1 INTRODUCTION

In search of an optimal relationship with its suppliers, PROINTER develops this Supplier and Purchasing Policy that aims to regulate commercial relationships for the benefit of lasting agreements and mutual satisfaction, allowing the best economic, quality and service results to be obtained.
This Policy highlights the integrity and compliance of suppliers with current legislation in terms of labor, tax, human rights, data protection, security and confidentiality and environmental protection.
Purchasing is one of the key functions of the company due to its high impact on society. PROINTER establishes the following Policy to ensure that the professional purchasing activity is carried out correctly, in accordance with the criteria and purposes of corporate interests.
With this Policy, PROINTER conveys values, principles and guidelines of conduct to regulate any customer-supplier relationship and establish a way of acting in all purchasing processes.
Meeting the demands of PROINTER’s recipients is a constant challenge that involves continuous evolution in adapting to the dynamics of an increasingly demanding market. To meet this challenge, it is essential to collaborate with trusted suppliers who provide solidity to the process chain.

 2 SCOPE OF APPLICATION

This Policy applies to all persons involved in the procurement and contracting process of PROINTER suppliers, ranging from negotiation to award and contracting.

3 OBJECTIVE

PROINTER’s objective is to consolidate stable and lasting relationships with its suppliers based on its values with which it can respond to the needs and expectations of the company’s recipients. Through this Policy, PROINTER establishes the main bases under which a purchase action (whether of products or services) must be executed, in order to establish a management style that guarantees objectivity, transparency and excellence in the purchasing process and achieve optimal management in terms of efficiency to meet PROINTER’s objectives.

With this Policy, the company aims to meet the following objectives:

• An adequate quality-price ratio in commercial transactions with PROINTER suppliers.
• To supply goods and services according to the established level of service.
• To offer its recipients quality goods and services.
• Systematically incorporate collaboration with suppliers aimed at innovating, developing and improving products and services and internal processes.
• Promote and take advantage of the technological advances offered by suppliers to reduce negative environmental impacts.
• Regularly include social and environmental criteria in purchasing decisions that contribute to creating a socially responsible value chain.
• To guarantee compliance with the commitments acquired and the legislation in force.

4 PRINCIPLES OF ACTION

To meet these objectives, PROINTER develops and continuously improves a purchasing management system based on the following elements:

• Do not be influenced by personal relationships or by the interest of employees when awarding or contracting a service. No employee of PROINTER will obtain any benefit from the award of a contract, and the acceptance of any object or incentive that may influence the objective criteria of contracting is prohibited.
• Know the expectations and needs of the beneficiary in order to offer the highest quality in their processes and their final product and/or service, and not carry out contracts that do not meet criteria of need, suitability and austerity.
• Develop processes that enable continuous active listening with suppliers to ensure knowledge of their expectations, favouring management, decision-making and the commercial relationship, and ultimately promoting profitability for both parties.
• Develop mechanisms that allow knowing the trends and evolution of the market in the different categories of suppliers related to the business field.
• Define approval criteria for all suppliers prior to purchase.
• Negotiate ethically, responsibly and competitively, in accordance with business expectations.

5 RESPONSIBLE MANAGEMENT

In order to offer the highest quality to its beneficiaries, PROINTER considers it essential to have a solid and reliable register of suppliers, which allows it to achieve a high level of performance. For this reason, the company is committed to a firm business relationship based on mutual respect, objectivity, quality, transparency and honesty. In addition, in its commitment to the environment and responsible purchasing, PROINTER pursues management that minimises the impact of its operations on the environment and preserves natural resources.
In this Policy, PROINTER sets out the procedures for the selection of suppliers and the making of purchases, seeking to avoid conflicts of interest and obtain mutual benefit, consolidating its ideology of remaining a responsible and sustainable company.
PROINTER also maintains a permanent commitment to the environment that it seeks to preserve in each of the processes of its line of business and, therefore, also seeks environmentally friendly behaviour from its suppliers. In this sense, the company is certified by the ISO 14001 standard in environmental management.

6 SUPPLIER SELECTION

To be a PROINTER supplier, natural or legal persons are required to consistently show impeccable ethical and legal behavior, particularly in labor and tax matters. Potential suppliers must maintain an adequate financial situation in full compliance with their obligations to public entities, banks, suppliers, legal and tax aspects and to the personnel in their charge, both in the professional and technical aspects, as well as in terms of occupational health and safety.
PROINTER suppliers must have sufficient capacity to deliver the services under the required conditions and specifications, as well as within the deadlines determined in the contracts, complying with the agreed service quality agreements.
PROINTER selects its suppliers under clear procedures, objectively and with equal opportunities, avoiding favoritism that harms free competition.
PROINTER especially values those suppliers who are actively committed to sustainability and corporate social responsibility, and reserves the right to check occupational health and safety standards, complying with labour and environmental compliance as many times as it deems necessary.
In the same way, PROINTER values its suppliers for their proactive contribution in the generation of more efficient and better quality models of goods and services.
To do this, the supplier must complete the Supplier Form and provide the necessary documentation (see Annex I)

7 EXPECTED SUPPLIER COMMITMENT

On the other hand, PROINTER expects its suppliers:
• To commit to the objectives stipulated in the contract, complying with the agreed commitments in a timely manner.

• They meet the highest quality standards in all the products and services supplied, being free of defects, as well as the contribution of value in terms of innovation and development.
• Comply with legislation, regulations and contractual agreements, staying away from any practice of corruption, extortion or embezzlement.
• Provide their employees with a safe working environment, which protects the human rights of their employees and treats them with dignity and respect, without engaging in discriminatory practices, forced labor or child recruitment, adopting the commitments set forth in local and state laws, as well as in the Universal Declaration of Human Rights, the fundamental conventions of the International Labor Organization and the principles of the United Nations Global Compact.
• Avoid discrimination and unfair or unfavourable treatment of workers on the basis of gender, race, age, social origin, religion, nationality, social orientation, political opinion, physical or mental disability, trade union membership, by developing equal opportunities programmes.
• Are environmentally friendly, establishing means to prevent leaks and accidental emissions, as well as using natural resources responsibly and economically, reducing energy consumption and greenhouse gas emissions.
• Have implemented a regulatory compliance organisation and management model following the guidelines set out in the fifth paragraph of article 31 bis of the Criminal Code in order to establish the appropriate measures for the prevention of crimes (including, but not limited to, fraud and fraud, punishable insolvencies, bribery, influence peddling, crimes against intellectual and industrial property, the market, consumers and corruption in business…).
• Are aware of and accept PROINTER’s Policies as well as its Code of Ethics, which describes PROINTER’s mission and vision and the values that must govern the daily activity of managers and employees.
  Based on the established, the supplier undertakes to correct as soon as possible any goods supplied that do not comply with the above. To verify that these requirements are met, PROINTER will periodically evaluate its suppliers, reserving the right to carry out audits and inspections to ensure compliance with this Policy, the legal regulations and the provisions of the contract.
  In the event that the aforementioned principles are not met, PROINTER will try to find solutions to remedy the situation. If a satisfactory agreement is not reached, the sanctions considered appropriate will be applied, and the contract with the supplier may be terminated.
  PROINTER will be receptive to any proposal that involves a continuous improvement in terms of its relationship with suppliers, understanding that this is a benefit for both parties.

8 RESPONSIBLE PURCHASING

PROINTER applies a Responsible Purchasing Policy to avoid adverse situations that make it difficult to achieve the established objectives.

– Among the risks arising from the purchases would be:

Making purchases without an authorized order.

• Receipt of unsolicited products.
• Receipt of defective products.
• Production stoppage due to lack of supply.
• Delays in the delivery of production due to lack of supply.

To minimise these risks, before making the purchase, PROINTER takes into account a series of considerations, among which the following stand out:

• Establish the requirements of the products to be purchased.
• Select sources of supplies.
• Negotiation, contracting, issuance and follow-up of orders.
• Verification of the price offered.
• Verification of punctuality in delivery.
• Product reception and compliance.
• Control of results and quality of service.
• Return of the product within the established period.
• In case of return, check that the product is returned in the established conditions.
• Verification of the return of the amount of the returned product or receipt of the product in good condition.

9 SUPPLIER EVALUATION

In order to know, verify and monitor the responsible performance of suppliers, PROINTER establishes a system of diagnosis and evaluation of contracted suppliers, ensuring that the requirements established in the contract are met.
PROINTER carries out a continuous evaluation of suppliers, which allows prioritizing which suppliers to contract with, renewing commitments, seeking improvements in the quality and effectiveness of services and how to interact in the context of the purchase, all under the criteria established in prior planning.
To carry out the valuation of suppliers, the following quantifiable criteria are established, among others, from which an objective value is obtained that qualifies the supplier:

• Ability to supply products.
• Experience.
• Delivery times.
• Prices.
• Quality.
• Warranty.

In accordance with these criteria, PROINTER carries out an annual assessment of its suppliers and acts in different ways depending on the non-conformities detected:

• 1-4 non-conformities: the Quality Manager informs the supplier that their situation is going to be studied and which non-conformities have been detected so that they can try to improve.
• 5 non-conformities: the Quality Manager decides whether the supplier is removed and goes to the list of non-approved suppliers.
• More than 5 non-conformities: the relationship with the supplier is terminated, which causes direct cancellation, unless there is no other option that can provide the company with this product or service.

10 ENTRY INTO FORCE AND VALIDITY OF THE POLICY

This document has been approved by the Board of Directors of PROINTER, entering into force on that same date and being fully in force until any modification is made to it.