This present Code of Ethics (also refereed as "the Code") is a document that communicates the values, responsibilities and codes of conduct governing the activities of Caravela Limited, its employees and all related third parties, within the parameters of personal, collective and corporate behavior, governed by the principles established by the company.

The Code of Ethics is mandatory for all employees of Caravela, and constitutes a set of basic principles with a declarative nature. It is a commitment and duty of all employees to comply with each of the guidelines given in this Code, in each one of their daily activities, performing their duties with prudence, professional judgment and ethical commitment.

Likewise, it is expected that any organisation that has business relationships with our company, as well as its employees, conduct business with the Company adhering to the standards of this Code.


Employees of Caravela Limited, its subsidiaries and affiliates (referred as “Caravela" or “the company”, in this document) should not use the Caravela "Business Liaison" (defined as customers, suppliers, competitors, etc.) for their own benefit. In addition, Caravela employees must not allow personal interests to affect the business of the company.

Therefore, employees of Caravela cannot, either directly or indirectly, through intermediaries or members of its family, have any participation in Business Liaison from any company related to Caravela, without prior written approval of the Management. This prohibition includes having, in any Business Liaison, a capital investment, profit sharing, stock options, commissions, employment or consultancy relationship, participation in boards or other commercial or personal interests in any Business Liaison. This does not include investments in securities, which represent less than 2% of the shares or debt securities from a company.

Before starting his or her job, each co-worker must report in writing, any interest of this kind related to any Business Liaison. Similarly, every co-worker must obtain prior written approval of Management before entering into any new situation that could create a conflict of interest, including commercial relations on behalf of the company with a family member within the third degree of consanguinity or civil affinity.

Paragraph 1.  Receipt of Gifts

If a co-worker receives a gift or any other benefit of a value higher than USD 100 (or its equivalent in local currency) from a Business Liaison, he or she must immediately make a written report indicating the nature of this gift, its provenance and its approximate value.

For this purpose, "funded benefits" includes all objects and services, travel or entertainment received or purchased by a co-worker to a Business Liaison for a value underneath the fair market price. This does not include regular business meals.

Paragraph 2. Loans

Employees must not accept loans or loan guarantees or incurring debt of any kind with any Business Liaison. This prohibition does not include loans on normal commercial terms from recognized financial institutions, as long as these loans are not related to financial activities of Caravela.

No employee will extend loans to, or receive loans from another worker of the companies of Caravela without prior written approval of the Management.

Paragraph 3. Products by Caravela

No employee may obtain any gain or personal benefit by marketing any products of Caravela. Employees must comply with internal purchase policies and resale restrictions of such products.

Paragraph 4. Other activities

Full-time employees may not engage in any other paid work, except for Compulsory Reserve Military Service.  To undertake any other remunerated activity requires prior written approval by the Management.

Paragraph 5. Confidentiality

Employees must keep secret all confidential information from Caravela companies, such as financial information, customer lists, intellectual property, etc., and only disclose it as a contribution to the Caravela businesses, within its established functions.  These regulations will continue even after the completion of the employment contract. Its disclosure or unauthorized use, is considered as a gross misconduct that warrants a disciplinary procedure which may end in dismissal for just cause and could have civil or penal consequences.

If there is any doubt about the handling of confidential or privileged information, its approval should be discussed with the Country Manager.

If private or privileged information is delivered with just cause, the nature of confidentiality must be reported and all third parties must sign a Confidentiality Agreement.

In the same way, Caravela respects the confidential and privileged information from third parties, as well as its intellectual and industrial property. All our employees must respect such rights. For this reason, it is not allowed to use that information for the benefit of the company without prior authorization of its owner.

Paragraph 6. Infringements

The present rules of the Conflict of Interest Policy, which may be amended from time to time, are an integral part of the terms and conditions of employment contracts or service contracts. The violation of any condition mentioned above is just cause to terminate the employment or service contract.


Through the enactment of the following principles of conduct, the company confirms its commitment in order to maintain the balance in supply - environmental demand, on its areas of influence, committing for this purpose to the administrative, operational staff and visitors.

Paragraph 1. Motivation

Caravela is aware that the proper environmental management requires a basic understanding of its ecological balance. Therefore, it promotes the dissemination of its environmental principles and specific programs in this field (Environmental Management is aiming to protect the Environment from pollution and damage directly or indirectly associated with its operations), including its administrative, operational, contractors, visitors and among communities in its area of influence.

Paragraph 2. Environmental Planning

The company activities whose implementation involves some risk for the environment, have an adequate environmental planning.

Paragraph 3. Environmental Protection

All Caravela facilities must meet not only with the environmental protection standards dictated by the national government or local authorities, but are also guided by the best practices and technologies available for environmental protection and conservation.

Paragraph 4. Environmental Responsibility

Good environmental management forms an integral part of academic activities. Therefore, it is the responsibility of each agency and staff working there.

Paragraph 5. Prevention

The actions aimed at the preservation of the ecological balance, will focus more on prevention than on correction of the negative environmental impacts.

Paragraph 6. Preservation and Mitigation

It refers to the conservation and mitigation, both natural and cultural, of the environmental resources when performing activities. 


The company does not discriminate, exclude or makes any distinction on the basis of gender, sexual orientation, religion, race, nationality, disability, age, among others. Caravela has at its core principle the respect for human and children's rights. For this reason, the practices of child labor and slavery are strictly prohibited and are unacceptable to the company.  Caravela promotes free development, welfare, equality and dignity behaviors, in order to favor its employees and the communities where the company operates.


It is the responsibility of employees to take special care of company assets. The above includes the use of all elements and communication tools, such as the Internet, telephones, computer equipment and some other computer, office automation and technological tools, as well as the machines required for the production processes and quality control.  Furniture and company equipment, including cellular devices, regardless of their condition, may not be lent, sold, leased, given away or destroyed.

The company telephones may not be used for long distance personal calls, unless they are specifically authorized or in accordance with the practices adopted by the company. Local calls can be made only if the normal course of business and other activities of Caravela are not affected. Other communication services must not be used for personal purposes.

For additional information about the specific use of computers, the employee can review the company’s Policy for the use of Electronic Equipment and Information. 


In order to fulfill the legal, economic and administrative obligations of the company, we are required to have accurate and reliable records. Supporting documents, accounts, payroll records and all other data, shall be complete, in order and true. All files must be kept in accordance with legal procedures and practices, and in accordance with the rules adopted internally by the company. Employees cannot make any accounting registration, omission or forgery with intent to ignore or distract the true intent of the transaction for his or her personal benefit.


All ideas, techniques, processes or inventions related to the activities within the company and which have been developed by employees or contractors of Caravela during its contract relationship are the confidential and exclusive property of the company.

All materials, ideas, processes, systems or inventions that are not part of the company must be respected, and Caravela should not commercialize them for the benefit of the company.

It is the obligation of every employee to inform to the Internal Control Team of Caravela any theft, plagiarism, copying or misuse of systems, procedures and methods of Caravela.


All company employees should encourage an atmosphere of respect, kindness and transparency, providing timely, specific and accurate information, according to customer needs.

Additionally, we expect our customers to share our principles. For this reason, our Code is published on the company website in order to comply with all the terms established in it, and in the relevant laws and regulations. Therefore, if it is determined that a client is involved in illegal or unethical acts that attempt against this Code, the business relationship must be terminated. 


The relationship between shareholders and management will develop in accordance with the parameters established in the statutes of the company and according to good governance practices.


Caravela seeks to provide opportunities to all suppliers without generating false expectations.  Contract relationship with suppliers is based on quality criteria, transparency, long-term relationship, compliance and competitiveness.

The Company promotes the compliance of the Code, in order to ensure that all suppliers are carrying out their activities under the framework of the laws and established rules. Likewise, all agreements and commitments established in the contracts are respected, and we expect thatcompany's suppliers relate to the company in accordance with the guidelines of the Code.

It is the duty of all, to initiate the necessary actions at the time to observe behaviors that are not aligned with the Code, in order to correct the situation.


Caravela has as its principle to compete with transparent practices of quality and innovation of the products and services, and not from the development of illegal practices. For this reason, it is prohibited to obtain information from competitors of the company that have not been officially published or have not been authorized for delivery. 

Similarly, it is considered as illegal practices pricing arrangements, the supply and price manipulation, so that such practices will be sanctioned in accordance with the stipulated by law.

Therefore, any agreement signed with the company's competitors must have a legal opinion from Caravela legal counsel certifying that the agreemenst do ot violate established regulations.


Caravela rejects any act of corruption, reasons for which bribery and extortion are prohibited, both for negotiations with third parties or internally within the company as well as with organizations outside the rule of law.  Equally, it is forbidden to promise, offer, pay, deliver, claim, demand or receive any amount of cash or in kind, from or to a third party, directly or indirectly, without complying with the authorization levels established according to the company processes.

All activities must start from the principle of transparency and compliance with anti-corruption laws and regulations.

Caravela is committed to conduct its operations in a clear and intact way. Under no circumstance it is allowed the bribery and/or extortion.  If someone in the company is being the subject of bribery and/or extortion in its working relationships within or outside the company, it is necessary to report the situation immediately. Similarly, if there is known the case of a third part that is being subject of bribery and /or extortion, it is required to report it.


It is prohibited to make any transaction in order to hide the real source of illicit funds or to let others know that it has a source of lawful activities. Money laundering involves illegal activities such as terrorism or drug trafficking, among others.

Caravela is committed to complying with the laws and regulations of each of the terriotories where it operates against money laundering and to implement relevant actions for evaluating trade relations that ensure the integrity of the company.


It is a top priority for the company to prevent any kind of labor incidents and safeguard the health and safety of all employees. For this reason, all co-workers are responsible for generating safe work environments and demonstrating safety and health oriented behaviors.

All members of Caravela must be committed and are responsible to report potential health and safety risks identified in the workplace, and stopping any work activity that is considered a risk.

It is the duty of all employees to attendtraining activities and training sessions provided by the company, for identifying risks in the work environment and complying with the laws, rules and standards consigned in the Occupational Health and Safety Management System at Work.


The participation of all employees from Caravela in social media, is of a personal nature and must have no relationship to the company. However, if any employee must use social media on behalf of the Company, the employee must be clearly identified, have written authorization from the Country Manager and comply with the following parameters:

i. Every publication must be aligned with the company principles and values.

ii. Complying with the guidelines about handling of confidential and privileged information.

iii. Be respectful in the forms of expressions used in front of the community.

iv. Do not offer products or services unauthorized by the company, and do not create any false expectations.

v. The use of social media without the express consent of the company, will always be in the personal capacity of the co-worker.


The code of ethics will always be updated, accessible and easy to understand for the employees and business liaison of Caravela.

Paragraph 1. Communication and Update

The company will send a new communication to all employees every quarter. Any questions or clarification on the guidelines listed in this code can be requested to the Human Resources Department. The internal audit of the company will evaluate annually the level of appropriation of the information provided and disseminated in the code of ethics.

Paragraph 2. Penalties

Violations of this Code constitute grounds for sanctions, which shall be applied depending on the seriousness of the misconduct, and may range from reprimand, dismissal, to a criminal complaint with the competent authorities.


Any deviation of this Code should be reported, through the confidential mailbox set up for this purpose:

All messages will be treated in a confidential manner.


The company, and therefore, its employees, respect the laws, regulations and regulatory requirements in each of the geographical areas where it is present.

Regardless of the position that the co-worker performs, an appropriate and correct behavior is expected, according to the principles of the company. Each employee is responsible for exercising control over its own functions, and if it leads a team, must be responsible for monitoring the compliance with the different responsibilities of its staff, in order to fulfill the mission and vision of the company.


The dispositions of this Code of Conduct are mandatory and enter into force in the five (5) business days after approval by the management of Caravela in its original version, as well as the modifications made to its content.