General Declaration of Business Philosophy
Alster Group Holding, LLC & Subsidies
Alster is committed to developing a close and quality service, providing advice with the highest standards of integrity, ethics, honesty that fits the needs of everyone who prefers us. Our solutions are based on 4 main pillars: talent, processes, data and technology. In this way, our behaviors are motivated by innovation and creativity, always safeguarding moral and behavioral integrality, as the respect for the norms and customs of those places where we carry out our actions. Within this behavioral framework, Alster, his collaborators and all members of his network must be bound by our values, the foundations of our organizational culture.
Our values are:
We are moved by our philosophy and vision, committed to the challenges and enthusiastic to be part of Alster and his network.
We act from shared value. We are involved with the needs of our customers, we generate memorable experiences and we are not satisfied with a simply good service.
We take care of our criteria, make conscious and beneficial decisions for all parties. We are transparent in our action. We always seek excellence, but with a focus on humanity.
We seek to make a difference, we take over change and build new ways of doing things. We see opportunities where others see problems, creating unique services and products. We have the courage and ability to change course when necessary.
We get over the standard, committed to doing it right and the first. We make things happen, we are protagonists of change. We learn from our mistakes and improve, we are in continuous beta.
We're building collective talent. We understand that participatory environments strengthen the creative process and speed up work. Listening to the other is key to generating synergy and avoiding misunderstandings.
A conflict of interest may arise in any situation in which the loyalties of a collaborator or member of our network are divided between commercial interests which, to some extent, are incompatible with Alster's interests. Alster strives to create an environment that protects its clients, suppliers and collaborators from such conflicts and hopes that no member of its community will be placed in a position that appears to be, or may be, in conflict with the interests of Alster or its clients.
It is extremely important to identify and avoid any conflict of interest, whether real or apparent. There is a conflict of interest when their private interests interfere in some way or compete with Alster's interests or have the appearance of a conflict.
Unless it is previously approved by the supervisor of a partner or member of our network, neither a partner nor his / her spouse, partner or any other member of the immediate family can have a financial interest directly or indirectly (either as an investor, lender, employee or other service provider) in a competitor, or in a client or supplier if that partner or its subordinates deal directly or indirectly with that client or supplier in the course of their work in Alster. It is vital to maintain our integrity that no one in Alster is influenced or affected by interests or relationships that conflict with the best interests of Alster.
We avoid giving material gifts of any value to customers or potential customers. Brand items related to minimum real value marketing campaigns are our only exception and must run through our authorized areas.
Nor do we accept gifts whose value is greater than $250 USD, from anyone looking for business of any kind with Alster. A collaborator can attend a food / event with a commercial contact, but even in this situation, the costs must be minimal and there should be no sign of quid pro quo.
Normal commercial entertainment, such as meals, musical, theatre, sports events etc. It is appropriate if it is of a reasonable nature and whose purpose is to maintain trade discussions in good faith or to promote better trade relations. All activities must be reported and approved previously by the collaborator's supervisor. No collaborator can accept tickets or invitations for entertainment if the host will not be present at the event with the collaborator.
Wherever you are in the world, and in any industry in which you are operating, we do not accept or receive anything that looks, sounds, feels or smells like bribery.
The following conduct is expressly prohibited:
Laws and customs vary throughout the world, but all partners and members of our network must defend Alster's integrity in other nations as diligently as they would in their own country. In doing business in other countries, it is imperative that the community be sensitive to foreign legal requirements and Chilean laws.
The Alster community, that is, collaborators, members of our network or suppliers, are prohibited from taking advantage of the opportunities that are discovered through the use of corporate property, information or position linked to Alster or its customers, without the express and written consent of Alster. No person belonging to the Alster community can use the property, information or post in or the name of Alster to obtain an inadequate personal gain, nor can he compete with Alster directly or indirectly. Alster's collaborators have an obligation with Alster to promote their legitimate interests whenever possible.
Each partner and member of our network must immediately inform its supervisor or the contact point in charge within Alster about all real or apparent conflicts of interest. It will be the directory of Alster and its members who directly or through delegated commissions will be responsible for the interpretation and application of this Code of Conduct to particular situations and will recommend an appropriate resolution of the conflict.
Confidential information includes all non-public information about Alster, our customers and our collaborators and other people who provide or work for us, as well as our suppliers that, if they are disseminated, could be useful for competition or harmful to Alster or its customers. This could range from information on the work we are doing for specific customers, to the status and performance of the client's staff, or even Alster's strategic plans. We are an open culture and we tend to hire open people, but we must be careful to draw a clear line in this area, particularly around the information of customers who trust our services.
The confidential information about Alster and his operations belongs to Alster. All partners and network members should be aware that, in any competitive environment, property information and business secrets should be protected in the same way as all other important Alster assets. It must not, without proper authorization, give up or release anyone other than Alster's partner, or an Alster's partner who does not need to know, confidential data or information. This information should not be used in any other way than for work. All files, records and reports acquired or created in the course of any relationship with Alster are owned by Alster. The originals or copies of such documents may be removed from the Alster offices for the sole purpose of fulfilling the duties of the Alster partner and must be returned at any time on request.
Each supervisor is responsible for monitoring the disclosure and use of confidential information by the partners under his or her direction. Additional restrictions on the use of confidential information are more fully set out in the confidentiality agreement that each of you signed by accepting a job with Alster.
Alster respects and is diligent in protecting the privacy of the collaborators, customers and members of your network, such as others who provide services or work for us and will comply with applicable data protection and privacy laws.
Alster's property, facilities or physical resources cannot be used for application or distribution activities that are not related to the services of a collaborator to Alster, except for charity activities that have previously been approved by Alster.
No partner or member of the network may negotiate or conclude any agreement with respect to Alster's registered, service or logos without express and written mandate from the Alster General Management.
Similarly, the use of the trade mark or service mark of another company, even one with which Alster has a commercial relationship, always requires authorization or approval of our Legal Area, to ensure that the use of the brand of that other company is appropriate. Employees should avoid unauthorized use of copyright materials from others and should consult with the General Management if they have any questions about the permissibility of photocopies, extracts, electronic copies or the use of copyright materials.
We never alter, adjust or manipulate our reports and records for any reason. We searched and informed the truth.
Alster has adopted controls in accordance with the domestic needs and requirements of applicable laws and regulations. These established accounting practices and procedures should be followed to ensure the full and accurate recording of all transactions. It is expected that all partners, within their areas of responsibility, will adhere to these procedures, as indicated in domestic legislation. Any accounting adjustments that are materially removed from the PAGs should be approved by the General Management and informed to the independent auditors of the Alster.
In addition, all off-balance-sheet transactions, agreements and obligations, quotas or other, and other Alster with non-consolidated entities or other persons must be disclosed to the General Management or Board and to independent auditors of the Alster. If you find or suspect an error in the financial records you are in, you must notify your supervisor, director or general management.
No director, partner or non-partner and member of our network can interfere or attempt to influence, directly or indirectly, the audit of the financial records of the Alster.
The violation of these provisions will result in disciplinary action, which may include dismissal, and may also subject the offender to substantial civil and criminal liability. If a partner is aware of any transaction or misaccounting practice with respect to the resources of Alster, you must immediately inform your supervisor or a member of the Audit Committee of the Alster. It may also raise its concern through one of the options set out in this Code of Conduct. There will be no reprisals against collaborators who reveal questionable accounting or audit matters.
The Alster involved in the preparation of reports and / or documents archived or sent to Alsteras well as those used in public communications made by Alsterthey must generate complete, fair, accurate, timely and understandable disclosures. The Alster they must not knowingly conceal or falsify information, distort or omit material facts necessary to avoid misleading public auditors or independent investors of the Alster.
Alster is committed to a working environment in which all people are treated with respect and dignity. Each individual has the right to work in a professional environment that promotes equal employment opportunities and prohibits discriminatory practices, including harassment. We therefore hope that all relations between people in the workplace will be professional and free from prejudice and harassment.
Alster guarantees equal employment opportunities without discrimination or harassment on the grounds of race, colour, nationality, national or ethnic origin, socio-economic level, religious belief or belief, political opinion, sex, gender reassignment, pregnancy or maternity, age, disability, alienation or citizenship, civil status (or civil society or other society recognized by law), genetic predisposition or carrier status, sexual orientation, gender identity, military service or any other characteristic protected by State or local law. Alster prohibit and will not tolerate such discrimination or harassment. Non-discrimination and anti-harassment legislation Alster is in the Hygiene and Safety Regulation and provides more detailed information on prohibited conduct, complaint procedures and protection against retaliation.
Alster undertakes to provide a safe workplace for all partners. In addition, several laws and regulations impose responsibility for Alster to safeguard against safety and health risks. For this reason, and in order to protect the safety of themselves and others, collaborators and others must follow all the safety instructions and procedures they adopt Alster. Questions about possible health and safety risks Alster or in the customer's offices, they must immediately address the supervisor of the partner.
The Directory of Alster has the exclusive responsibility for the final interpretation of the Code of Conduct. This can be reviewed, changed or amended at any time by the Directory of Alster.
Alster has established a Compliance Committee composed of the CEO, P & C Manager and Administration and Finance Manager. All violations or alleged violations of this Code of Conduct must be immediately reported to the head of the area, General Management, Director of the Alster or the Compliance Committee. If the violation or suspicion of violation involves either of these parties, or concerns accounting, internal controls or audit matters, it must report directly to the Compliance Committee. Alster to email etica @ alsterlegal.com. Reports made in the line of ethics can be made in a confidential and anonymous manner. If you make an anonymous report, provide as many details as possible, including copies of documents that you consider relevant to the case.
Alster It shall immediately investigate all reports of alleged non-compliance with this Code of Conduct and other reported irregularities, and shall determine an appropriate course of action. Reactions in any form against a person who reports a violation of this Code of Conduct or the law, even if the report is wrong or helps in the investigation of a reported violation, are in itself a serious violation of this policy. The acts of retaliation must be reported immediately and properly disciplined.
Alster take appropriate measures against any partner whose actions violate this Code of Conduct. Disciplinary actions may include the immediate termination of the contract or other, more detail of these actions are found in the Regulations on Hygiene and Safety of Alster and in the framework contracts for the provision of services with members of our network. If the organization has suffered a loss, it may pursue its remedies against the persons or entities responsible as permitted by law. If the laws have been violated, Alster cooperate fully with the relevant authorities. It is expected that the entire community of Alster cooperate in internal misconduct investigations.
Any renunciation of any provision of this Code of Conduct can only be granted by the Board. Amendments to this Code of Conduct should be approved by the Board or Compliance Committee.