About us
With more than 60 years of experience and trajectory, at DF Group we are sure of who we are and what we want. Our mission is to contribute to creating a better world by seeking to generate a positive impact on the quality of life of our clients. We want to make a constructive contribution to society.
DF Group is more than products, it is Vocation, Innovation and Service.
Our job is to get involved and relate to create opportunities, to build and grow; transmitting to others our family values, for success in business and in life. We professionalize ourselves to face adversities and discover opportunities We enjoy and love what we do
Welcome to our Family
Scope
This Code shall apply to partners, managers, employees and interns (collectively, collaborators), as well as to suppliers, commercial agents, representatives, contractors, clients, and other stakeholders as appropriate under the circumstances and applicable (collectively, third parties), who must know, understand and abide by the provisions of this Code.
Corporate governance
The Managing Partners and the General Manager will be the highest-level decision-making bodies regarding the implementation of this Code of Ethics. They must take the necessary measures to ensure that all persons covered by this Code are aware of, understand, and abide by its provisions.
The Ethics Committee, comprised of the Compliance Officer and the General Manager, will be responsible for overseeing compliance with this Code, including investigations into complaints. The General Manager and the Compliance Management System (CMS) Manager must implement procedures and actions to ensure compliance with this Code. In turn, in coordination with the HR Department, they will adopt measures to ensure all employees are trained to comply with the provisions herein and related policies. In the case of business partners, the Area Representatives will coordinate appropriate communication mechanisms with the CMS Manager. All those who interact with the company are responsible for complying with the principles of this Code in their roles within the company. The CMS Manager will resolve issues related to the interpretation of this Code that cannot be satisfactorily addressed through normal supervisory or communication channels, and may have direct access to the Managing Partner.
Compliance with the law
Those who interact with DF Megafrío SRL are responsible for understanding and complying with the laws, regulations, contracts, and standards of the Republic of Argentina and the countries in which they operate, as well as the company's internal rules applicable to their duties. Noncompliance may result in financial harm or penalties for employees, and the company's reputation may be affected, regardless of the public status of the noncompliance.
Conducting legal consultations in a timely manner is essential to ensuring business legitimacy, protecting the interests of DF Megafrío SRL, its competitive advantages, and the normal conduct of its commercial activities.
Compliance Management System (CMS)
DF Megafrío SRL has developed an integrity program in accordance with the requirements of Law 27.401 and its amendments, consisting of this Code of Ethics, the Compliance Policy, integrity in bidding processes or relevant interactions with the public sector, and a training plan for staff. All of this constitutes a compliance management system in accordance with the IRAM-ISO 37001:2019 standard.
In line with this program, partners and managers explicitly declare the organization's commitment to not using influence in public office and require employees to inform their supervisors if they have a politically exposed family member, so they can assess the situation and develop an action plan if necessary. Furthermore, the company does not participate in public bidding processes.
Integrity in business
DF Megafrío SRL upholds its commitment to zero tolerance for corruption, bribery, facilitation payments, and conflicts of interest in all their forms. It neither gives nor receives bribes or facilitation payments to achieve improper advantages in its business or finances, nor does it use agents or third parties to give or receive bribes and/or facilitation payments on its behalf.
The use of these means constitutes a crime and is therefore covered by local legislation on the matter.
Confidentiality, data protection and intellectual property
Company information may not be used for purposes other than the performance of the duties of each area, nor may it be disclosed without prior authorization from the partners and managers of DF Megafrío SRL. All non-public information, such as strategic plans, commercial databases, financial plans, projects, as well as customer and supplier information, is considered confidential information. Likewise, all information arising from commercial or administrative transactions related to the company's activities is considered confidential information. Employees must maintain the confidentiality of this information, and these obligations will continue even after they leave the company. The commercialization and/or dissemination of any type of information is prohibited.
All persons covered by this Code are required to diligently protect the information and data entrusted to them by the Company or to which they have access as a result of their work. They must identify themselves appropriately if it is confidential information and, in all cases, keep it in a secure location and manner, limiting access only to those who need it to perform their duties.
The Company reserves the rights and intellectual property rights over all information, inventions, and/or creations developed by its employees as a result of their work, unless expressly provided otherwise in writing by the Board of Directors.
Responsible risk management
All employees must be responsible and fully aware of the risks involved in their actions in the performance of their duties. If they have any doubts regarding the risks assumed, they should raise them with their immediate supervisor, who must clarify them. All employees are responsible and must avoid compromising the firm's corporate image by engaging in illegal acts or acts contrary to morality and good practices, and/or compromising good market practices in the industries and other activities in which they operate.
Conflict of Interest
DF Megafrío SRL is committed to preventing situations that may constitute conflicts of interest in order to avoid personal interests interfering with those of the Company.
A conflict of interest is understood as any situation in which an employee may benefit themselves and/or a relative, close associate, or third party by placing their own interests (or those of the relative, associate, or third party) above those of the Company.
All individuals subject to this Code must refrain from using the Company’s financial, human, and/or work resources for personal gain, as well as from using commercial information or business plans to carry out personal activities or projects, whether for themselves or for someone close to them.
Employees must report any situation that presents a conflict of interest to their immediate supervisor, who will evaluate the situation and implement an appropriate action plan.
Purchasing and Contracting
Employees whose responsibilities include purchasing products or contracting services from suppliers must ensure that such transactions are conducted under normal market conditions and comply with the provisions of this Code of Ethics as well as the Company’s internal procedures. Suppliers will be evaluated based on fair and transparent commercial and technical criteria, applying due diligence standards and policies as defined in the commercial negotiation procedures.
In turn, suppliers are committed not only to maintaining the confidentiality of information, but also to refraining from engaging in conduct with third parties on behalf of DF Megafrío SRL that could improperly involve the Company.
Third-Party Due Diligence
DF Megafrío SRL carries out a Due Diligence process aimed at mitigating potential risks associated with third parties, such as business partners, suppliers, distributors, and intermediaries. To this end, the company continuously works on a stakeholder risk matrix and updates control points within both processes and work instructions.
The presence of medium-high risk levels does not preclude a commercial relationship but requires the collection of supporting evidence to explain or justify each of the risks involved.
However, the presence of high-risk levels does preclude the establishment of a commercial relationship.
Use of Communication Channels
DF Megafrío SRL provides its employees with both internal and external communication networks to ensure a smooth flow of information (emails, mobile phones, Slack, the internal communication platform HUMAND, and reporting channels accessible via HUMAND or the company website).
It is important to emphasize that when communicating on behalf of the organization, it is essential to provide timely, reliable, accurate, and easily understandable information. One must always keep in mind that everything written or said can impact the company’s reputation.
Information may only be shared with third parties outside the company if there is specific authorization and the accuracy of the information has been verified with the appropriate department within the organization.
Accurate Records, Reporting, and Accounting
The financial records and other information provided by DF Megafrío SRL to its shareholders, regulators, and other stakeholders must be accurate and complete. These records offer valuable insights for the business and serve as evidence of its actions, decisions, and obligations. Therefore, it is of utmost importance to comply with all internal control procedures implemented by the company to ensure proper accounting of transactions and their corresponding disclosure.
These procedures must be included in the company’s Procedures Manual, kept up to date, followed, and published on the internal communication platform (HUMAND) to ensure that all transactions are properly authorized and recorded.
Internal Controls
It is the policy of DF Megafrío SRL to promote a culture focused on control. Internal controls help manage operations effectively, provide accurate and reliable information, prevent unlawful conduct, and protect the company’s assets.
All members of the Company, according to the hierarchy established in the organizational chart, are responsible for internal control and for ensuring compliance with the established controls. They must also be proactive in monitoring risks and, when weaknesses are identified, either implement or propose appropriate control measures.
Relationships with Employees and Stakeholders
DF Megafrío SRL establishes that interactions with employees and various stakeholders must take place in an environment of Respect, Dignity, and Fair Treatment.
Customer Focus
DF Megafrío SRL focuses on meeting customer requirements and strives to exceed their expectations, recognizing that sustained success is achieved when an organization earns and maintains the trust of its customers and other stakeholders. To this end, the company implements, maintains, and continuously improves a Quality Management System in accordance with the IRAM-ISO 9001:2015 standard.
Product Requirements
DF Megafrío SRL guarantees the safety and quality of the products it markets. To achieve this, it is committed to communicating product requirements to its suppliers and ensuring that the specifications are understood and implemented. The company guarantees that appropriate measures have been implemented for the services provided and that suppliers operate in accordance with product quality and safety requirements, thereby complying with legal and contractual specifications.
Environmental Responsibility and Sustainability
DF Megafrío SRL is committed to ensuring that its actions have a positive impact on people and the environment, maintaining a preventive approach to care and promoting initiatives that encourage greater environmental responsibility. The company understands and acknowledges that natural resources are finite, making their protection and rational use essential. It promotes the use and analysis of Sustainability Indicators to support effective resource management.
Customer Due Diligence
Our Due Diligence process also applies to our international customers in order to prevent involvement in activities regulated by Law 27.401 regarding money laundering. DF Megafrío SRL knows its international customers and does not engage in transactions where the source of funds is at risk.
Training
DF Megafrío SRL firmly believes that continuous training in best practices is crucial to fostering a culture of compliance and integrity. Therefore, an annual training plan has been developed, which includes the Integrity Program and other training sessions that support the achievement of the company’s objectives.
Reporting Channels
This Code serves as a resource that helps us act ethically and responsibly in our daily activities, promoting high standards of conduct. Therefore, it is the responsibility of everyone at DF Megafrío SRL and its stakeholders to report any behavior that contradicts the good practices and values described herein. To this end, a consultation and reporting channel has been made available on our website, allowing for immediate and confidential communication, as well as inquiries regarding our integrity program.
Non-Compliance and Sanctions
In the event of a breach of this Code of Ethics, the company’s rules and/or policies, as well as applicable regulations and laws, by any of the stakeholders, sanctions may be imposed. Such sanctions may include, but are not limited to, the termination of the employment or contractual relationship, as applicable. Additionally, appropriate legal actions will be taken.
It should be clarified that the provisions of the Code take precedence over instructions from supervisory levels.