CONFLICTS
OF INTEREST

4.0
[ethics]
A conflict of interest exists when an employee’s personal interests may interfere with the proper performance of their professional duties, thereby affecting impartiality and objectivity in decision-making.

We do not use our position to obtain advantages for ourselves or for third parties. We avoid any situation in which our loyalty could be, or appear to be, compromised. The Audit Committee and the Corporate Practices Committee may issue opinions regarding specific conflict of interest matters brought to their attention.

4.1    PROVISION OF SERVICES TO ANOTHER EMPLOYER

Any additional employment or professional engagement undertaken by an employee shall not interfere with the fulfillment of their obligations and responsibilities to DESC or create a conflict of interest with DESC.
código de conducta, DESC

4.2     EMPLOYMENT RELATIONSHIPS WITH SUPPLIERS AND CUSTOMERS

A conflict of interest exists when an individual is employed by DESC or any of its companies while simultaneously maintaining an employment relationship with a supplier or customer of the Group.
código de conducta, DESC

4.3     COMPETING WITH DESC COMPANIES

Directly or indirectly participating in, or becoming involved with, businesses or activities that compete with any DESC company is strictly prohibited.
código de conducta, DESC

4.4     USE OF MATERIAL NON-PUBLIC INFORMATION

This refers to any acts, events, facts, or circumstances of any nature that influence or may influence the market price of the securities of DESC or any other company within the Group, commonly referred to as Material Events, which have not been disclosed to the investing public.
código de conducta, DESC
Directors, Officers, and Employees who possess material non-public information shall refrain, including but not limited to, and in accordance with applicable law and DESC’s internal Policies, from:
  • Directly or indirectly purchasing, selling, or otherwise trading in any securities issued by DESC or its affiliated companies.
  • Disclosing such information to any person, including family members, members of management, suppliers, or customers.
  • Recommending that any person engages in securities transactions based on access to material non-public information.
Such activities are unlawful and may result in civil and criminal penalties.

4.5     RELATIONSHIPS WITH FAMILY MEMBERS AND FRIENDS

A conflict of interest may arise where romantic relationships, domestic partnerships, or relationships by blood or marriage exist, are initiated, or are maintained between:
  • A supervisor and any individual who reports directly or indirectly to such supervisor.
  • DESC employees who maintain such relationships with personnel employed by Customers and/or Suppliers.
These relationships create an inherent presumption of favoritism, abuse of authority, or conflicts of interest, potentially affecting the work environment and objective decision-making.

If any employee detects, identifies, or becomes aware of any such situation, they must reported it immediately through the Feedback and Transparency Hotline.

4.6     OWNERSHIP INTERESTS OR FINANCIAL INTERESTS IN OTHER COMPANIES

We avoid holding any direct or indirect ownership interest or financial interest in any current customer, supplier, or competitor where such interest could give rise to a conflict of interest with DESC’s business activities.
código de conducta, DESC
Ownership interest or financial interest” means acting as a partner, shareholder, or an immediate family member of a partner or any employee of any company or legal entity that is a customer, supplier, or competitor of any DESC business.

If the existence of such a financial interest becomes known, it must be disclosed to the Business Director, who shall refrain from participating in any decision involving the relevant third party and, where appropriate, submit the matter for approval by General Management. If a Director is subject to such circumstances, the matter shall be submitted for consideration by the Audit Committee and the Corporate Practices Committee.