SQM Code of Ethics

FAQs

Should I report using either the Internet Form or the telephone?

With this channel, you can file a confidential and potentially anonymous report using the report form or the phone. Either way, it is important to use only one mechanism and not both simultaneously regarding the same claim to prevent a duplication of cases.

Is it possible to make a report anonymously?

Yes, the platform allows you to report anonymously. However, if you choose to provide your information, we will be able to follow up on the case more effectively.

You need to know that in some cases, local legislation requires that the report be submitted with the identification of the affected person. If the reporter fails, the investigator in charge may ask for the affected person's name or investigate another classification, given that the legal requirements weren’t fulfilled.

Is the platform secure and confidential?

Yes, our platform is protected with high security standards to ensure the confidentiality of your report and protect your identity.

What do I do if I do not have access to the platform?

If you do not have direct access to the platform, you can file your report via email sent to complianceny@sqm.com

Can I make a report by another means if I cannot use the platform?

Yes, you can also make a report by email or by calling the ethics hotline.

What type of situations should I report?

You can file a report regarding any situation that may violate our Code of Ethics (the SQM’s or the Iodine Plant Nutrition's), internal policies, or national or international law.

Is it necessary to have evidence to make a report?

Reports must be made in good faith. Having proof when making a report is not mandatory, but additional evidence or information can help make the investigation more effective.

Can I make a report if I am not a direct witness?

Yes, you can report suspicious behavior even if you are not a direct witness, as long as you have reasonable grounds to believe it has occurred.

What should I do if I am not sure if something is reportable?

If you have doubts about whether a situation is reportable, you can make an inquiry through the channel, and the Compliance team will guide you.

How do I know if my report has been received correctly?

You will receive an automatic acknowledgement in your email, confirming that your report has been received.

Who will see my report?

Depending on the nature of the case, a team of trained professionals, such as Compliance, Audit, HR, or an external investigator, will review the report.

What is the estimated time to receive a response to my report?

The response time varies depending on the complexity of the case. However, we are committed to keeping you informed and will provide timely updates.

Can I request an update on the status of my report?

Yes, you can request an update on the status of your report at any time through the platform or by contacting the Investigation team directly.

What happens if the report is unfounded or false?

Malicious or unfounded reports will be evaluated under the company's internal policies, and if malicious intent is proven, appropriate action will be taken.

How is the investigation of my complaint conducted?

Once the complaint is received, a rigorous investigation will begin, which may involve interviews, gathering evidence, and reviewing facts. The process will be handled impartially and with appropriate confidentiality.

How long will the investigation take?

The length of the investigation will depend on the complexity of the case. However, we are committed to completing it efficiently and keeping you informed.

Can I find out who is investigating my complaint?

The investigator assigned to your case will be notified early in the process. However, specific details about internal investigation procedures may be confidential.

What if the report involves a senior manager?

Suppose the complaint involves a member of senior management. In that case, it is ensured that the investigation process will be conducted with appropriate oversight and by impartial personnel to avoid any conflict of interest.

What if the report involves a member of the Ethics and Compliance Management?

Suppose the complaint is against a member of the Ethics and Compliance Management. In that case, such a member shall not know about the complaint and shall not participate in the role of investigator. By naming a person as a respondent, the system automatically excludes them from the case referral. However, complaints against Ethics and Compliance Management members may be filed directly with the Head of Audit and Risk by email.

Will any action be taken against the person reported?

If the investigation determines that there has been a violation of company policies or the law, corrective action will be taken, ranging from training to disciplinary sanctions.

What if I fear retaliation for making a report?

The company has a strict policy against retaliation. Any retaliating attempt will be taken seriously, investigated, and punished accordingly.

Can I make recommendations to the company through the whistleblower channel?

Yes, the channel is not only designed for whistleblowing; you can also ask questions, make suggestions, or comment on topics related to compliance and ethics.

What should I do if I have questions about the channel or whistleblowing?

If you have questions about using the channel or need guidance with the reporting process, contact the Compliance team for additional assistance.

What information do I need to provide when making a report?

When making a report, we ask you for key information such as a detailed description of the incident, the people involved, relevant dates, and any available evidence. The more information you provide, the easier it will be to investigate the case.

Can I make a report in any language?

Yes, the reporting channel is available in several languages. However, we recommend using the language in which the procedure is handled within the company for a faster investigation.

Is there a time limit for making a report?

There is no specific time limit for filing a report. However, the sooner the report is made, the easier it will be to investigate and take corrective action.

Can I report an incident that occurred in the past?

Yes, reports about past incidents are equally valid, as long as they involve behavior that is still relevant and violates company policies.

Can I make a report if the reported behavior occurred in another country where the company operates?

Yes, the whistleblower channel is available to report incidents in all company locations. Investigations will be conducted under local and international regulations.

What if I make a report in error?

You can contact Compliance Management to correct the information if you realize you have made a reporting mistake. The company appreciates any attempt at clarification or correction.

Is the complaint process the same for all employees?

Yes, the process is the same for all employees, suppliers, and other interested parties. Everyone must follow the same procedures to ensure fairness and consistency in investigations.

Can I make a report about something that happened outside of my workday?

Yes, if the incident is work-related or affects the company, you can report it regardless of when or where it occurred.

Is it possible for my report to be dismissed?

If the investigation concludes that there is insufficient evidence or that the behavior does not violate company policies, the complaint will be dismissed.

What do I do if I disagree with the resolution of the investigation?

If you disagree with the resolution, you can request a case review through the appeals channel or contact Compliance Management to discuss your concerns.

Can I participate in the investigation?

You will not be asked to participate actively in the investigation if you do not want to. Still, if you are a witness, you may be called upon to provide further information or clarification if necessary.

Will the investigation process affect my work or relationship with the company?

The investigation will be conducted impartially and should not affect your work or relationship with the company. If you are a victim of retaliation, it will be investigated as a separate offense.

What if I feel pressured or threatened because I have made a report?

If you think you are being pressured or threatened, report it immediately to the Ethics and Compliance Management. The company has strict policies against retaliation and will take strong measures to protect you.

Are there any incentives for making a report?

We do not offer incentives for making a report, as the channel is intended to ensure compliance with company policies and integrity.

What happens if I regret making a report?

If you regret it, you can withdraw it, but your report will already be evaluated and processed according to procedure. The investigation will proceed regardless of the withdrawal.

If I see a violation, shouldn't I report it to my manager, security, or human resources and let them deal with it?

When you observe behavior that you believe violates our code of conduct or other policies, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager or another member of our management team. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. For such circumstances, we have partnered with NAVEX. We would rather you report anonymously than keep the information to yourself.

Why should I report what I know? What’s in it for me?

We all have the right to work in a positive environment, and with that right comes the responsibility of acting ethically and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the very existence of an entire company.

Does management want me to report?

We certainly do. We need you to report. You know what is happening in our company, both good and bad. You may have initial knowledge of an activity that may cause concern. Your reporting can minimize the potential negative impact on the company and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

I know some individuals act unethically, but it doesn't affect me. Why should I bother reporting it?

Our company promotes ethical behavior. At any level, all unethical conduct ultimately hurts the company and all employees, including you. You only have to consider what happened in recent corporate scandals to see the disastrous effects that a seemingly harmless lapse in ethics can have on an otherwise healthy company. So if you know of any misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The EthicsPoint system and report distribution are designed so that implicated parties are not notified or granted access to reports in which they have been named.

What if I remember something important about the incident after I file the report? Or what if the company has further questions about my report?

When you file a report at the EthicsPoint website or through the EthicsPoint Call Center, you receive a unique, randomized number called a “Report Key” and are asked to choose a password. You can return to the EthicsPoint system by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative. We strongly suggest you return to the site within the specified time to answer company questions. You and the company have now entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

Can I file a report from home and remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name, and the EthicsPoint system strips away Internet addresses to maintain anonymity.

What if I lose my Report Key or forget the Password I created?

To ensure that security and confidentiality are maintained, if you lose your report key or password, you will need to file a new report. The new report should mention that it is related to a report or question you previously submitted.

To Make a Report

After you complete your report, you will be assigned a unique code called a "report key." Write down your report key and password and keep them in a safe place. After 10 business days, use your report key and password to check your report for feedback or questions.