement, being one of our pillars to be a sustainable organization in all areas.
In support of this aspect, we are committed to sustaining a harmonious environment for interactive internal and external communication with the various stakeholders.
With our suppliers, our commitment goes beyond marketing, establishing quality guidelines that ensure the traceability and safety of our raw materials and inputs, and therefore of our final product.
Through the development of a Culture of Quality and Food Safety, we aim at the growth and participation of all collaborators, to achieve the improvement of the organization and of each member, thus ensuring the competencies for the elaboration of safe, legal and authentic products.
Our Commitment and Purpose
At Frutura Uruguay we believe that we all deserve to work in an environment where we are treated with dignity and respect, which brings out the full potential of each of us. Frutura Uruguay is committed to respecting and protecting the human rights, safety and dignity of the people who contribute to the success of our business. We seek to operate responsibly and make positive contributions to the community. It is of utmost importance that all our dealings are conducted in a legal, moral and ethical manner. We align our standards with the Employment Standards set forth in this Code.
The Policy sets out the standards we expect all our suppliers to meet when producing and supplying products or labor for Frutura Uruguay regardless of where in the world they operate. Our suppliers must be committed to comply with all applicable laws and regulations and be aligned with Human Rights and International Labor Standards. This includes, among others, labor, environmental, safety (i.e. product safety), anti-bribery, anti-corruption and trade laws and regulations.
This Code may be amended by Frutura Uruguay from time to time and at any time as permitted by law. The application and/or interpretation of this Code rests solely with Frutura Uruguay and is not intended to create any rights in favor of any party other than Frutura Uruguay. Suppliers are responsible for this Code and are expected to follow it unless restricted by contract or law.
Definitions
Applicable laws and regulations refers to all national, departmental, local and other laws and regulations applicable to suppliers’ operations, including, but not limited to, the labor, health and safety, and environmental laws and regulations of the jurisdiction where the labor used to produce the products and their components is employed.
Code means this Supplier Code of Conduct.
Co-worker(s) refers to any current or former co-worker, worker, employee or staff member employed or contracted by the supplier, facility or subcontractor, including all foreign and migrant workers.
Facility means any entity that produces, processes or harvests the products sold to Frutura Uruguay that may be owned or operated by the supplier.
Subcontractor refers to any entity contracted by the facility to produce, process or harvest the products sold to Frutura Uruguay.
Supplier refers to the entity that has been contracted by Frutura Uruguay to provide products or services.
Unauthorized subcontracting refers to the assignment, delegation or otherwise transfer of any part of a purchase order to a facility without full disclosure to or consent of Frutura Uruguay.
Suppliers, Facilities and Subcontractors
The supplier is responsible for ensuring compliance with the Code throughout its operations and supply chain. Supplier shall maintain the ability to trace all components or ingredients of the products/services back to their origin and, upon request, provide Frutura Uruguay with the names, addresses and contact information of each entity in the supplier supply chain, including, but not limited to, other suppliers, agents, affiliates or subcontractors (“supplier partners”).
All facilities and supplier partners involved in the production of products/services provided (sold) to Frutura Uruguay must be disclosed and approved by Frutura Uruguay. Facility and supplier partner practices shall be consistent with the Code and applicable laws and regulations.
Preference for local suppliers and underrepresented groups
Preference is given to outsourced suppliers and services belonging to underrepresented groups. They are those who traditionally have not had equal access to economic opportunities because of systematic discrimination or other social barriers. To define whether a person belongs to a previously excluded population, criteria such as gender, ethnicity, sexual orientation, age, disability status, immigration history, education level and income level are taken into account.
We seek to work with local suppliers and outsourced services, close to the company’s facilities and ideally not local subsidiaries of large companies. In this way, we seek to minimize the environmental impact of transporting supplies and materials, in addition to strengthening and promoting local economic development and employment, in line with the company’s social objectives.
Supplier selection preferences
In our commitment to responsible and sustainable business practices, Frutura Uruguay strives to make conscious decisions when selecting suppliers. In situations where suppliers are considered on an equal footing, we express a clear preference for those that contribute positively to our local community and exhibit a low environmental impact. We believe that by favoring local suppliers, we can strengthen our ties with the community and minimize our environmental footprint.
In addition, Frutura Uruguay attaches great importance to suppliers with certifications, in line with our sustainability objectives. Certifications such as Environmental, Social and Governance (ESG) are highly valued.
By incorporating these selection preferences, Frutura Uruguay not only seeks operational excellence, but also seeks to contribute to a more sustainable and inclusive global business ecosystem. We appreciate the efforts of our suppliers that align with these values, fostering a collective commitment to responsible and ethical business practices.
Corporate records
All records/documents necessary to verify compliance with the Code, applicable laws and regulations will be maintained and made available to Frutura Uruguay upon request. Records must be true, accurate and complete, and the supplier may not alter or falsify documents/records. This requirement also applies to any employment agency used by the supplier or the supplier’s partners. The records/documents include all those under Law No. 18,099 and Law No. 18,251.
Human rights and labor standards
Frutura Uruguay recognizes the inherent dignity and equal rights of all people. We are committed to upholding and respecting human rights in all aspects of our business operations.
The Policy outlines our commitment to conduct business in a responsible and ethical manner, promote a culture of respect and contribute positively to the communities in which we operate and sets out the standards we expect all our suppliers and supply partners to meet when producing and supplying products or labor for Frutura Uruguay, no matter where in the world they operate.
Employment is freely chosen: all employees, contractors and temporary workers shall work on a voluntary basis and shall not be subject to any physical, mental or sexual exploitation, such as forced, bonded or indentured labor. Employees shall not be subject to any form of coercion, fraud, deception or relinquishing control of their person to another for the purpose of such exploitation. The supplier and its partners shall not support or participate in slavery or human trafficking in any part of its supply chain. Employees must maintain possession or have control of personal identity and travel documents. Employees’ freedom of movement shall not be restricted; nor shall employees be prevented from terminating their employment.
Working hours: employees shall not be required to work hours or complete production quotas that would result in a violation of legal working hour requirements. Suppliers and their partners may require overtime from their employees if all applicable laws and regulations related to overtime are followed.
Wage deductions: W ages will not be withheld except as required and/or permitted by law.
Employment agencies: Suppliers and supplier partners shall only use employment agencies that are permitted by law to operate and shall ensure that the hiring of employees either directly or indirectly follows the Code, applicable laws and regulations. To the extent prohibited by law, employees shall not pay fees or related costs incurred for the purpose of employment or as a condition of employment.
Freedom of association: employees shall have the right to freedom of association and shall not face unlawful retaliation, harassment or intimidation for exercising these rights as defined by applicable law.
Working conditions are safe and hygienic: suppliers and supplier partners are responsible for understanding and complying with all applicable health and safety laws and guidelines. Suppliers are responsible for identifying, assessing and mitigating safety and health risks and concerns. They are responsible for providing health and safety training and communicating health and safety information in local languages. This training should be provided to all workers at the start of employment and at appropriate intervals thereafter. Workers should have easy access to clean sanitary facilities, potable water and hygienic facilities for preparing, storing and eating food.
Child labor and young workers: in accordance with applicable law, all employees must be at least the legal age established by national law. Official and verifiable documentation of each employee’s date of birth, or a legally recognizable means of confirming each employee’s age, shall be maintained. Employees under eighteen (18) years of age shall not perform any work that is dangerous or interferes with their education or endangers their health, safety, moral or social development. All legal restrictions on working hours for employees under the age of eighteen (18) must be respected.
Wages and benefits: employees will be paid at least the legal minimum wage and overtime for hours worked and will be provided with all legally required benefits. Wages will be paid according to the legally required schedule and form (i.e., following the method and timing of payment and documentation requirements, such as detailed wage statements required in our country. Accurate payroll and production records will be maintained.
Non-discrimination and harassment: Suppliers and supplier partners must not tolerate any form of harassment or discrimination based on any characteristic protected by applicable law. Any behavior, communication or other conduct that creates an intimidating, offensive, abusive or hostile work environment, or otherwise interferes with any employee’s ability to perform his or her job, is unacceptable. All workers will be treated with respect and dignity. Suppliers and supplier partners must not permit physical or mental punishment or abuse of any team member.
Bribery and corruption
Suppliers and supplier partners must be committed to conducting business in compliance with all laws prohibiting bribery and other corrupt practices. Its worldwide business operations must comply not only with local anti-corruption laws, but also with laws that apply to its business activities around the world, such as the U.S. Foreign Corrupt Practices Act (the “FCPA”) and the U.K. Bribery Act.
Our rule is clear: “do not bribe anyone, at any time and for any reason”.
This prohibition applies both to activities carried out by collaborators or agents of suppliers or suppliers’ partners. As noted above, violations of the Code will be brought to the attention of the supplier and may result in termination of the business relationship as described at the beginning of this Code.
Anti-money laundering
Suppliers and supplier partners are prohibited from participating in or facilitating transactions anywhere in the world involving funds derived from illegal activities. They must comply with all applicable anti-money laundering laws, rules and regulations of Uruguay and all other countries where they operate. Therefore, all payments and transactions with customers, vendors, suppliers and supplier partners will be examined. We will not accept funds or make payments that appear to be derived from illegal activities.
Gifts, gratuities and business courtesies
Suppliers and supplier partners shall refrain from issuing gifts, gratuities and business courtesies that may create an appearance of favoritism or that may adversely affect the company’s reputation for impartiality and fair dealing.
Social and Environmental Compliance
Frutura Uruguay expects suppliers and supplier partners to conduct business in an environmentally responsible and sustainable manner, including efficient consumption of energy, water and other natural resources, minimizing waste and landfill diversion, and reducing the use of harmful chemicals. At a minimum, suppliers must comply with all applicable laws, regulations and guidelines. Suppliers must obtain and maintain all required environmental permits, approvals and records and relevant reports.
Management systems
Policies and procedures shall be operational, and management shall identify a person or persons at the facility or workplace responsible for monitoring and implementing practices to comply with all applicable laws and regulations and the Supplier Code of Conduct.
Other implementation principles
Emergency preparedness and response: Suppliers shall identify and plan for emergency situations and shall implement and provide guidance to workers on emergency response procedures, including emergency reporting, alarm systems, worker notification and evacuation procedures, drills, fire detection and suppression equipment, exit facilities and recovery plans.
Reporting Violations: The supplier is responsible for reporting any violations of this Code, whether by the supplier, its partners or the company. The supplier shall train its management and supervisory level employees on the obligations created by this Code and shall instruct them to report any violations of this Code. Suppliers should also inform these collaborators that they can do so without fear of reprisal. Suppliers agree not to retaliate against any of their agents, collaborators or partners for reporting any violation. Complaints can be made to the company through its confidential hotline (website, email, phone number).
Suppliers acknowledge that Frutura Uruguay has no obligation to investigate complaints it receives related to the supplier’s operations. Suppliers acknowledge that they are independently obligated to ensure that their company and its partners follow this Code and all other applicable laws and regulations, in accordance with Law No. 18,099 and Law No. 18,251.
Evaluation and compliance: With respect to the performance of our suppliers and outsourced services, these will be evaluated internally, through an evaluation that will be applied annually (maximum every two years), according to compliance with the agreed objectives. In addition, compliance with the principles of this Code may be monitored on site.
Amendments to the Supplier Code of Conduct: Frutura Uruguay is committed to integrating human rights considerations into its decision-making processes, business strategies and risk management practices. We reserve the right to review the policy periodically to ensure its effectiveness and relevance. Frutura Uruguay is committed to make the necessary revisions based on changes in the business environment, laws or best practices.
Communication of the Supplier Code of Conduct: Frutura Uruguay expects its suppliers to communicate clearly and accurately with collaborators and supplier partners and educate them about this Code. Suppliers are expected to maintain adequate training programs for managers, employees, and supply partners to implement the Code’s standards and comply with applicable legal requirements.
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Introduction
At Frutura Uruguay, we value the privacy and security of our customers’ and suppliers’ data. This privacy policy is intended to explain how we collect, use and protect the personal and business information you provide to us to conduct business. Our company is committed to respecting your privacy and ensuring the proper use of your data.
I. Information We Collect
1.1 Personal and business information: We collect personal and business information provided directly to us by means of a contact form sent by e-mail, such as name, company name, RUT or CI, e-mail address, telephone number and mailing address.
1.2 Log Information: When you visit our website, our servers may collect information about your IP address, browser type, operating system, pages visited and length of stay. This helps us improve the user experience and understand how our site is used.
1.3 Cookies and Similar Technologies: We use cookies and similar technologies to collect information about your browsing behavior and preferences on our website. You can learn more about the use of cookies in our Cookie Policy.
II. Use of Information
2.1 Improving Services: We use the information collected to improve our services, personalize your experience on our website and respond to your requests.
2.2 Communication: We may use your information to contact you in connection with our business. If you prefer not to receive these communications, you can inform us to unsubscribe at any time.
2.3 Security and Safety: Your personal and business information is used to ensure the security of our operations and prevent fraudulent activities.
2.4 Legal Compliance: In some cases, we may process your personal information to comply with applicable legal obligations or regulations.
III. Share Information
3.1 Service Providers: We do not share information with service providers.
3.2 Related Companies: We may share information within our company or with affiliated companies for legitimate business purposes.
3.3 Legal Requirements: In certain circumstances, we may be required to disclose your personal and business information in response to legal requests or to comply with government regulations.
3.4 Trusted Third Parties: We will not share information with third parties, such as advertising agencies or business partners, for marketing or promotional purposes.
IV. Data Protection and Security
4.1 Information Security: We use technical and organizational security measures to protect your information against loss, unauthorized access, misuse or disclosure.
4.2 Data Encryption: The information you provide through our website is encrypted using secure encryption technology to ensure its confidentiality.
4.3 Restricted Access: We limit access to your personal information to employees and service providers who need this information to fulfill their job duties.
V. Your Rights
5.1 Access to Information: You have the right to access the personal information we hold about you and to request a copy of it.
5.2 Rectification: If your personal information is inaccurate or outdated, you have the right to request its correction.
5.3 Deletion: You may request deletion of your personal information from our database in certain circumstances.
5.4 Opposition to Processing: You have the right to object to the processing of your personal information in certain circumstances.
5.5 Data Portability: You may request that we provide you with a copy of your personal information in a format that is easily transferable.
5.6 Withdrawal of Consent: If we have obtained your consent to process your personal information, you have the right to withdraw such consent at any time.
VI. Juvenile Policy
6.1 Age Requirements: Our services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under the age of 18.
VII. Changes in the Privacy Policy
7.1 Updates: This privacy policy may be updated from time to time to reflect changes in our privacy practices. Any modifications will be posted on our website along with the updated version of the policy.
VIII. Contact
If you have any questions or concerns regarding our privacy policy or the use of your personal data, please do not hesitate to contact us.
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Introduction
At Frutura Uruguay, we understand the importance of protecting the privacy and security of the data of our customers and suppliers, whether they are individuals or legal entities. This Privacy and Data Security Policy sets out our commitment to manage information securely and comply with applicable privacy regulations. We value the trust our customers and suppliers place in us and strive to protect the confidentiality of their personal information.
I. Collection of Personal and Business Data
1.1 Purpose of Data Collection: We collect data from our customers and suppliers for the sole purpose of achieving proper business exchange.
1.2 Type of Data Collected: The data collected may include, among others, names, company name, RUT or CI, addresses, contact information, payment information.
1.3 Customer Consent: We only collect personal or business data through a form completed by our customers or suppliers, which means an explicit.
II. Use of Personal and Business Data
2.1 Limitation of Use: The data are used only for the specific purposes for which they were collected, to exchange goods and services. We will not use the data for any other purpose without consent.
2.2 Marketing and Communication: If the customer consents, we may use personal data for marketing and communication purposes, such as sending special offers, product updates and newsletters.
III. Personal and Corporate Data Protection
3.1 Data Security: We implement technical, administrative and physical security measures to protect our customers’ personal data against loss, theft and unauthorized access.
3.2 Secure Storage: Personal data is securely stored on servers protected by firewalls and up-to-date security software. We also use encryption technologies to protect data transmission.
IV. Access and Control of Personal and Business Data
4.1 Access to Data: Customers have the right to access their personal data and request copies of the information we hold about them.
4.2 Correction and Deletion of Data: Customers may request correction of incorrect or incomplete data, as well as deletion of their personal data, in compliance with applicable regulations.
4.3 Data Retention: We will retain personal and business data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable regulations.
V. Sharing of Personal and Business Data
5.1 Trusted Third Parties: We do not share personal and business data with trusted third parties.
5.2 No Sale of Data: We will not sell, rent or share personal and business data with third parties for commercial purposes without the explicit consent of the customer.
VI. Legal and Regulatory Compliance
6.1 Legal Compliance: We will comply with all applicable privacy and data protection regulations, according to law 18331.
VII. Transparency and Communication
7.1 Privacy Policy Available: Our Privacy Policy will be available and accessible to all customers on our website.
7.2 Data Breach Notification: In the event of a data breach that may jeopardize the privacy of customers, we will notify those affected and the appropriate authorities as required by data breach notification regulations.
VIII. Staff Education and Awareness
8.1 Staff Awareness: All Frutura Uruguay employees will receive training on privacy and data security policies and the importance of personal data protection.
IX. Responsibility and Supervision
9.1 Responsibility: A designated privacy officer will oversee the implementation of these policies and ensure compliance with privacy and data protection regulations.
X. Privacy Policy Updates
10.1 Updates: These privacy policies will be kept updated and reviewed periodically to ensure their relevance and effectiveness over time.
This Code of Ethics and Business Conduct applies to Frutura Uruguay. Frutura Uruguay is committed to the highest standards of social responsibility practices. Each member of Frutura Uruguay must act with integrity and transparency and provide safe and fair working conditions.
We are responsible for knowing and adhering to the values and standards described in this Code and for asking questions if we are unsure of company policy. If we are concerned about whether the criteria are being met or are aware of violations of the Code, we should contact Human Resources and Compliance management. Frutura Uruguay takes the standards outlined in the Code seriously, and violations are grounds for disciplinary action up to and including dismissal.
The success of our business depends on the trust we earn from our employees, customers and shareholders. We gain credibility by fulfilling our commitments, showing honesty and integrity, and achieving the company’s objectives only through honorable conduct. It is easy to say what we should do, but the proof is in our actions; we lead by example.
When considering any action, it is advisable to ask:
We will only maximize trust and build credibility by answering “yes” to these questions and working daily to build our trust and credibility.
At Frutura Uruguay we believe that we all deserve to work in an environment where we are treated with dignity and respect, bringing out our full potential. Frutura Uruguay is committed to respecting and protecting the human rights, safety and dignity of the people who contribute to the success of our business. We seek to operate responsibly and contribute positively to the community; it is of utmost importance that all our dealings are legal, moral and ethical.
All Frutura Uruguay employees are also expected to support an inclusive workplace by adhering to the following standards of conduct:
Frutura Uruguay will not tolerate discrimination, harassment or any behavior or language that is abusive, offensive or unwanted.
Frutura Uruguay is committed to providing a workplace for its diverse employee population that is inclusive and free from discrimination of any kind and from abusive, offensive or harassing conduct, as set forth in the “Sexual Harassment Complaint Procedure” in Frutura Uruguay’s Internal Regulations. Employees who feel harassed or discriminated against should report the incident to their management or to Human Resources and Compliance.
Frutura Uruguay recognizes the inherent dignity and equal rights of all people. We are committed to upholding and respecting human rights in all aspects of our business operations.
This policy outlines our commitment to conduct business in a responsible and ethical manner, promote a culture of respect and contribute positively to the communities in which we operate and sets out the standards we expect all our suppliers and supply partners to meet when producing and supplying products or labor for Frutura Uruguay no matter where in the world they operate. Frutura Uruguay is committed to complying with all applicable laws and regulations, including but not limited to labor, environmental, safety (i.e. product safety), anti-bribery, anti-corruption and trade laws and regulations.
All Employees shall work on a voluntary basis and shall not be subject to any physical, mental or sexual exploitation, such as forced, bonded and indentured labor. Employees shall not be subject to any form of coercion, fraud, deception or relinquishing control of their person to another person for the purpose of such exploitation. The supplier and its partners shall not support or participate in slavery or human trafficking in any part of its supply chain. Employees must maintain possession or have control of personal identity and travel documents. Employees’ freedom of movement shall not be restricted; nor shall Employees be prevented from terminating their employment.
Wage deductions: Wages will not be withheld, except as required and/or permitted by law.
Employment Agencies: The supplier and supplier partners shall only use employment agencies that are permitted by law to operate and shall ensure that the hiring of employees, whether directly or indirectly, follows the Code, applicable laws and regulations. To the extent prohibited by law, employees shall not pay fees or related costs incurred for the purpose of employment or as a condition of employment.
Employees shall have the right to freedom of association and shall not face unlawful retaliation, harassment or intimidation for exercising these rights as defined in Law No. 17,940 “Freedom of Association. Union Rights”.
Frutura Uruguay is committed to comply with all applicable health and safety laws and guidelines. Frutura Uruguay is responsible for identifying, assessing and mitigating safety and health risks and concerns. In addition, at the start of employment and at appropriate intervals, Frutura Uruguay will conduct health and safety training and communicate health and safety information in local languages. Employees must have easy access to clean sanitary facilities, drinking water and sanitary facilities for preparing, storing and eating food.
In accordance with applicable law, all employees must be at least the legal age established by national law. Official and verifiable documentation of each employee’s date of birth, or a legally recognizable means of confirming each employee’s age, shall be maintained.
Employees under the age of eighteen (18) shall not perform any work that is hazardous or interferes with their education or endangers their health, safety, spiritual development, moral development or social development, and legal restrictions on working hours for employees under the age of eighteen (18) shall be respected.
All employees will receive clear, written information about their terms and conditions of employment through a written contract or offer of employment. The contract/job offer must be in a language that the employee understands before signing any documents. In the case of foreign workers, terms and conditions of employment will be provided prior to leaving their home country.
All employees will receive their salary in accordance with the labor regulations in force for each sector of activity, respecting the legal minimum per task, the corresponding surcharges according to the hours worked and all the additional salary benefits established. Salaries will be paid according to the schedule and legal deadlines for each type of settlement, generating the documents and declarations required by current legislation and presenting them within the corresponding deadline to the competent body or the employee.
The weekly workload will be subject to the labor regulations in force according to each sector of activity. Extra work or work on days off shall be exceptional, voluntary and regulated by labor laws. No exceptions may be made except in cases of emergency or highly seasonal work and/or of an unpredictable nature. Weekly breaks will be in accordance with the regulations, establishing one day off per week, preferably on Sunday. After hours or home office work is not permitted, except for positions where expressly approved.
Frutura Uruguay, its suppliers and supplier partners must not tolerate any form of harassment or discrimination based on gender, gender identity or expression, race, ethnicity, national origin, age, sexual orientation, socioeconomic status, religion, education, disability, political opinion or any characteristic protected by applicable law.
Any behavior, communication or other conduct that creates an intimidating, offensive, abusive or hostile work environment, or otherwise interferes with any employee’s ability to perform his or her job, is unacceptable. All workers will be treated with respect and dignity. Frutura Uruguay, its suppliers and supplier partners must not allow physical or mental punishment or abuse of any team member.
At Frutura Uruguay, we believe that diversity represents a wide variety of differences among our employees. We strive for a diverse, inclusive and equitable workplace where all employees feel valued and respected, regardless of gender, gender identity or expression, race, ethnicity, national origin, age, sexual orientation, socioeconomic status, religion, education or disability.
Inclusion is an essential component of diversity, where our differences are leveraged to create an equitable, welcoming, respectful and dynamic work culture. An inclusive work environment recognizes our differences and actively works to combat barriers to equity.
At Frutura Uruguay, everyone should feel comfortable to speak their mind, especially with regard to ethical issues. Managers have a responsibility to create an open and supportive environment where employees feel comfortable asking these types of questions. We all benefit when employees exercise their power to avoid mistakes or irregularities by asking the right questions at the right time.
Frutura Uruguay will investigate all reported cases of questionable or unethical behavior in accordance with the Frutura Uruguay Employee Complaints and Suggestions Procedure. In each case where inappropriate behavior is found to have occurred, the company will take appropriate action. We will not tolerate retaliation against employees who raise genuine ethical concerns in good faith.
Employees are encouraged, in the first instance, to address these issues with their superiors or Human Resources and Compliance management, as most problems can be resolved quickly. If for any reason, that is not possible or if an employee does not feel comfortable raising the issue with management or HR and Compliance, Frutura Uruguay’s Board of Directors operates an open door policy.
Frutura Uruguay is committed to conducting its business in compliance with all laws prohibiting bribery and other corrupt practices. Frutura Uruguay’s business operations worldwide must comply not only with local anti-corruption laws but also with laws that apply to Frutura Uruguay’s business activities worldwide, such as the U.S. Foreign Corrupt Practices Act (the “FCPA”) and the U.K. Bribery Act. The FCPA prohibits Frutura Uruguay and any business unit in the supply chain from offering or giving “anything of value” to a government official or his or her family members to influence that person in his or her official duties or to encourage improper or illegal conduct. The prohibitions of the UK Bribery Act also cover bribes offered to private entrepreneurs.
Our rule is clear: “do not bribe anyone, at any time and for any reason”.
This prohibition applies both to activities carried out by employees of Frutura Uruguay, suppliers and third parties on behalf of Frutura Uruguay. The company makes improvements to the anti-corruption program based on reported cases.
As noted above, violations of the Code will be reported to Frutura Uruguay and may result in disciplinary action, including separation/termination.
Frutura Uruguay employees are prohibited from participating in or facilitating transactions anywhere in the world involving funds derived from illegal activities and expect the same from our suppliers and their employees. Frutura Uruguay and its suppliers must comply with all applicable anti-money laundering laws, rules and regulations of Uruguay and all other countries where they do business. Therefore, all payments and transactions with customers, vendors, suppliers, agents and affiliates will be reviewed. We will not accept funds or make payments that appear to be derived from illegal activities.
For your information, Frutura Uruguay’s whistleblower policy is as follows:
A whistleblower, as defined in this policy, is an employee of Frutura Uruguay who reports an activity that the employee in good faith believes to be illegal or dishonest to one or more of the parties specified in this policy. The whistleblower is not responsible for investigating the activity or determining failures or corrective actions; the appropriate management officials are charged with these responsibilities. Examples of illegal or dishonest activities are violations of national, departmental or local laws; billing for services not performed or goods not delivered; and other fraudulent financial reporting.
If an employee has knowledge or concerns about illegal or dishonest fraudulent activity, the employee should contact his or her immediate supervisor or Human Resources and Compliance management. The collaborator must exercise good judgment to avoid unfounded accusations. An employee who intentionally submits a false report of irregularities will be subject to disciplinary action up to and including dismissal.
Whistleblower protection is provided in two important areas: confidentiality and against retaliation. To the extent possible, the confidentiality of the complainant shall be maintained. However, disclosure may be necessary to conduct a thorough investigation, comply with the law and provide defendants with their legal rights of defense. Frutura Uruguay will not retaliate against a whistleblower. This includes, among others, protection against retaliation in the form of adverse employment actions, such as layoffs, reductions in compensation, poor work assignments and threats of physical harm. Any whistleblower who believes he or she is being retaliated against should contact Human Resources and Compliance management immediately. A whistleblower’s right to protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.
All reports of illegal and dishonest activities will be reported immediately, investigated and appropriate corrective action will be implemented accordingly.
Employees who have any questions about this policy should contact Human Resources and Compliance management.
Management has the added responsibility to demonstrate, through its actions, the importance of this Code. In any business, ethical behavior does not just happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. Ultimately, our actions are what matter.
For our Code to work, management must be responsible for promptly addressing ethical questions or concerns raised by employees and taking appropriate action to address such issues. Managers should not view employees’ ethical concerns as threats or challenges to their authority, but rather as another encouraged form of business communication.
Frutura Uruguay’s commitment to integrity begins with compliance with the laws, rules and regulations in the places where we do business. In addition, each of us must understand the company policies, laws, rules and regulations that apply to our specific functions; if we are unsure whether a contemplated action is permitted by law or Frutura Uruguay policy, we should seek expert advice. We are responsible for preventing violations of the law and for reporting possible violations.
Contracts with business partners who are not complying with the provisions of this Code of Ethics will be terminated, also in cases of infringement of the law, in case of being involved in corrupt and unethical actions.
An integral part of Frutura Uruguay’s business success is our protection of confidential company information, as well as non-public information entrusted to us by employees, customers and other business partners. Confidential and proprietary information includes financial and pricing data, customer names and addresses, or non-public information about other companies, including current or potential suppliers and vendors. We will not disclose confidential and non-public information without a valid business purpose and proper authorization.
In the case of donations or community investments to charities or advocacy groups, all relevant stakeholders shall be informed and publicly disclosed.
We must avoid any relationship or activity that may impair or even appear to impair our ability to make objective and fair decisions in performing our work.
Bribes in any form, including kickbacks or gifts, are explicitly prohibited in any part of contract payments or “soft dollar” practices. In addition, we prohibit the use of company funds for direct or indirect political contributions, sponsorships or in-kind donations.
Other ways in which conflicts of interest could arise are shown below:
It is not always easy to determine whether a conflict of interest exists. Employees who have a question about a conflict of interest should seek advice from their management. Before engaging in any activity, transaction or relationship that may give rise to a conflict of interest, employees should seek review by their management or the Human Resources and Compliance department.
Frutura Uruguay is committed to compete solely on the merits of its products and services. We must avoid any action that creates the perception that Frutura Uruguay sought, received or provided favorable treatment to external entities in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other benefits from persons or companies with whom Frutura Uruguay does or may do business. We will not give or accept business courtesies that constitute or could reasonably be perceived as unfair business inducements that would violate the law, regulation or the policies of Frutura Uruguay or customers, or that would cause embarrassment or reflect negatively on Frutura Uruguay’s reputation.
Most of the business courtesies offered to us in the course of our employment are offered because of our positions at Frutura Uruguay. We should not feel any right to accept and maintain a business courtesy.
Employees who award contracts or who may influence the allocation of business, who create specifications that result in the placement of business or who participate in the negotiation of contracts must take special care to avoid actions that create the appearance of favoritism or that may adversely affect the company’s reputation for impartiality and fair dealing. It is prudent to refuse a courtesy from a supplier when Frutura Uruguay is involved in the selection or reconfirmation of a supplier or in circumstances that would create the impression that offering courtesies is the way to obtain business with Frutura Uruguay.
Gifts: Employees may accept unsolicited gifts, other than cash, that conform to reasonable ethical market practices, including:
Generally, employees may not accept compensation, fees or money of any amount from entities with which Frutura Uruguay does or may do business. Tangible gifts (including tickets to a sporting or entertainment event) having a market value in excess of $4,000 (UYU) cannot be accepted unless approval is obtained from your management.
Employees who have questions about accepting business courtesies should speak with their management or the Human Resources and Compliance department.
Your relationship with another employee (including sexual or romantic relationships, family relationships, close friendships, roommates or similar relationships, whether one of you is the other’s supervisor or manager) must not disrupt company operations or violate our policies against discrimination or harassment contained in the Internal Regulations.
For the protection of the employee and the company; and to avoid any potential conflict of interest; the following are examples of prohibited conduct between employees in a direct or indirect reporting relationship: dating or asking to date, making or accepting sexual advances, establishing or attempting to establish a romantic or sexual relationship with any employee working under their direct supervision or indirect supervision or management, and close friendships that result in favoritism are prohibited. If you are involved in or become aware of any conduct the same or similar to the above examples, you must report it immediately to Human Resources and Compliance. In addition, if there is a possibility that the relationship goes beyond an employee/subordinate relationship with anyone under your control, this must be reported immediately to Human Resources and Compliance. Thereafter, if appropriate, the Company will review and discuss options with you to eliminate or otherwise address the potential conflict.
We create, retain and dispose of our company records as part of the normal course of our business in accordance with all Frutura Uruguay policies and guidelines, as well as all regulatory and legal requirements.
All corporate records must be true, accurate and complete, and company data must be promptly and accurately entered into our books in accordance with Frutura Uruguay’s applicable accounting principles. Records/documents include, but are not limited to, licenses, permits, certifications, policies and procedures, and employee and facility records.
We must not improperly influence, manipulate or mislead any unauthorized audit or interfere with any auditor engaged to perform an independent internal audit of Frutura Uruguay’s books, records, processes or internal controls.
At times, we are all faced with decisions we would rather not have to make and issues we would rather avoid. Sometimes we hope that if we avoid facing a problem, it will simply go away.
At Frutura Uruguay, we must have the courage to tackle tough decisions and make difficult choices, secure in the knowledge that Frutura Uruguay is committed to doing the right thing. Sometimes this will mean doing more than simply what is required by law. Merely because we can follow a course of action does not mean that we should.
Although Frutura Uruguay’s guiding principles cannot address all problems or provide answers to all dilemmas, they can define the spirit in which we intend to do business and should guide us in our daily conduct.
Company resources, including time, material, equipment and information, are provided for the company’s business use. However, occasional personal use is permitted if it does not affect work performance or cause a disruption in the workplace.
Employees and those representing Frutura Uruguay are expected to behave responsibly and use good judgment to conserve the company’s resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues related to their proper use.
Generally, we will not use company equipment, such as computers, photocopiers and fax machines, to conduct outside business or to support any religious, political or other outside day-to-day activity, except for company-requested support of non-profit organizations. We will not solicit contributions or distribute non-work related materials during work time. Working time” is the time employees are expected to work and does not include rest, meal or other authorized breaks.
To protect the interests of Frutura Uruguay and our fellow employees, Frutura Uruguay reserves the right to monitor or review all data and information contained on an employee’s company-provided computer or electronic device, use of the Internet or Frutura Uruguay’s Intranet. We will not tolerate the use of company resources to create, access, store, print, solicit or send any material that is harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate. Questions about the proper use of the company’s resources should be directed to its management.
Frutura Uruguay is a high-profile company in our community and, from time to time, journalists and other members of the media may approach employees. To ensure that we speak with one voice and provide accurate information about the company, we should direct all media inquiries to members of General Management or first-line management. No one may issue a press release without first consulting with General Management and/or first-line management.
Frutura Uruguay has created an Ethics Committee whose responsibilities encompass oversight responsibilities, including preventing fraud, investigating complaints or violations of the Code of Ethics and conducting an internal audit annually. The committee will accept audit reports for Global GAP (Grasp and FSMA) and that a full audit report and Corrective Action Plans are submitted to the committee. The committee shall provide a report and recommendations of its findings at least once a year. The members of the Ethics Committee shall include, at a minimum:
Frutura Uruguay will investigate all reported cases of questionable or unethical behavior. In each case where inappropriate behavior is found to have occurred, the company will take appropriate action. We will not tolerate retaliation against employees who raise genuine ethical concerns in good faith.
Employees are encouraged, in the first instance, to address these issues with their superiors or Human Resources and Compliance management, as most problems can be resolved quickly. If for some reason that is not possible or if an employee does not feel comfortable raising the issue with management or HR. and Compliance, reports can be made to the company through its confidential hotline.
Possible misconduct will be investigated by the Ethics Committee, under the supervision of the General Management. Each person involved shall cooperate with any internal or external investigation and maintain the confidentiality of the respective investigation. Depending on the situation or complaint received, the need to refer the case to an external entity that can better address and follow up on the situation will be evaluated. Any employee who makes any false or malicious statement regarding an alleged violation of the Code of Ethics may be subject to disciplinary action.
Modifications to the 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 of those already established. The motion shall 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 (two thirds) of the members of said body.
At least annually, all employees and the Human Resources and Compliance team will be instructed on the behavioral expectations based on our Code of Ethics and Business Conduct, as well as how to report, confidentially if they wish, any concerns regarding possible violations of our Code of Ethics. New team members will receive instructions on the Code as part of the induction process.
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.
