Due to the commercial nature of the company, national and international standards of probity and responsible management, MAKOL OCR S.A., in its capacity as a company in the health sector, adopts the following business policies tended to the commitment of the company, its shareholders, board of directors and collaborators to achieve, in their exercise of their functions, an ethical and transparent practice for the clients, third parties and the company itself, acting with a philosophy of ethical principles, of non-discrimination, of social and environmental sustainability and of zero tolerance for acts that oppose its organizational principles of anti-corruption and anti-bribery. Our complaints channel has the main purpose of receiving and dealing with complaints regarding irregularities, concerns, or breaches of the law.

Above all, Makol OCR S.A. as a company, its shareholders, and its employees, will always keep in mind that they have an extraordinary responsibility to work in the health field, having as a goal to always seek to provide the best possible option for the patients, as their final users. Makol OCR S.A. constantly seeks to improve its service and dedication to patients with first-class products, of the highest quality, in constant innovation and at the forefront of medical techniques.


The following policies will be applicable to all members of Makol OCR S.A., regardless of whether that are in an employment, hierarchical or other relationship.

Despite the enumeration of specific obligations for different groups involved in Makol OCR S.A., the basic rules of ethics, transparency and correct action will be applicable to all its officials, regardless of the nature of their employment or hierarchical relationship.

As general principles, it will be the function of all members:

  1. Legality:

    All actions of Makol OCR S.A. and its members must conform to strict principles of legality, including, but not limited to rules on corruption, fraud, extortion, labor, health, and tax policies. Also respecting the commercial embargoes decreed by certain countries that are mandatory by their suppliers and by extension to Makol OCR S.A. It also expresses its repudiation and zero tolerance of illicit drug trafficking, terrorism, arms trafficking, promotion of child prostitution, kidnapping, bribery, money laundering and, in general, all illegal practices.

  2. Zero tolerance for corruption and anti-competitive practices:

    1. Makol OCR S.A. will have a policy of zero tolerance to corruption, bribery, fraud and similar illegal acts, regardless of their denomination, involving payment in money or in kind, advantages, privileges, loans of services, directly or through third parties, to a public official, to any entity that handles public resources and has authority over individuals, an official of a private company or a private company, with the aim of obtaining an undue benefit for itself or for third parties to the detriment of organizational principles, regardless of the financial effects or whether the task has been achieved or not. It includes any other activity whose objective is to obtain a business advantage or a decision that would not have corresponded but as a result of the improper actions. Acting in full conformity with the provisions of Legislative Decree No. 9699 “Responsabilidad De Las Personas Jurídicas Sobre Cohechos Domésticos, Soborno Transnacional Y Otros Delitos” and Law No. 8422 “Ley contra la Corrupción y el Enriquecimiento Ilícito en la Función Pública”.

    2. Care of and to third parties:

      Members of Makol OCR S.A. are not allowed to accept for themselves or for third parties, nor to request or offer on account of their charges, gifts, invitations, or benefits of any kind. The exceptions are official and protocol donations and those authorized by custom as manifestations of courtesy and good education. It will be allowed to offer and receive social care (including meals, accommodation and transportation) provided that they a) are not provided for an improper purpose and the nature, style and tone of any social care is reasonable under the circumstances and cannot be perceived as lavish, disproportionate or inappropriate; b) are not prohibited by the policies of the employer of the person to whom they are offered y c) in the case of public officials they are permitted by law. Social care will be permitted when it is part of the normal course of business, whose purpose is to inform and / or educate customers about the products offered, provided that such attentions are carried out in a transparent manner and under the protection of decorum and the respective laws and in a manner and reasonable amount for its purpose. Modest gifts of promotional or similar products will also be allowed, provided that their value does not exceed an amount of US$15, - , amount that will be reviewed periodically.

    3. Unfair competition practices:

      In addition, all unfair competition practices or anti-competitive agreements so designated by applicable law or international custom are prohibited, including, but not limited to monopolistic practices, bid rigging, abuses of dominant positions or market sharing.

  3. Honesty and Good Faith:

    Makol OCR S.A. and its members will seek at all times to act honestly and transparently towards their customers, suppliers and internally. Seeking to create stable and long-term relationships between these actors based on good faith, respect, dedication, trust, and transparency.

  4. Non-discrimination:

    Makol OCR S.A. is an environment free of discrimination based on race, age, religion, gender, sexual orientation, nationality, social origin, disability, or political affiliations, so situations of intolerance or lack of respect originating in any of the above will not be allowed, always seeking a respectful treatment to the internal and to third parties, be they clients, suppliers, or authorities.

  5. No to harassment:

    Makol OCR S.A. has a policy of non-tolerance to harassment and/or workplace or sexual harassment, as well as to "bullying" of any kind, either internally or to customers, suppliers, or authorities.

  6. Occupational safety:

    Makol OCR S.A. seeks to create a healthy and safe work environment, through the communication of good practices and behaviors, seeking to minimize as much as possible the occurrence of accidents, injuries, or diseases. It will be the obligation of all members of Makol OCR S.A. to comply with the occupational safety indications of their positions and the general guidelines issued in this regard. The information provided by the collaborators of Makol OCR S.A. about any condition will be handled in the strictest confidence and must be communicated only in order to safeguard the health and life of the person in emergency situations.

  7. Environmental Sustainability:

    Makol OCR S.A. seeks that its operations do not harm the environment, working on reducing its environmental impact through healthy policies of resource use, water, energy efficiency, participation in recycling policies and other environmental sanitation. Committing to try to use only business partners who share their environmental sustainability policies.

  8. Healthy work practices:

    Makol OCR S.A. applies strict adherence to the labor laws applicable to its employees, seeking fair compensation, regular payment with the enjoyment of holidays and regulated working hours; with strict compliance with social security rules and payments and occupational risk policies.

  9. Respect for confidentiality and intellectual property:

    Makol OCR S.A. is aware of the value of information and advocates respect and protection of all information obtained directly or indirectly, regardless of whether it has been expressly designated as confidential or not. In Addition, it recognizes the value of its own and third-party intellectual property, and will ensure the protection of it, whether originating from Makol OCR S.A., its customers, or suppliers, by reporting the violations to the indicated persons.

  10. Sound accounting and tax practices:

    Makol OCR S.A. will apply internationally accepted accounting standards and principles, keeping a strict control of its books and in faithful compliance with tax obligations.

  11. Special responsibility for medical products:

    Aware of its responsibility in the handling of products of a medical nature, Makol OCR S.A. and its collaborators will place special emphasis on the proper handling of all the products they sell, ensuring an adequate transport and storage of these in accordance with the specific indications of each product and also monitoring the same level of compliance by its suppliers. Moreover, it will seek to have traceability of all the products marketed in order to meet the warning calls that may exist from its suppliers or the health authorities.


In addition to these principles of general compliance, Makol OCR S.A. establishes specific obligations for its shareholders, board members and directors; as well as for its employees as indicated:

Shareholders and Owners

In the exercise of their property rights, they must:

  • Configure the company as an instrument at the service of creating well-being for all parties, making compatible its inescapable purpose of obtaining benefits with a sustainable and respectful social development with the environment, ensuring that all its activity is developed in an ethical and responsible manner.

  • Configure the company as an institution in the medium and long term without the desire for short-term enrichment compromising its continuity.

  • Seek a fair balance between capital and labor so that workers receive through their wages the right compensation for their work.

  • Name as administrators and directors, people who meet the appropriate conditions of preparation and experience and who perform a professional, ethical, and responsible exercise of its management.

  • Define and defend the mission and values of the company in line with its ethics policies.

Board of Directors and Administrators

In the exercise of their administrative and management functions, they must:

  1. Regarding their management functions:

    • Carry out a professional, ethical, and responsible exercise of their activity.

    • Comply with and enforce the company’s policies and, for that, make them known and establish the appropriate mechanisms to guarantee its application.

    • Promptly and accurately inform shareholders of situations that can affect the proper functioning and viability of the company.

    • Comply with and enforce generally accepted accounting standards and principles and establish internal and external control and risk management systems appropriate to the characteristics of the company.

    • Maintain the books and records of the company with accuracy and honesty, so that they allow obtaining information and conscious and responsible decision-making.

    • Provide external and internal auditors of the company with all the information and explanations they require for the performance of their work.

    • Subordinate their own interests to those of the company when acting on behalf of the company.

    • Immediately communicate or act on any fact or situation that could suppose or cause a conflict between the interest of the company and administrators or managers and refrain from intervening in its resolution.

    • Maintain confidentiality of antecedents, data, and documents to which they have access by reason of their functions in the company, even after they have left them.

    • Face the payment and fulfillment of debts and obligations of the company without delay or unjustified breaches and proceed to the collection of their credits with the diligence that the case requires.

    • Develop and keep a succession plan in place in the key positions of the company, so that its continuity does not depend on the permanence of any administrator or employee.

    • Choose employees and subordinates according to the principles of merit and ability, seeking only the interest of the company.

    • Seek innovation of the products commercialized by the company, seeking to be aware of technological developments and trends in the sector.

    • Apply and ensure the application of different compliance policies of their suppliers.


  2. Regarding the company’s suppliers and customers:

    • Interact with suppliers of goods and services in an ethical and lawful manner.

    • Seek and select only suppliers whose business practices respect human dignity, do not break the law, and do not endanger the reputation of the company.

    • Select suppliers based on the suitability of their products or services, as well as their price, delivery conditions and quality, not accepting or offering gifts or commissions in money or in kind, that may alter rules of free competition in the production and distribution of goods and services.

    • Seek excellence in the company’s goods and services so that its customers and ultimately, patients, get the satisfaction reasonably expected from them.

    • Guarantee products and services of the company and respond quickly and effectively to customer complaints, seeking satisfaction beyond mere compliance with current regulations.


  3. Regarding the company’s competitors:

    • Do not abuse a dominant or privileged position in the market if that were the case.

    • Compete loyally with other companies cooperating to achieve a free market, based on mutual respect among competitors, refraining from unfair practices.

    • In particular, do not attract customers from other competitors through unethical methods.


  4. Regarding the company’s employees:

    • Treat employees with dignity, respect, and justice, taking into account their different cultural sensibilities.

    • Do not discriminate against employees on the basis of race, religion, age, nationality, sex or any other personal or social condition beyond their conditions of merit and ability.

    • Do not allow any form of violence, harassment, or abuse at work.

    • Recognize the rights of association, unionization, and collective bargaining.

    • Promote the development, training, and professional and personal promotion of employees.

    • Link the remuneration and promotion of employees to their conditions of merit and ability.

    • Establish and communicate clear criteria and rules that keep the rights of the company and employees balanced in the hiring and separation processes.

    • Guarantee safety and hygiene at work, adopting all reasonable measures to maximize the prevention of occupational risks.

    • Attempt to reconcile work in the company with personal life and family of the employees.

    • Seek, as far as possible, labor integration of people with disabilities or handicaps, eliminating all kinds of barriers in the company environment for their insertion.

    • Facilitate the participation of employees in the company's social or environmental action programs.


  5. Regarding civil society:

    • Respect human rights and democratic institutions and promote them wherever possible.

    • Maintain the principle of political neutrality, not interfering politically in the communities where it carries out its activities, as a sign of respect for different opinions and sensitivities of people linked to the company.

    • Interact with public authorities and institutions in a lawful and respectful manner, not accepting or offering gifts or commissions, in money or in kind.

    • Refrain from making contributions to political parties.

    • Collaborate with Public Administrations and with non-governmental entities and organizations dedicated to improving the levels of social care.


Employees and Collaborators:

  • Carry out all functions in compliance with the strictest standards of ethics and responsibility, including, but not limited to, those indicated in this document or the verbal instructions of the administration.

  • Absolutely refrain from carrying out any conduct that may be understood as illegal, corrupt, or anticompetitive, in strict adherence to the Anti-Corruption and Anti-Bribery Policies of Makol OCR S.A.

  • Apply the different compliance policies of suppliers as indicated, attending trainings required for this.

  • Carry out assigned duties faithfully and to the best of abilities, responsibly and effectively.

  • Respect the collaborators, avoiding all forms of harassment and bullying, including, but not limited to what is established in Law No. 7476, Law Against Sexual Harassment in Employment and Teaching.

  • Respect that Makol OCR S.A. is an environment of zero tolerance to drugs, alcohol, and tobacco, always complying with the Policy on Alcohol and Drug Free Environment, during working hours or on behalf of the company outside those hours.

  • Refrain at all times from physical or emotional violence towards people and damage to the assets of the company, employees, customers, or suppliers.

  • Seek an adequate use of the resources and assets of the company and use them only for their intended purposes, with criteria of austerity and responsibility.

  • Work time should not be devoted to activities that are not related to the function performed. The personal or commercial activities in which any member of the Company participates outside of their work, should not be in any conflict, either in time or content, with the responsibility contracted with Makol OCR S.A.

  • Safeguard the confidential information of Makol OCR S.A., its suppliers and customers, whether it has been so designated or not, even after the employment relationship has ended; whether they have had access to it by reason of their direct functions or have been indirectly aware of it. This limitation is extended to all commercial information such as customers, prices, pricing policies, strategies of Makol OCR S.A. or its suppliers, etc. that make up daily work of the collaborator.

  • Reasonably use personal social networks, so that they do not compromise Makol OCR S.A. in any way, nor express personal opinions as if they were company opinions, seeking to avoid compromising Makol OCR S.A. at all times.

  • Have a presentation and personal hygiene that reflect the values of professionalism and organizational culture, projecting an image consistent with the company. Having in mind at all times the dress code established by Makol OCR S.A.

  • Immediately communicate any fact or situation that could suppose or come to cause a conflict between the interest of the company and an employee, as well as communicate any fact or situation that could be detrimental to Makol OCR S.A., its suppliers or the image of any of them.