Ethics are an ideal of human behavior, which orients to every individual on what is correct, and what should individuals do. It is conceived as the executor arm of the moral, which is the pursuit of general welfare.

Labor Ethics rule the decision making processes (what should be done), as well as the process after the decision was made (how should we do it).

The Constitution of the Bolivarian Republic of Venezuela establishes as a supreme goal the re-foundation of the Republic in order to establish a democratic, participative, leading, multi ethnical and multi cultural democracy, within a State of Justice, Federal and decentralized, which consolidate the values of freedom, independence, peace, solidarity, welfare, territorial integrity, and the order and the law for this and future generations.

The preamble sets forth the right to life, to work, to the culture, to Education, to social justice and equality without any discrimination or subordination.

This set of norms of POLINTER incorporates some values of the Constitution of the Bolivarian Republic of Venezuela, in its article 2, wherein there are set forth superior values of legal order and its social role: justice, equality, solidarity, social responsibility and in general the preeminence of human rights and ethics.

The constitution mentions the values of Ethics not only public but also the implications beyond the legal norms that shall exist in a set of ethical norms that would guide officers, workers and the State itself in the transformation process thereof.

Every individual during his / her performance has their own pattern of values, but every worker shall make compatible his / her behavior with the corporate values, the Behavior and Ethics Code in POLINTER, the strategic objectives, the internal standards of the Corporation and the aplicable Law.

It is important to remark that this Code is of obligatory compliance for all the POLINTER family, as therein are set forth the moral instructions that shall guide the behavior of employees in order to create a corporate culture based on a value system.

This Code is adapted with the Vision, Misión, Leit Motiv and Values of POLINTER as it follows:

VISION: Become the leaders in the production and commercialization of Polyethylene in Latin America, thus contributing with the development of Venezuela in a world leader in the market of the polyolefin.

MISSION: Produce and commercialize Polyethylene with efficiency, quality, safety, in an environmental-friendly manner, focusing primarily in the domestic supply, contributing with the economic and social development of Venezuela.

LEIT MOTIV: “Polyethylene for the Development of the Country”


Values

• Responsibility
It is the consciousness about the consequences of our actions about ourselves and others. Responsibiliy warrants the compliance of the commitments assumed, generates trust and peace in individuals.

• Respect
Is the essential base for a healthy and peaceful interaction between the members of any society. Respect encompasses all the aspects of life. Not only is the respect to ourselves and others, and even to living beings and environment in general, but to the laws, social standards, the legacy of our predecessors and to the country in which we were born.

• Honesty
It is the respect to ethical and moral principles, the following up of what society consider as proper customs. The sincerity is the basis of honesty. Those honest shall not make any misappropriation. When individuals are honest, projects are carried out easily and the collective trust is transformed into a great value force. It is required courage to be authentic and perform in a straight and clear way.

• Devotion to Work
It is the restless and careful execution of any task. It is a force with a great power of transformation, which has taken mankind to the highest levels of development and civilization. It is so important that it not only depends our economic performance but also our happiness as such comes from our economic compensation and in the physical and mental activities.

• Loyalty
Comprises the compliance on what fidelity and honor laws demand. Loyalty is related with the bonds, fidelity and respect feelings inspired by our beloved individuals or ideas. Those loyals have a high standard of commitment and are consistent with their feelings and honor their duties. There are many factors that inspire loyalty. Our family, friends, our partners, the school we study or the company we work at, and even the country we belong to are the most important.

• Solidarity
It is when two or more people gather, collaborate and join mutually to achieve a common goal. The solidarity is an important value for humans, as the highest degrees of civilization and technological advance is due to such value, and has been able to survive along human history. Solidarity is such an enormous power that when we put it into practice, we become stronger and we are able to assume the largest challenges, and resists the most adverse situations.

• Humbleness
It comprises of the recognition of our limitations and weaknesses, as well as perform our duties based on such knowledge. It is the consciousness about what we are, of our strengths and weaknesses as human beings that impede to believe that we are superior to others. Humble people are always willing to learn new things and outperform in different aspects of their lives.

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The Board of Directors of Poliolefinas Internacionales, C.A. (POLINTER) pursuant the faculties granted by the Social Statutes, DECREES the following: BEHAVIOR AND ETHICS CODE IN POLINTER

TITLE I
General Provisions

Article 1. The norms set forth in this Code shall be of obligatory compliance for all employees at POLINTER, regardless of the position or function thereof, as well as those who perform duties for the Company for a specific period of time or task. The provisions herein established shall not be breached under any circumstance.

Article 2. This code shall be recognized by all workers at POLINTER, and is expressly set forth that the lack of knowledge thereof will not excuse the employee of the compliance thereof. All incoming employees (permanent, contracted, sub-contracted, interns, thesists and apprentices) shall receive and inductive course on the Behavior and Ethics Norms in POLINTER before performing any activity within the Company.

Article 3. These norms have the following ethical objectives:

a. Become a formal and institutional reference for personal and professional behavior.

b. Set forth an ethical behavior based on corporate values.

c. Reduce the subjectivities of personal interpretations on moral and ethic principles.

d. Consolidate the image and identity of POLINTER within its interested public.

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TITLE II
Behavior Guidelines

Article 4. Workers shall be example of the behavior through the devotion to service and the commitment of the guidelines of values of POLINTER.

Article 5. The breach or non-compliance of this Code are deemed as severe faults that cause disciplinary actions, as well as civil or penal penalties.
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Chapter I
Labor Relationships

Article 6. The duties of every employee at POLINTER are:

a. Perform with honesty, discretion, effectiveness, veracity and loyalty.

b. Maintain the respect to his / her dignity as individual and as professional.

c. Comply and monitor the compliance of this Code.

d. Enhance the confraternity with their partners, through the respect, collaboration, transparent attitude, cordiality and rational tolerance.

e. Perform his / her function with decision, by overcoming defies and protecting the interests of the Company.

f. Develop tasks based on the strategic objectives of POLINTER without using any position, function, activities, assets, position or influence in order to obtain personal benefits or for third parties.

g. Respect the work performed by each individual.

h. Maintain the confidentiality of all the information used in the tasks, pursuant the norms of the Company.

i. Use with efficiency the assets and information of the company, as well as produce records and reports with reliability and precision, accordingly to the legal purposes of the Company, without altering or misleading the contents of any document, information or data.

j. Preserve the assets of the Company in terms of equipments, materials, technological and strategic information, as well as operational facilities.

k. Promote actions that allow improving the internal communication, the integration and development of teamwork.

l. Be responsible for every subscribed and sealed document.

Article 7. Employees shall be courteous, willing and able to attend to all individuals, as well as respecting the individual differences.

Article 8. Employees shall be loyal with their partners, supervisors or managers. Moreover, they shall recognize the merits of the tasks performed by others.

Article 9. Any worker shall not prejudice the reputation of any employee of the Company by means of defamation and prejudices caused by pre-concepts, false testimony, non-fundamental information or any other form. Defamation and prejudices is object of penal sanctions set forth in the Penal Code.

Article 10. Workers shall not obtain favors in turn of commitments or personal obligations.

Article 11. All Managers, Superintendents or Supervisors shall stimulate to their supervisors or personnel under his / her command, to the generation of ideas aligned with the objectives of the Company, although they represent changes of the status quo. Such ideas shall be canalized by the formal means.

Article 12. The Ownership of inventions and service improvements of the Company will be of POLINTER, although inventors will have rights to a share when the retribution in the enjoyment is non-proportional to the magnitude of the results.

The fixation of such share will be negotiated between the parties with the approval of the Labor Inspector of the Jurisdiction, and by a Judge in the cases in which an agreement is not reached.

Article 13. It is expressly forbidden the discrimination based on race, sex, religion, social status, color, age, believing or any other form of discrimination. If any employee feels that is being discriminated, he / she shall immediately report to his / her supervisor, or to the Human Resources Department of the Company.

Article 14. There are forbidden any pressures, threats or harassments of any kind.

Article 15. It is forbidden that the moral harassment, understood as the act to disqualify by jeans of words, gestures or attitudes, the self motivation, security or image of the employee. The victims of this type of action must report it immediately to his / her supervisor, or to the Human Resources Department of the Company.

Article 16. All employees shall respect the values of the Company, without pressures that would promote the grant of improper advantages.

Article 17.  As a demonstration of loyalty to the Company and the members thereof, there may be made certain constructive criticism, made in a clear form and through the proper channels.

Article 18. Errors shall be tolerated, but a research shall be made on its causes, and avoid any concomitance thereof.

Article 19. Any employee shall request help to other employees of the Company when his capabilities are not enough to perform any duty, in order to obtain the means to overcome such limitations.

Article 20. The corresponding management shall evaluate the errors, as well as the goals achieved in order to make ongoing improvements of the quality of the work.

Article 21. All employees have the right to know the results of their performance evaluation. A clear process of performance management is adopter with individual orientation to the employee on issues that have a direct or indirect influence on the results of their work.

Article 22. POLINTER will guarantee to its employees the right to know the criteria of promotions and the evaluation upon such criteria.

Article 23. The effort of employees to improve the result of their performance is valued, and the recognition for their performance is herein recognized.

Article 24. It is deemed that personal, administrative, and medical, and fringe benefits information shall be confidential, and only will have access the personnel responsible of the custody, filing and treatment of such information. The requests, analysis and transference of such information shall only be carried out by personnel authorized to do so, pursuant the legal terms and provisions, by virtue of being presented as evidence in any trial, accordingly with the orientation of the legal area. All employees shall have the right to access to their own information.

Article 25. The personal data of workers shall be constantly updated, and they will have to provide the information if any changes occur.

Article 26. It is guaranteed to all employees the right to request and receive any disclaimer required on their rights and interests.

Article 27. It is guaranteed to all employees a proper working environment, characterized by its security, hygiene, health and welfare. In case that there are situations in which life and / or physical integrity of one or more employees are under an imminent threat, there shall be suspended the performance of their duties and take the corrective measures required, as well as notify immediately to the immediate superior.

Article 28. POLINTER promotes the institucional communication through physical and electronic means, which shall ease the information exchange, facilitate the management of knowledge and allow the closening and participation of individuals. However, the confidentiality shall be preserved in any time without the divulgation of messages with pornographic, racist, illegal, political or similar messages.

Article 29. All employees shall attend to their workplace using a proper wear and personal appearance. This implies that employees shall bear in mind the type of activity they perform and the public they are in contact with.
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Chapter II
Relationship whit Society

Article 30. Either POLINTER and its employees are committed to comply with the laws and applicable norms of the Bolivarian Republic of Venezuela, as well as with the legislation of any nation in which they shall perform any activity or task.

Article 31. All customers, partners, providers and even competitors deserve a respectful and polite treatment. It shall be considered the ongoing perfection of communication and interpersonal relationships.

Article 32. All customers and providers shall be informed on actions that are being carried out for the solution of their issues. The response to providers, customers, service providers and others shall be sincere and shall not be used any deceiving information that would cause delays or prejudices in the practice of their rights.

Article 33. All negotiations made on behalf of POLINTER shall be made by means of honest practices. The non-compliance of this provision will cause the cease of any labor relationship and / or penal sanctions.

Article 34. Those individuals responsible of providing information to suppliers, competitors and shareholders shall only inform and / or resend documents to third parties when duly authorized by the Company, and always identifying the authors of such actions.

The information provided shall be trae, and shall be provided to all the interested parties. In case that any employee is not authorized to answer any question, the requesting party shall be notified.

It may be broadcast public information of procedures and factual analysis of the Company in an equal form to all the interested parties.

Article 35. It is forbidden the broadcast of any strategic or confidential information that has not been issued by POLINTER. This kind of information may only be broadcast when the task requires so, under a previous approval of the corresponding Management and always under an agreement of confidentiality.

Article 36. Any worker shall be involved in activities or situations in which their personal interests interfere with those of POLINTER.

Article 37. All workers shall perform their function on behalf of the Company, without offering technical asístanse of counseling of any type to providers, customers, service suppliers from POLINTER, or tose who are in process of induction or participating in bids, except in the cases when the respective Managements grant the authorization to do so.

Article 38. The resources of work (information, technology, equipment) shall be used for the work accordingly with the purposes of the Company, and not for particular interests.

Article 39. When in practice of the professional activities, it is forbidden of making comments on the competition, or about their quality or performance of the products. In case of making a formal statement of the Company, the Management shall approve it prior its broadcast.

Article 40. In case of the existence of direct relatives in the Company, the relationship shall be expressed and avoid that any of them assumes any controlling, monitoring and approving the work of others, or may have an influence on a salary increase or promotion thereof.

Article 41. Any situation that would represent a potential conflict of interests shall be notified immediately to any superior, or to the Management.

Article 42. It is expressly forbidden to all employees at POLINTER:

a. Accept personal invitations for hosting, travels or any other attractions that would cause damages to the image and / or interests of the Company.

b. Be under the influence by personal relationships with customers, providers, partners or competitor in terms of decision making processes.

c. Maintain commercial relationships with customers, providers or competitors of the Company in order to obtain personal privileges, by virtue of his / her position or function.

d. Constitute as partner, manager, counselor or broker of any individual that perform transactions or is a competitor of POLINTER in the production of goods and services.

e. Receive, request or suggest any type of financial help, gratification, reward, commission, donation, present or benefit of any type in personal form or to relatives or third parties during the practice of the professional activities. Furthermore, it is forbidden to influence for the same purposes to other member of the Company during the decision making process.

f. Employ the information of the Company to obtain personal benefits, for relatives or third parties.

g. Accept gifts from customers, providers, associates or competitors, except the presents clearly identified with a commercial value that shall not exceed ten (10) taxation units. Those gifts with a meaningful value that for any reasons cannot be returned shall be incorporated to the Company.

h. Make suggestions to customers, providers or partners that influence the hiring of counselors or personnel, with a particular interest.

Article 43. Contacts with former workers of POLINTER through commercial or personal relationships shall not have any influence in any decision of the Company, nor shall favor the access to privileged information.

Article 44. Gifts, presents or rewards in charge of the Company for any individual, either personal or corporate, which maintain institutional relationships, may be performed with the proviso that is not money (regardless of the sum), without any meaningful value and cannot be a condition or result of businesses. It shall be counted with the due authorization and registry in the corresponding accounting books.

Article 45. The Management of POLINTER, with the support of the employees, shall seek growing levels of competitiveness and profitability, in order to remunerate shareholders in a fair way and compatible with the invested capital. Every employee has to bear in mind the social interest of POLINTER, and the common interest of shareholder, above any other type of interests.

Article 46. In order to disclose or provide strategic or confidential information of POLINTER, even in the case of interviews, the General Manager of the Company shall authorize it, as well as shall counsel on the needs and form of answer, and shall appoint the spokesman / spokeswoman.

Article 47. In case that are personal interviews, press articles or any other public manifestation form is used, the name of POLINTER shall not be mentioned, in pro of the preservation of its interest and image, and avoiding any negative impact on it.

Article 48. POLINTER will favor the support of actions for the exercise of the citizenship, as well as for the local, regional and national development, specially those activities dedicated to improve the communities wherein POLINTER operates. Furthermore, POLINTER promotes corporate activities that motivate social participation and commitment amid the employees of the Company.
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Chapter III
Ethical Behavior

Article 49. The Guidelines developed herein allow the improvement on the quality of relationships, the practice of citizenship and business success.

Article 50. Those employees with doubts on the application or interpretation of any of these provisions herein contained, shall communicate them immediately to his / her supervisor or Human Resources Management.

Article 51. Any attempt of bribery, irregularities or possible irregular behavior against the interests of POLINTER, and that implies a breach of this Code, legal norms and / or regulations, shall be notified to the Internal Audit Management by producing enough evidence. In case that the direct supervisor or corresponding Management was notified, they will be responsible of the due notification to Internal Audit Management.

Article 52. Those employees who have knowledge on any breach of this code, he / she shall notify such cases immediately to his / her Supervisor. POLINTER will not allow any reprimands nor harassment against any individual who reports any suspicious breach to the Law or norms of the Company, including the norms set forth in this Code.

Article 53. A Ethics Commission will be created in order to promote this Behavior and Ethics Code in POLINTER, as well as prevent actions against it, and even solve any questions arising by virtue of this Code. When this code is enforced, the Commission shall promote an induction course about it. Ethics Commission shall comprise of seven (7) employees appointed by each Management of the Company.
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TITLE III
Final Provisions

Article 54. The effective application and compliance of this Code is responsibility of the President, Directors, General Manager and Company Managers. The general responsibility on the implementation, control and maintenance of this Code corresponds to the Management of Human Resources of the Company.

Article 55. The norms of this code shall be amended only by the Board of Directors of POLINTER.

Article 56. This code will enter in force on January 1st of year 2007.

Given, subscribed and sealed on this July 17th of year 2006.

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