Ethics and Conduct Protocol

SAXUM believes that the well-being of people, employees, clients and communities of influence is fundamental and in view of this promotes the highest ethical standards, offering quality services and constantly raising the performance expectations of its resources.

Based on people's individual responsibility, civic duty and integrity, the company aims to promote exemplary conduct in relation to:

  • Customer and stakeholder service.
  • Sustainable performance.
  • Integrity and teamwork.
  • Act ethically.
  • Protection of human rights.

Main Ethical Principles

Relationship between employees:

The Company is committed to the protection and promotion of human rights and, with this concept in mind, this policy incorporates guidelines on the responsibility to respect human rights, build greater trust with our external stakeholders, and demonstrate good international business practices.

The Company's human rights policy is based on the following:

  • The Universal Declaration of Human Rights
  • The principles of the United Nations Global Compact.
  • The International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work.

The company fosters and promotes an inclusive and respectful work environment by establishing clear standards of behaviour;



  • The Company rejects any discriminatory behaviour and employee diversity is valued and respected.
  • Job applicants are judged on the basis of their performance and qualifications without regard to race, creed, gender, religion, national origin, age, disability, veteran status or sexual orientation.
  • Appropriate compensation will also be determined on the basis of performance and qualifications without regard to race, creed, sex, religion, national origin, age, disability, veteran status or sexual orientation.


Prohibition of Child labor, forced/compulsory labor:

  • The Company opposes any form of harmful child labor and forced or compulsory labor.
  • Harmful child labor or the use of forced or compulsory labor is prohibited in all Company workplaces.


Freedom of association and collective bargaining:

  • The company respects the right of employees to join, form or not to form a union without fear of retaliation, intimidation or harassment.
  • When employees are represented by a legally recognized union, the Company is committed to constructive dialogue with their representatives.
  • The Company makes the effort to reach mutually beneficial agreements, collaborating with its workforce to find solutions for day-to-day interactions, as well as in contract negotiations.


Health and safety:

  • Maintaining a safe and healthy work environment is fundamental to the Company.
  • Accidents harm employees and undermine the effective performance of the company, as well as the trust of the communities in which we operate.
  • The Company is responsible for accident prevention by maintaining a healthy work environment, promoting a proactive safety culture, following procedures and using all necessary personal protective equipment.


Harsh or inhuman treatment or harassment are not permitted:

  • Employees are treated in accordance with the policy of maintaining a work environment free of all forms of harassment, whether sexual, physical, verbal or psychological.
  • The Company prohibits the use of indentured servitude, slavery, bondage or any other involuntary forced labor.
  • The Company rejects corporal punishment of any kind, harassment by any offensive act, humiliating comment or display, insults and any act of intimidation or threat.
  • The company has a specific HR policy and internal procedures related to personnel certified by ISO 9001 and a corporate policy and application programs for health and safety.


Procurement Policies:

The company has developed a Responsible Purchasing Management Policy to ensure that the process is carried out in a safe, sustainable, environmentally responsible and transparent manner in each of the processes.

Purchasing management procedures were designed to ensure respect for equal treatment among suppliers, taking into account the particular characteristics and constraints imposed by the local environment and respect for fair competition. All procurement decisions are based on the criteria of; price, quality, performance, delivery time and suitability of the proposed services for each need in specific circumstances. The company has a specific Purchasing Management policy and internal procedures for dealing with suppliers and/or service providers certified by ISO 9001 (Annex II).


Anti-Corruption and Anti-Bribery Policy:

The Company is firmly committed to the prevention of corruption and expects its employees, officers and directors to conduct themselves in an honest and ethical manner when dealing with government officials and any other parties. The fight against corruption is an absolute priority for the Company and to this end, it has developed policies in accordance with all the laws in force in the countries in which it operates, and in general with the international conventions applicable to it.


Prevention of any form of money laundering:

Money laundering consists of reinvesting illegally obtained sums of money in legal activities. The Company takes all appropriate measures to prevent any form of money laundering in the course of its business.


Conflicts of interest:

A conflict of interest exists in those situations where there exists interference between a Company interest and a personal interest of the collaborator, compromising the independence, impartiality and objective exercise of a function.

The company requires its employees and third parties to demonstrate loyalty and avoid placing themselves in a position where they could find themselves in a conflict of interest situation.


Respect for confidentiality in business:

The Company assures its employees, related third parties and customers that the information provided is treated with due respect and used only for authorized purposes. All employees have a general obligation of confidentiality of information made known to them in the course of their duties, and particularly in the course of specific business relationships. Confidential information is information whose disclosure to an unauthorized person could seriously damage the reputation of the Company, its employees or its customers.

Procurement Policies

The company needs to acquire materials and contract services in a timely manner and in the best conditions of quality, opportunity and cost offered by the market for the development of contracted projects.

To support this, a Purchasing Policy has been developed so that the process is simple and expeditious; and to ensure that effectively through the philosophy of Continuous Improvement, the initiatives of cost reduction are contributed, granting transparency to each of the processes, in a safe, sustainable and environmentally responsible manner.

This management of the Supply Area is based on the definition of SAXUM Engineering policies.

Procurement Objectives:

  • Generate appropriate controls of the procurement process.
  • Provide adequate tools for cost control.
  • Provide consistency in all procurement and contracting operations.

Procurement Functions

The Supply Area will have the necessary personnel, systems and services to ensure the efficient execution of purchasing activities, which include:

  • Maintain simple procedures that respond to the customer's purchase needs.
  • Keep an updated registry of suppliers open.
  • Maintain updated electronic files and proper documentation involved in all Purchase activities.
  • Analyze and evaluate the quotes received, based on the combination of factors such as price, quality, delivery time, etc.
  • Select suppliers with proven capabilities and ensure that they maintain satisfactory performance in Sustainable Development.
  • Minimize direct awards (sole supplier).
  • Prepare Letters of Recommendation, the Commercial and Technical Analysis Reports of the offers received.
  • Clarify the doubts that suppliers may have.
  • Get suppliers to deliver services in a timely manner.
  • Maintain strict confidentiality in all purchasing activities.
  • Deepen knowledge of the markets for goods and services, developing market intelligence to detect opportunities and risks.

Professional Behavior

The SAXUM Procurement Team develops working relationships with other specialized SAXUM areas such as Engineering, Legal Affairs, Finance, Accounts Payable, etc .; making use of your support for the purposes of review, comment and information during the development process of tenders and awards.

In carrying out purchasing functions and responsibilities, Area staff conduct themselves in a highly professional and efficient manner; complying with the following characteristics:

  • Careful knowledge of SAXUM policies and practices.
  • Detailed knowledge and understanding of the Market.
  • Innovative attitude.
  • Accurate strategic planning.
  • Flexibility in the selection of the purchase method that best meets the needs of users and market conditions.
  • Use agile and simple contracting processes, understanding that these characteristics depend on the magnitude and complexity of the good to be provided or service to be contracted.
  • Demand a high level of compliance from Suppliers.
  • Have knowledge of legal issues, incoterms and risk of exposure in commercial situations related to purchases.

Project Management Procedures

SAXUM specializes in the provision of engineering services and management of high-level projects for the industry.

Our management style is based on project management through a corporate structure, business units and the own management teams of each project.

This allows us to be a company that, following the corporate guidelines, we can adapt the resources, techniques, structures and management to the particular characteristics of each Project, in the region that is located.

Scope of our project management model:

SAXUM provides a wide range of project management services, and can summarize them in:

  • EPCM projects
  • Engineering Projects: conceptual, basic and detailed.
  • Projects of Feasibility Studies, Trade Offs, and Environmental Impact
  • Supervision and Maintenance Projects

SAXUM project management model:

SAXUM, through the project teams and the support of the corporate areas, design, implement and control the execution of each Project through the Project Execution Plans (PEP).

These plans, unique and unique to each project, reflect the Project or Service Management Planning, its structure, particularities, critical points, operational controls, construction equipment, engineering, contractor control and any other methodology that is customized and adapted. to each need, always, considering the applicable legal framework and SAXUM corporate guidelines.

Each PEP details the specific requirements of the Client, generating particular modalities of application for each contract and is sized according to its complexities.

The result of this planning also involves all the necessary activities of verification, validation, monitoring and measurement, both for the products purchased, hired own and third parties, as well as for the constructions and installations carried out.

In the case of purchased products, the identification of particular characteristics or functions may arise, being called the "Non-standard Products" and may require specific inspection and testing plans.

The PEP, in turn, has the peculiarity of being able to adapt to other Management Systems such as that of the Client or other parties involved in the contract.

Construction Management Procedures

SAXUM´s Construction Management is the core of the company's services. It involves the direction, regulation and supervision of a project from early development to its completion and is responsible for planning work schedules, coordinating the most efficient method and

construction strategies and budgeting.

The team is composed of multidisciplinary professionals that allow us to administer the different disciplines, such as: Civil/Structural, Mechanical, Electrical and Instrumentation, Safety, Contracts, Administration, Commissioning, etc.

Our experience, strong focus to project objectives, and the mutually reinforcing joint-work between our professionals of all different departments, allows us to be the tailor-made solution for our customers’ EPCM projects.

SAXUM acts as the owner's representative in conducting the Site Supervision, Comprehensive Project Planning, Contract Administration and Management Control through Cost and Resource Control, involving the Technical Field Office, Quality and its team of Health, Safety and Environment to ensure that problems are addressed on time, guaranteeing a strong commitment to achieve objectives of costs, time and quality of the final product, unique in each project.

SAXUM has procedures for construction management that allow, among other things, to standardize the activities of the work team, optimize the monitoring of the project master, monitor the progress of the different work contracts, control the costs of the project and the quality of the jobs running.

These procedures, in each of their areas, are backed by ISO 9001 quality standards that distinguish our company.


Logistic & Expedition Procedures

Our experienced Sourcing team has the capacity and portfolio of suppliers necessary for the planning, coordination and purchase management of all the necessary resources for your project, together with the appropriate Logistics team to ensure that the materials and equipment are available at the foot of the work to ensure compliance with the RAS dates of the construction program.

Furthermore SAXUM offers comprehensive services of:

  • Comprehensive Logistics and Comex Management, totally focused on EPCM projects.
  • Evaluation, development and management of suggested suppliers for international, national and local logistics.
  • Analysis, planning and development of port services and customs procedures including dispatchers. Customs and import strategy. Early mode configuration for imports or exports. Analysis and dynamic geographic proposals of free zones, fiscal deposits, and nationals. Foreign Trade Management. Import and Export Services. Guarantee compliance with environmental, safety and quality policies.
  • Origin / Destination Analysis of the optimal port, air, land and rail infrastructure for entering the country; as well as internal / domestic routes to guarantee a quality and safe supply. Guarantee compliance with environmental policies.
  •  Analysis and review of access roads to project areas, design of strategic supply logistics and reverse logistics. Study of global storage and redistribution centers in order to ensure proper logistical support, guaranteeing compliance with environmental, security, and community social relations policies.
  •  Service and management of freight forwarder at a global level, with the capacity to operate with general loads, dangerous loads, and extra heavy loads or loads outside of standard dimensions. Equipment and professionals with proven expertise. Polymodal transport: national and international, global capacity in land modalities including rail, sea and air. Guarantee compliance with environmental, safety and quality policies.
  •  Advice on strategic mobilization and demobilization plans for machinery and equipment park. Traffic flow and organization of the road matrix of income / expenses of sites. Guarantee compliance with environmental, safety and quality policies.
  • On Site Production Logistics. Management and administration of the Park of Machines, Equipment, light and heavy vehicle fleet and transport of people, during construction and operation. Applied technologies and professionals capable of inspecting and guaranteeing preventive, predictive and corrective maintenance. Cost Control Management and performance improvement. Fuel Supply Platform Administration. Guarantee compliance with environmental, safety and quality policies.

Engineering Procedures

SAXUM has a team of engineers and professionals with extensive experience and experience capable of providing comprehensive solutions to industries. With a strong track record in the mining, cement, lithium, manufacturing and Oil & Gas sectors.

Our professionals in the disciplines of Civil & Structural Engineering, Mechanics, Piping, Electrical, and I&C participate in the different stages of your project, from feasibility to detailed engineering for construction, to help you achieve cost and deadline objectives.

By standardizing procedures, SAXUM guarantees the correct fulfillment of each of the stages for the development of Engineering projects. The procedures used during the Start, Planning, Development, Control and Closing phases of each of our projects are certified under the ISO 9001 Quality Standard. In this way, we ensure the most efficient and quality management of our services.

SAXUM, in its continuous improvement process, has adapted all the procedures to the highest international requirements and is in the process of ISO 9001: 2015 quality certification.


Pre-commissioning and commissioning Procedures

SAXUM has professionals to carry out the tasks of Pre-Commissioner, Commissioner and Commissioning of all Mechanical, Electrical and Instrumentation and Control systems, carrying out the corresponding checks and tests under specific conditions, with highly trained personnel with extensive experience in the field, to ensure that project equipment and facilities have been constructed in accordance with IFC detailed engineering guidelines and documentation.

SAXUM in its continuous improvement process has adapted all the procedures to the highest international requirements and is in the process of ISO 9001: 2015 quality certification.