Quality and Code of Ethics

Continuous improvement in process management is a constant in Papelera del Nervión since its foundation. It was in 2005 that Nervión obtained for the first time the ISO 9001:2000 quality certification in our management system, currently having ISO 9001:2015 certification.

Our Quality Policy is focused on the complete satisfaction of our customers. To achieve this goal, we make every effort to meet the ever-increasing requirements and expectations of our customers, as well as the applicable legal provisions, so that we can:

Ensure the highest quality of our products.
Provide assistance to our customers in an efficient and fast way.
Maintain the expectations of our customers in the highest levels of satisfaction in terms of the amount of delivery and time of the same.
Maximum flexibility when adapting to the continuous changes of the market.

QUALITY POLICY

PAPELERA DEL NERVION, S.A., is a company dedicated to the handling, transformation and marketing of packaging materials and other industrial products. In its constant process of continuous adaptation to the Quality and Productivity needs demanded by an increasingly competitive market, it has a Quality Management System..

The General Management expressly states its full and fundamental commitment to comply with the requirements and continuously improve the Quality Management System in order to achieve compliance with the following objectives:

The main objective and the one that guarantees the company’s survival is customer satisfaction.
The Management will promote and support the necessary improvements to achieve the objectives, with the involvement of all personnel.
Quality is always susceptible to permanent and continuous improvement. Failures will become opportunities to learn, and must be used to eliminate the sources or causes that generated them.
Quality requires collaboration and full participation of all hierarchical levels and to that end, information, communication and training are essential.
Contamination prevention.

The General Management ensures that its Quality Policy is understood and accepted by all personnel;
With the help of internal audits, verifies that the Quality System maintains its efficiency and adequacy.

The General Management also assumes a commitment to prevent from pollution and to the rational use of resources due to our activity.

December 2014

Mikel Arzoz, Dirección

Code of Ethics

Papelera del Nervión, S.A. develops and encourages ethical and responsible behaviors along its value chain to meet the expectations of the stakeholders with which it relates, with the involvement of the Management and all its workers.

Our Values and Conducts requirable to third parties outside Papelera the Nervión, S.A.

The relationship with Papelera del Nervión, S.A. must be developed in an environment of trust thanks to transparency in our business relationships, the development of the appropriate channels of communication, commitment to their needs and professional ethics and integrity, based on the following corporate ethical principles or behaviors:

1. Respect and commitment to the confidentiality of personal data: The confidentiality of personal data accessed by reason of our professional activity must be maintained at all times, even after it has been completed. It is essential to implement the necessary security measures to protect confidential or personal data of your own and third parties

2. Commitment to current and applicable legislation: We will not establish any relationship or commercial activity with anyone who has a link and/or promotes illegal business activities.

3. Good faith and honesty: Commercial relations must be conducted with clarity, objectivity, seriousness and honesty by preventing illegal, unethical or fraudulent conduct.

4. Anti-corruption and bribery policy: We do not accept any corruption, bribery or influence-trafficking to carry out a professional activity, either with the public administration or in the private sphere.

Bribery shall mean any benefit offered or paid to influence the decision or conduct of any person whether in the private or public sector, in order to obtain or maintain business or to ensure any unjustified sale such as a license, permit, tax rebate, payment exemption or a favorable administrative or judicial decision.

5. Prevention of occupational hazards: The provisions of the current and applicable legislation on the prevention of occupational risks must be complied with.

6. Compliance in tax and social security matters: Any unlawful practice involving the unlawful circumvention of payment of taxes to the detriment of the public finances and the competent Social Security shall be avoided.

7. Transparency in financial and accounting data: Economic and financial information must faithfully reflect its economic, financial and financial reality, in accordance with generally accepted accounting principles and applicable international financial reporting standards.

8. Commitment against money laundering and irregularity in payments: Money laundering is defined as "participation in any activity intended to acquire, possess, use, convert, transfer, hide or disguise the actual nature, origin, location, provision, movement or ownership of goods or rights in property, knowing that such goods originate from a criminal activity or from participation in a criminal activity".

We will not maintain commercial relations with anyone with relevant evidence of committing crimes either because of their non-identification, misrepresentation of their accounts in order to justify the illicit origin of amounts of money or for receiving unidentified money from illegal and/or opaque activities.

We will also not accept cash payments in transactions amounting to or greater than EUR 2,500 or its value in foreign currency.

9. "Enterprise Secret": It involves guaranteeing, protecting and keeping confidential the professional secrecy ("Know-How") of our company and/or third parties to which it has access for any reason whatsoever.

i. The "duty of secrecy" obliges you to:

a. Not to disclose to any other person, without due consent, information to which he would have had access in the course of his duties, except has been requested by legal imperative.

b. Comply with these conditions already expressed even when the professional relationship with our company has ended, for any reason.

c. Article 197 of the Penal Code safeguards the disclosure of secrets by any person handling personal data. The conduct that is typified in this article is the empowerment by an individual of a secret or disclosure of privacy, of a letter, of papers, electronic messages without the consent of the affected person.

10. Commitment and respect for intellectual property rights: The intellectual and industrial property that corresponds to all the information, ideas, concepts, projects, patents, designs, services, programs, technology, brand, equipment, technology, software, software, software, software, computer programs, know-how, etc. of our company and that of third parties must always be respected.

In particular, physical or electronic information or documentation belonging to Papelera del Nervión, S.A. or another company may not be used as a result of the performance of a previous charge or a business relationship without due prior written consent.

So appropriate controls should be established and ensured to prevent illegal use and acts that violate intellectual property rights in software applications and other computer products.

The license or assignment may only be assigned to third parties of intellectual property rights by prior written formalization of a contract.

11. Commitment and respect for the environment: A responsible attitude to the environment and commitment to comply with environmental legislation and the rational use of resources will be ensured. Therefore, it is necessary to avoid committing any illegal act that degrades the environment.

Commitment to this code

The recipient of this Code must:

i. Respect and ensure compliance with the principles established by the Universal Declaration of Human Rights.

If it is found that the recipient does not respect this Code of Ethics, our company may propose to take corrective measures to normalize the anomaly or may suspend the contractual relationship with the supplier, if proposed to him of corrective action, it has not applied them.

ii. Commit to communicate any act or conduct that may be contrary to the Code or general or sectoral regulations applicable to the following addresses:

§ E-mail to address: canaletico@nervion.net

§ By means of a form of communication of indication or suspected criminal conduct that can be obtained in physical or digital format by requesting it to the headquarters of Papelera del Nervión, S.A. to the attention of the "Compliance Officer" or to the address canaletico@nervion.net.

Management System of Prevention of Criminal Risks of Papelera del Nervión, S.A.

The commission by any of the contracting parties and/or any of the natural persons who are members or dependents thereof, any of the conducts criminalized in the Criminal Code, in accordance with article 31a of the Criminal Code may imply criminal liability of the Legal Person.

Thus, Papelera del Nervión, S.A. will supervise through the tools enabled and available the relationship with the persons, entities or organizations with which they have business relationships to prevent or prevent any illegal behavior.

EWe require our customers and suppliers to comply at all times with applicable laws, proper ethical standards and all commitments resulting from our company's internal policies.

Confidentiality and Protection of Personal Data

Papelera del Nervión, S.A. will take the necessary measures to preserve the identity and guarantee the confidentiality and anonymity of the data corresponding to the person who would have brought the facts to the attention if identified.

The data will be kept in our system only for the necessary time for the investigation of the reported facts. In any case, three months after the introduction of your personal data, our company will proceed to its deletion of the system. If it is necessary to keep it necessary to continue the investigation our company may continue to process your data in a different environment as legally appropriate.

Papelera del Nervión, S.A. will guarantee the confidentiality of all data and background handled and the actions carried out, unless by law or injunction the referral of information is appropriate.