SQM Code of Ethics

We are a global company committed to excellence. Our activities are mainly focused on producing minerals in a manner that is sustainable and selectively integrated in the processing and commercialization of products destined to industries of paramount importance for human development.

SQM is renowned for its high levels of competitiveness, excellence, and innovation across its business areas in a context of high-standard integrity.

Ethical behavior has, as starting point, the basic commitment that all of us and anyone working with SQM should abide by the law. SQM offers zero tolerance for corrupt activities to anyone working on its behalf, including improper payments or benefits directly or indirectly granted to public officers.

Our leaders are responsible for teaching by example to those they supervise, for building a respectful work atmosphere, and providing guidance to workers when at a crossroad of ethical dilemmas. We count on our leaders to enforce the Code and set an example through their actions. If you are in a leadership position, bear in mind your team is observing your actions as an example.

Our leaders must be able to discuss queries or dilemmas with their workers and be available to help others. All Code-related questions and noncompliance reports that reach their attention must be considered with the utmost seriousness

CONTACT THE ETHICS AND COMPLIANCE MANAGEMENT OFFICE:

You do not necessarily have to know which steps to take in a given situation, but you do have to know when to ask for help. The Ethics and Compliance Management office is ready to assist in more difficult and complex situations. You can reach them at [email protected]

Never will our Code of Ethics be capable of covering all the situations you may be faced to. However, it can certainly serve as the basis for good decision-making. Our Codes contains plenty of references to policies and procedures you can follow to find further information. It is our duty to comply with all current laws as well as with our Code, policies and procedures.

All workers, executives, and Board members from all companies, affiliates and subsidiaries owned and controlled by SQM, irrespective of job tenure, salary, location, or position, must observe our Code. All SQM people are expected to read the Code and be trained on it. We also expect that non-controlled joint ventures adhere to our Code or implement their own codes with the same values and principles

Failure to meet our Code can bring serious consequences for SQM and people involved. Code violations are taken very seriously by SQM senior management to the point they can lead to internal disciplinary actions, like reprimands, sanctions, or even terminations. On their part, public authorities will be able to impose their own sanctions, like fines or even time in prison of people involved

RESPONSIBILITIES OF ETHICS AND COMPLIANCE MANAGEMENT OFFICE

The Ethics and Compliance Management Office is responsible for implementing and keeping our Code updated. If, at some point, you have some doubts about the Code and how to do things right, please contact the Ethics and Compliance Management Office. It is their job to respond those questions and allocate the resources for you to make the right decision and comply with the Code and the law.

If someone becomes aware of a situation that may violate our Code, it is our obligation to report it.. SQM and its leaders commit themselves to taking very seriously all reports submitted in good faith and to protect all parties engaged in an investigation process from any sort of retaliation. 

Raising concerns or reporting a suspicion of Code or policy infringements takes courage. We can feel the pressure to keep quiet or keep away from trouble. However, we admire those who report when they think that something is going wrong or even when a worker may think his/her boss may be a party involved.

Remember it is our duty to report our certainties or suspicions of Code or policy transgressions.

To that end, SQM has made available the following channels for formal reporting:

Hotline assistance:
Chile

Toll-free number
ENTEL: 800-360-312
Movistar: 800-800-288
Claro: 800-225-288

Belgium

Toll-free number
0-800-100-10

USA

Toll-free number
844-330-7095

Mexico

Toll-free number
001-800-658-5454

Spain

Toll-free number
900-99-0011

South Africa

Toll-free number
0-800-99-0123

Ecuador

Toll-free number
1-999-119

China (Shanghai)

Toll-free number
10-811

China (Beijing)

Toll-free number
108-888

Any individual who raises its concerns in good faith will be protected against retaliatory actions. Retaliation can occur in many different ways, such as harassment, intimidation, demotion, or the assignation of unwanted tasks as a result of filing a report in good faith. Retaliation against outspoken workers -in itself a very serious breach of this Code- will be investigated and, if proven true, sanctioned pursuant to the Code and our Internal Order, Hygiene and Safety Regulations (hereinafter “IOHSR”).

A report in good faith is that where the disclosing party strongly believes or thinks it is highly likely that an improper conduct has occurred or is occurring, and where that report has not been submitted maliciously. A report does not necessarily have to be proven to be filed in good faith, though the disclosing party must believe his/her concern for the likelihood of improper conduct is genuine

SQM stakeholders are the groups most affected by our decisions. Specifically, our people, local communities, business parties, and shareholders. These groups must be borne in mind when we make decisions and supply our goods and services. Our actions trigger consequences in the real world and the impact caused on our stakeholders must be taken into account.

People represent our most valued asset. Those of us who work at SQM are valued and respected members of our organization. To get the job done and build trust through respect we must rely on each other, which has been the key to our long-term success

We are more productive when the environment around us is safe and healthy. Some guidelines must be followed to ensure we will work in a safe and efficient way. We are of the belief that practically all workplace safety accidents and risks can be averted. A safe workplace will maximize productivity and reduce losses.

SQM employs, sophisticated equipment and machinery that frequently demand advanced training. It is our responsibility to make sure we receive the proper training before we can operate equipment associated to our job in a safe and responsible way. Should you realize something is unsafe, report it so that it gets fixed and an accident is prevented.

Part of creating a safe work environment means being free of the effects of illegal drugs and alcohol at the workplace. SQM workers are prohibited from consuming or being under the influence of illegal drugs or alcohol during working hours, as in such circumstances people are more likely to sustain accidents that will affect their own and others’ lives. For further information on this topic, refer to our IOHSR.

We give our best when there are no distractions pulling our attention away from our job. We hire, promote, recruit, and make work decisions based on individual skills for a certain position. We make no discrimination based on age, race, religion, gender, nationality, sexual orientation or other personal characteristics under the Non-Discrimination Law. Everyone is treated with the same level of respect.

Not only bullying, mobbing, and sexual harassment buy all forms of harassment are prohibited. Instances of improper actions may include obscene language, physical contact, intimidation intended to humiliate a person or group of people or generate a hostile atmosphere. Among others, it may include obscene gestures, jokes, lewd insinuations, graphic material, threatening or hostile acts, insults, or similar acts

f you are a witness to or suspicious of harassment, discrimination, or bullying actions, report them.

Promoting respectful work relationships to create the conditions necessary for every individual to actively develop its skills is part of what we do while we do our job. We comply with all applicable legal regulations regarding fair working conditions, salaries, maximum working hours, child and forced labor. We foster integration all across our operations and uphold positive practices on human rights. Among such actions we find the total prohibition of recruiting child labor, forced labor, or any similar practice. The number of hours people should work must be in line with the applicable legislation and a fair payment must be made in return.

If you are suspicious that human rights violations are being committed, report it now so that the appropriate measures can be taken

At SQM, company's interests always come first. Conflicts of interests arise when our own activities or personal relationships interfere -or are perceived as interfering- with our ability to serve the primary interests of SQM. Acting in favor of one's own interests when this decision interferes with those of SQM's can affect the company and can even lead other people to question our impartiality. It is important to avoid and disclose real or potential conflicts of interests.

In general terms, people are prohibited from working at SQM while simultaneously working for a competitor company, supplier, customer, or similar party, as our personal interests will be torn between companies.

On the other hand, we must be certain that the workers, suppliers and contractors we select have been recruited for their own worth, value, price, quality, and the best benefit for SQM and not for what is best for us as individuals. For this reason, we must be very careful and properly notify whether we have in mind hiring a relative or close friend or if you are actually working with any of them in the same area and office. For further information on the subject, please refer to our Conflicts of Interests Policy.

Conflicts of interests do not necessarily mean a Code violation. However, failure to disclose an actual conflict, does constitute a Code violation. If you know of, or think you might know of, a conflict talk to your supervisor or contact the Ethics and Compliance Management Office for proper handling.

At SQM we respect the rights to privacy of personal data. For this reason, we ensure that all private personal data will be kept safe and used properly. People with access to private information must actively safeguard their privacy pursuant to applicable laws. Personal data include personal and other identification numbers, dates of birth, financial, medical, and salary information, and contact information, such as phone number, emails, and addresses.

In using company systems, such as email and instant messaging, workers should be careful and apply high ethical standards in their communications. Inappropriate or careless communications can end up in embarrassing or harmful situations for SQM. Pursuant to local legislation, the company reserves the right to monitor the use of systems and access data contained in computers, networks, and other company-owned devices.

SQM will abide by all applicable data privacy laws, like the EU General Data Privacy Regulation (GDPR) and similar local regulations.

We seek to create shared social value with the communities existing in the areas where our operations are based. To that end, we promote local sustainable development and respect for the autonomy of communities by keeping open a permanent engagement and dialogue process conceived to reach mutually beneficial agreements. We create bonds based on transparency, respect, and mutual trust.

We are committed to sustainable development and to strictly abiding by the current environmental regulations in place in each country where our operations are based, ensuring the possible impacts our processes may have on the environment, the responsible management of natural resources, the implementation of protective and preventive measures against contamination, the integration of climate change, and the continuous environmental monitoring will be rigorously assessed while caring for people's, well-being, biodiversity, and the environment.

We take every effort to ensure our job is done in a safe and environmentally responsible way and take good care to verify that all materials and waste are properly managed, according to our procedures and applicable legislation.

It is everyone's responsibility to properly report and correct any environmental violation that may occur within our operations.

Special rules and considerations must be kept in mind when interacting with public entities and public officers. SQM keeps honest relationships with public officers and their respective public entities across the world. Interactions with public officers must be held under a framework of respect and transparency and always under the guidance of our internal procedures and relevant applicable laws.

SQM is subject to different types of regulatory enforcements. If a public officer is visiting the premises for inspection purposes, we must follow the provisions contained in the Protocol for Interactions with Public Officers.

Lobbying is a legitimate activity and an integral part of the democratic process. We must always comply rules governing the meetings or interviews with public officers. Before requesting a meeting with a public officer, we must first know and carefully follow all internal policies applicable to the case.

If you are not sure you are interacting with a public officer or about the right procedure to apply, contact SQM Ethics and Compliance Management Office.

For further information on the topic, refer to our SQM Protocol for Relationships with Public Officers.

Our business partners must observe high ethical standards pursuant to the Code of Conduct for SQM Business Partners. Among these business partners we can find vendors, distributors, agents, contractors, subcontractors, consultants, representatives, intermediaries, joint-venture partners, clients, and other third parties associated to SQM, or any of its subsidiaries or whoever does business on its behalf anywhere in the world.

Extending business courtesies, spending time or sharing a meal of reasonable price with our business partners can strengthen our bonds and offer a unique opportunity to get to know people more deeply.

Before giving or accepting business courtesies we must be well aware of the difference between what is acceptable and what is not. The meals and courtesies we offer must be acceptable and not luxurious, frequent, or given with the intention of receiving something in return. Giving or receiving cash money or its equivalent, such as (gift cards) or vouchers, is strictly forbidden. For further details on amounts and conditions regarding business courtesies, refer to our Procedure for Business Courtesies.

We are active market competitors, but never turn to unethical or unlawful practices to win. That is, we never engage in anticompetitive behavior to obtain a dubious advantage. We always follow two golden rules to guarantee free competition:

Never enter into anticompetitive agreements or understandings. This includes written formal and informal, verbal or “handshake-type” agreements.

Never abuse of a dominant or market-leading position.

If these two rules are followed, we will be avoiding many of the potentially complex activities that could derive into legal troubles for SQM and people involved.

Anticompetitive practices are unlawful and harmful for our clients who must pay extra costs for products and services. We do not need to engage in these conducts as SQM gains will depend mainly on the merits and benefits of its products and services. If we are ever suspicious of an unfair competitive behavior, we must report the case.

In our data collection from competitors and other business partners, we apply legal and ethical tactics only. We respect confidential information from third parties, patents, trademarks, copyrights, trade secrets, and other types of information.

For further information refer to our Policy of Free Competition.

Building a solid reputation may take years but a single bad decision can ruin it. Never more so, when bribery and corruption acts are involved. Bribery, or the act of giving, offering, or receiving - directly or indirectly- something valuable to obtain or retain improper business advantages is a global concern. Corrupt acts generate money and resources for immoral people who damage communities and people. As a company and individuals, we must make our own efforts to root out corruption.

Zero Tolerance for Corruption: We do not pay, offer, or accept bribes to/from public officers or other third parties or tolerate engaging in corrupt acts in any of our business activities. 

We also afford zero tolerance to corrupt actions (where public or other types of officers are involved) from business partners or third parties doing business on our behalf. In other words, others are not allowed to give or offer something valuable on SQM behalf.

There are legal bodies, like the Foreign Corrupt Practices Act (FCPA) that impose severe penalties on companies and individuals caught bribing public officers anywhere in the world. In Chile, Law Nº 20.393 can levy criminal penalties on Chilean companies making unlawful payments, both to public officers as well as to private parties.

Bribes are generally paid to public officers with the purpose of gaining improper advantages. The definition of public officer, contained in our Policy Against Bribery and Corruption, can be a very broad definition (and even different depending on the applicable laws). Basically, it can include a person serving a governmental position, an elected officer, or even a candidate for public office. Payments made to people closely related to public officers can likewise increase the risks of corruption, just as described in our Policy Against Bribery and Corruption. Sometimes it may be difficult to tell whether we are working with a public officer or with someone closely related to one. Therefore, if in doubt, contact the Ethics and Compliance Management Office.

REMEMBER: Examples of improper advantages are wide-ranging and can include secure businesses, obtain information, secure new projects, do favors, or other commercial benefits. Bribes do not necessarily take the shape of money or cash; they can also translate into employment offers, gifts, entertaining, investment opportunities, or any other valuable object.

At SQM all types of improper payment, bribery or corruption are strictly prohibited either to public officers or public entities or individuals.

While working with business partners like vendors, contractors, agents, or distributors any act of corruption committed by any of the parties can be extremely harmful for the company. For instance, if a distributor bribed someone to secure a business for SQM, we might well be liable for those actions as he was acting on our behalf. We must be very clear about the work our partners are doing for us and let them know about our commitment against bribery and corruption.

We do not make facilitation payments. Generally, facilitation payments, also known as commissions or tips, consist of small payments made to public officers to expedite routine functions, such as establishing certain services, processing documents, or issuing visas.

If you are ever asked to pay or to offer a bribe (directly or indirectly through any other person or entity), refuse it and contact the Ethics and Compliance Management Office immediately. If we learn of a situation that involves or might involve a bribe, we should report it. For more information on bribery and corruption refer to our SQM Policy against Bribery and Corruption and other policies, procedures, guidelines, and relevant financial controls.

Investment groups and people with an equity ownership in SQM who provide financial support are specially entitled to receive accurate and timely information. We are also responsible for providing value to our shareholders in a way that satisfies our short and long-term goals.

All information, irrespective of whether it belongs to SQM, to our clients, business partners, or other third parties is treated as confidential. We make sure that all trade secrets and SQM proprietary information be protected against illegal, unauthorized, or irresponsible use. This includes information about SQM operations not publicly available and important for our success and profitability.

We do not use privileged information maliciously. That is, we do not make investments, purchase or sale shares of any company based on privileged information. Neither can we recommend others to purchase or sale shares based on privileged information we may have. That is illegal.

For further details on this topic refer to the Manual for Handling Information of Interest for the Market of Sociedad Química y Minera de Chile S.A.

We protect all information and documents containing material on our patents, trademarks, copyrights, trade secrets, and any other intellectual property. We protect our intellectual property against unauthorized use or improper disclosure. Confidential and proprietary information must be shared only with those explicitly authorized to access it and can be shared on a need-to-know basis.

All SQM assets must be protected. This includes both tangible (computers, earth moving equipment, drills, vehicles, and office equipment) and intangible (patents, trademarks, trade secrets, and copyrights) assets. The use of company assets must be limited to the resources needed to complete our work.

What to Do What No to Do:

Check bank account or make a personal phone call can be allowed if done reasonably.


No to Do: Take home some company equipment at night to use them in personal projects without authorization.

All resources must be spent in a responsible and transparent manner, according to our internal procedures. Personal expenses or others not associated to SQM business will not be reimbursed without proper approval.

Information disclosed to the media, such as papers, journalists, blogs, reporters, and other similar means of communication must be first approved by the CEO and disclosed by the person he appoints. This will ensure the information disclosed is clear and consistent.

You must abstain from using the media or social media in company systems and have always in mind our rules about disclosing and protecting confidential information. In brief, the same provisions ruling the protection of our confidential information apply to the use of social media.

Even when we are not at work we are perceived as ambassadors to SQM. This means that, while our actions or words cannot be seen as a reflection of SQM, others might well see them as coming directly from SQM. Most of the time, social media posts remain in the cyberspace as a permanent record for everyone to see. Remember this next time you use social media.

Our capacity to make intelligent and profitable decisions is mainly based on timely, accurate, and useful information. All the information we disclose about our company must be precise and truthful, in line with SQM legal requirements in order to keep accurate financial records and ledgers. The above includes information provided to government regulators, investors, Board members, our managers, finance team, and others. Each time we include financial statements in annual reports, balance sheets, expense reports, or other documents we must be certain this information is accurate and complete.

Using deceiving information to represent the financial soundness of our company can undermine our long-term success and, many times, violate the pertinent laws. Accounts such as sales figures, expenses, earnings, and invoices must be accurately recorded pursuant to applicable accounting procedures.

SQM has put in place a number of internal accounting controls with the purpose of guaranteeing that the transactions and other provisions regarding company assets be properly reviewed and then duly authorized by Administration. Meeting these important requirements will, in turn, allow us to meet our legal obligations and avoid taking risks.

The Ethics and Compliance Management Office is always available to help you out with challenging or complex situations. You can contact them at [email protected]