The Madera Fiber Technologies Ethical Code defines the rules of business conduct that must be applied to our day-to-day relations both internally and with our partners.
It also serves as a guide for developing a sense of responsibility as well as staff involvement.
The standards set out in the Ethical Code are not exhaustive and, combined with our employees’ sense of responsibility, they establish the fundamental rules of business conduct guidelines applicable to both Madera Fiber Technologies employees and partners.
In any case these rules replace the laws or regulations in force in the different countries, neither they replace the principles and rules arising from other internal policies and procedures within Madera Fiber Technologies.
Each Madera Fiber Technologies’ employees and managers must comply with the Ethical Code and ensure that it is distributed to all employees and that each employee adheres to it.
I. Respect for fundamental Human Rights →
II. Development of economic and social dialogue →
IV. Ethics and rules of business conduct →
V. Reporting infringements to the Code of Ethics →
Madera Fiber Technologies and their employees shall respect the laws regulations in force in the countries in which they are based.
Madera Fiber Technologies complies with national legislation and regulations governing child labor.
In any case, it will not employ children under the age of 16, and complies with the provisions of the ILO regarding the health, safety and morality of young people aged between 15 and 18.
Madera Fiber Technologies ensures that its suppliers and partners adopt the same provisions
Madera Fiber Technologies undertakes to ensure freedom of choice in employment and to eliminate all forms of forced and compulsory labor.
Madera Fiber Technologies ensures that its suppliers and partners adopt the same provisions.
Madera Fiber Technologies undertakes to implement actions aimed at respecting the environment and improving its protection.
In carrying out their daily activities, all Madera Fiber Technologies employees are made aware of their responsibilities towards protecting the environment, especially through the following commitments:
Madera Fiber Technologies undertakes to:
Madera Fiber Technologies undertakes to implement active policies and methods to prevent risks that may affect employee health and safety, to regularly check their correct application and measure their efficiency.
In particular, the company undertakes to ensure its officers and employees take responsibility for protecting health and preventing accidents in the workplace, and to ensure the design and development of its products and production facilities in such a way as to promote the best working conditions possible..
All subcontractors working on the premises of Madera Fiber Technologies shall be expected to apply these health and safety policies and to conform to all legislation in force in the country.
Madera Fiber Technologies seeks to develop a relationship of trust at all levels of the company by inviting its employees to express themselves freely, in particular concerning the improvement of their workplace environment.
The quality of discussion and communication between each employee and his or her superior is a central component of the company´s social dialogue..
Madera Fiber Technologies undertakes to inform and consult in a timely manner the employee representatives in each legal entity or the employee representatives at European level, and to conform to the legal obligations specific to each country.
Madera Fiber Technologies recognizes the existence of trade unions worldwide and the right of workers to form the union organization of their choice and / or to organize workers’ representation in accordance with the laws and regulations in force.
It undertakes to protect union members and leaders and not to make any discrimination based on the offices held
The company undertakes to promote a policy of consultation and negotiation. Given its decentralized legal and managerial structure, this policy is enshrined in collective bargaining agreements signed with the individual establishments, on the one hand, and companies, on the other.
Due to its program-based activity, Madera Fiber Technologies must constantly adapt to the life cycle of products (launch, development and end of life), and must accompany its customers in their international growth. The company industrial and social redeployment constantly supports these changes.
Whenever possible, Madera Fiber Technologies will adopt a forward-looking approach to its industrial and social redeployment operations in order to limit the social impact..
Within this context, each of the restructuring operations will involve an in-depth industrial, economic and social dialogue as part of the strategic orientations defined by Madera Fiber Technologies:
In its recruitment actions and career management, Madera Fiber Technologies undertakes not to make any discrimination, in particular on the basis of age, gender, skin color, nationality, religion, health or disability, sexual orientation, political or philosophical opinions or trade union allegiances.
All employees have the right to work in a healthy environment, free from any form of hostility or harassment qualified as unlawful under the regulations and practices in force in the countries.
In particular, Madera Fiber Technologies forbids any unlawful conduct construed as sexual or moral harassment, even in the absence of any direct relationship of seniority or subordination.
Madera Fiber Technologies undertakes to promote professional training to encourage the professional insertion of young people, by fostering:
Given the specific nature of its activities and the need to capitalize on its expertise to ensure control over its programs, Madera Fiber Technologies considers the internal development of its workforce’s employability a priority.
Madera Fiber Technologies encourages each employee to participate actively in his or her professional development, and undertakes to ensure equal opportunities for professional development.
Madera Fiber Technologies encourages geographic and professional mobility within the company to develop its workforce’s employability. Particular attention is paid to managing internal mobility to make sure of its short- and mediumterm relevance.
The use of Madera Fiber Technologies’s funds, services, or assets for any unlawful or improper purpose is strictly forbidden. No individual or company shall engage in the practice of purchasing privileges or special benefits on behalf of Madera Fiber Technologies through the payment or receipt of bribes, gratuities, or other forms of payoffs, in cash or in other benefits. Likewise, no company or individual (domestic or foreign) shall accept money or benefits in kind in infringement of any law or regulations.
1.2 Prohibition of all political contributions
Madera Fiber Technologies makes no payments and provides no services to political parties, elected officials, or candidates for office, even when the lawful nature of such contributions is recognized pursuant to laws in countries where such payments might be made.
1.3 Prohibition of all illegal payments to government agencies or their employees
No payment may be made in the hope of obtaining favorable action from a government or administrative agency. Gifts, services, or lavish entertainment offered to government or administrative employees or officers are forbidden since they may be construed as attempts to influence government or administrative decisions in matters affecting Madera Fiber Technologies.
1.4 Truth and accuracy of accounts, books and records
All assets, liabilities, expenses, and other transactions carried out by Madera Fiber Technologies must be recorded in the companies’ books and accounts which are to be kept truthfully and accurately, in accordance with the applicable accounting principles, rules, and laws.
No undisclosed funds or unrecorded assets of Madera Fiber Technologies shall be established or maintained for any reason whatsoever.
Documents pertaining to commercial or financial transactions must reflect these transactions faithfully.
No payment may be approved or made with the intention or understanding that all or any part of such payment is to be used for any purpose other than that described in the documents supporting said payment. No false or artificial entry may be made in the books and records of the company or its subsidiaries for any reason whatsoever.
2.1 Restrictions on gifts and entertainment from customers and/or service providers
Madera Fiber Technologies policy forbids the acceptance of any gift or gratuity from customers or suppliers in any form whatsoever (in particular, cash/monetary payments, merchandise, services, entertainment, or travel) valued at or more than the equivalent of one hundred (100) euros per year and per business partner. except in extraordinary cases in accordance with Madera Fiber Technologies internal policies.
If gifts or gratuities are received, they are to be returned immediately to the giver.. When it would be discourteous to refuse or to return the gift, the employee must inform to his/her Manager, who will determine what steps, if any, to take with regard to the gift pursuant to this Code. In all such cases, the employee must ask the customer or supplier to refrain from giving such gifts in the future.
It is strictly forbidden to offer and/ or accord any cash or cash-in-kind for gratuity purposes, sponsorship deals or for other purposes to any representative of a customer or a supplier, directly or indirectly, in order to obtain a contract or any other commercial or financial benefit.
In all instances, according gifts and/ or favors valued at the equivalent of one hundred (100) euros or more to potential or current customers or suppliers is strictly forbidden, except in extraordinary cases in accordance with Madera Fiber Technologies internal policies.
2.2 Supplier and service provider selection
The selection of suppliers or service providers for Madera Fiber Technologies must be based on quality, need, performance, and cost. During negotiations with suppliers and service providers, it is the responsibility of each Madera Fiber Technologies employee and officer to promote the company’s best interests within legal limits, to seize the best opportunities, and to obtain the best possible business conditions, without reliance on favoritism resulting from friendship or using any discriminatory criteria forbidden by the Madera Fiber Technologies Code of Ethics.
2.3 Consultants and other service providers
Under our Purchasing procedures, agreements by and between Madera Fiber Technologies and its agents, representatives, and consultants, or any other service provider must clearly list the actual services to be performed, the basis for fees or the price, and all other terms and conditions. All payments must be determined and paid in relation to the actual services provided. Agents, representatives, and consultants are forbidden to act on behalf of Madera Fiber Technologies unless explicitly authorized to do so in writing by duly empowered company representatives.
2.4 Prohibition of all investments in suppliers
No employee or officer may directly or indirectly invest in a supplier working with Madera Fiber Technologies, a supplier’s parent company or its subsidiaries, nor may an employee or officer lend funds to them, with the exception of purchasing securities traded on a regulated market within the limits established by regulations in force.
2.5 Prohibition of purchasing goods or obtaining services from suppliers or customers for personal use
Employees and officers may not use their connection with Madera Fiber Technologies to obtain the same advantages for their own personal purchases as those granted by the supplier or customer to Madera Fiber Technlogies, unless it is explicitly stated in the contract between Madera Fiber Technologies and the supplier or Madera Fiber Technologies and the customer.
Madera Fiber Technologies believes in strict compliance with the rules and laws governing competition in force in the European Union and each Country where Madera Fiber Technologies does business. The rules and laws of fair competition forbid any written or unwritten understandings, agreements, plans, arrangements, or schemes among competitors involving price, territory, market share, and/or customers
Madera Fiber Technologies is committed to monitoring due conformity with these commitments.
Madera Fiber Technolies’s employees and officers are therefore forbidden from entering into such agreements or understandings with Madera Fiber Technologies’s competitors.
In addition, no manager may seek to obtain from an employee commercially sensitive or confidential information relating to a former employer of a Madera Fiber Technologies employee. No Madera Fiber Technologies employee or officer shall seek to use commercially sensitive or confidential information obtained during a former employment during the course of employment with Madera Fiber Technologies. In all circumstances, the exchange, or actual or attempted use within Madera Fiber Technologies of commercially sensitive or confidential information belonging to a competitor or former employer are prohibited.
Further, it is mandatory that any employee wishing to join a professional association whose membership includes competitor representatives obtain written approval from his or her superior Human Resources Manager.
4.1 Confidentiality of employees’ personal data
Madera Fiber Technologies and their employees must pay particular attention to complying with all laws and regulations relative to the protection, use and confidentiality of personal data.
The information relative to employees’ private lives, and performance assessment, promotion and salary must be kept confidential. Access to this type of information is reserved for authorized personnel only..
As a result, Madera Fiber Technologies employees:
4.2 Confidentiality and protection of Madera Fiber Technologies assets, documents and data
Files, assets and technical data and other confidential Company information are important assets that may be critical in preserving Madera Fiber Technologies’s results and competitive edge. All these elements are the property of the Company and must be returned by the employee on termination of his or her employment contract. The following in particular are of a confidential nature: information concerning the existence, terms and conditions of projects and commercial agreements of Madera Fiber Technologies, Company financial and technical data, and all other sensitive data, such as that relative to production unit sales, intellectual property rights, technology, computer software or hardware used in the normal practice of its business.
It is forbidden for all Madera Fiber Tecnologies employees to divulge this information to third parties without prior authorization, or to other Madera Fiber Technologies employees without the authority to access this information..
Any use for personal purposes, directly or indirectly, of information obtained in the course of the employee’s professional activity is strictly prohibited..
Any infringement of this rule may result in legal action under the applicable provisions in employment law, civil law or penal law..
All the above provisions apply in the same manner to information supplied by our clients.
Persons whose employment contract has expired or who are no longer contractually bound to the Madera Fiber Technologies by an employment contract shall maintain confidentiality of all this information.
Madera Fiber Technologies employees and officers must loyally perform their duties and assignments.
Madera Fiber Technologies considers that executive and management positions within the company require a full-time commitment. Therefore, no executive or manager may hold a second job, or own or operate a business that requires active use of his or her own time without the express authorization of the Human Resources Manager.
A conflict of interest exists when an employee or a close relative is liable to benefit personally from a transaction involving a company in the Madera Fiber Technologies, in particular with customers or suppliers.
Likewise, when an employee attempts to choose or have a company chosen, especially as a supplier, in which he or she, or a close relative has a direct or indirect financial interest..
When in doubt, the employee must refer to his or her superior to determine whether or not the transaction in question constitutes a conflict of interest.
Madera Fiber Technologies employees and officers are responsible for the proper use of the company’s assets and resources, including those involving intellectual property, technology, or computer hardware and documents, software, real estate, plant equipment, machinery and tools, components, raw materials and company liquidity (“the assets”).
To this end, Madera Fiber Technologies employees and officers must, in particular:
Any company employee aware of any infringement of the rules set out in the present Code may bring the matter to the attention of his or her superior or the General Management: – Through the internal reporting procedure.
No employee may be punished, dismissed or be the subject of discriminatory measures for having reported in good faith, or for having recounted actions infringing the Code of Ethics.
However, the wrongful use of these procedures exposes the perpetrator to disciplinary action or prosecution
Internal reporting procedure
Any company employee aware of any infringement of one or more of the rules set out in the present Code may bring the matter to the attention of his or her superior or HR Manager.
The referral to the superior or the HR Manager may be made verbally or in written form.
Depending on the nature and importance of the facts recounted, additional investigations may be launched, an inquiry carried out or the decision taken to implement an internal audit procedure.
The person implicated must be advised of the procedure concerning him or her. If protective measures are required, the person implicated shall be advised after such measures have been taken.