a little bit of history

In the late 1990s, Felipe Ibáñez and Jorge Gutiérrez, who had been friends since childhood, founded Viña Anakena in Alto Cachapoal, at the foothills of the Andes Mountains with the goal of crafting elegant, innovative, and distinctly New World wines that reflected their origin and Chile’s potential as a producer of world-class fine wines.

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Roots of The Andes

Code of Ethics

LETTER FROM GENERAL MANAGEMENT

Dear Colleagues:

The following is a description of the rules of conduct that guide our behavior as employees of Viña Anakena.

Our success is closely tied to our reputation, which we have built through the efforts of everyone in this organization over the course of more than 10 years.

These rules simply refer to treating our coworkers, customers, partners, suppliers, and consumers fairly and with dignity. As members of our organization, it is our responsibility to act honestly and prevent inappropriate conduct.

I invite you to read this code and follow it closely so that we can all feel proud to work in the winery.

INTRODUCTION

This code defines the commitments, principles, and responsibilities of all employees of Viña Anakena, and also pertains to all who provide services to this organization.

Our company’s mission is to be an example of quality in Chile and abroad, and because our strategic pillars include social responsibility, the integrity of everything we do is essential.

This code is intended to regulate our professional actions in establishing relationships of trust based on integrity and honesty. It also delineates our responsibilities to the company as well as our coworkers, customers, suppliers, consumers, and governments.

Integrity:

Integrity is the quality of consistency, sincerity, and honesty. A person with integrity is trustworthy. Integrity is a fundamental value in our organization.

Management:

Managers must set an example of proper conduct and provide a clear, coherent, and credible perspective and use good judgment to create an environment in which employees feel safe to express their concerns without fear of reprisal.

The managers must encourage compliance with the Labor Code, Internal Regulations, and the Law.

Concerns

In the event that a violation of the conduct code is observed, the witness must immediately inform the Conduct Committee or General Management, which will then conduct a thorough and fair investigation in order and resolve the matter.

The company values the collaboration of employees who identify potential problems that need to be addressed and under no circumstances will such action jeopardize employment.

The information provided must be honest and precise.

The Code and the Law

Viña Anakena complies with the laws and regulations applicable to its business.

“The labor laws exceptionally authorize people who are 15–18 years old with the express authorization of their parents or guardians to enter into employment contracts for the sole purpose of performing light tasks that do not compromise their health and development and that comply with established formalities,” Labor Law.

In its commitment to the prevention of child labor, Viña Anakena will not enter into any contractual relationships of subordination of or dependence upon minors under the age of 18. This measure is also applicable for sub-contracted companies.

Viña Anakena employees and those of its operations abroad will comply with all of the laws and internal regulations of the foreign countries in which they operate.

Commercial and Financial Records

The company’s accounting standards and principles are based on legal regulations that ensure the preparation of complete financial reports that are complete, reliable, accurate, and in full compliance with the law. Any attempt to distort the true nature of a transaction or to evade taxes will be not be tolerated.

Company Property

Company property must be protected and used as intended and not for personal gain or the benefit of any person outside the organization.

Excessive phone calls and e-mails are considered to be a misuse of company property.

The unauthorized removal of company products, equipment, or information, embezzlement, or intentional use of false information may result in dismissal and criminal prosecution. The theft of items belonging to other employees will be treated in the same manner as the theft of company property.

Employees must not engage in personal activities during working hours that interfere with or impede compliance of job-related responsibilities.

Company computers and equipment may not be used for outside business or illegal activities.

Employees may not take advantage of information acquired through the company for personal financial gain.

Company assets include, but are not limited to:

• Company funds and products

• Employee time and the product of their work

• Computer systems and programs

• Telephones, wireless communications devices, and photocopiers

• Company vehicles

• Confidential information

• Company commercial brands

Use of Information

All of the company’s non-public information, including contacts and pricing information, market plans, technical specifications, and employee information, etc., must be protected.

Employees must not reveal non-public information to anyone outside the company, including friends and family.

Employees are required to protect the company’s non-public information at all times, whether during working hours or on personal time, and even after employment has ended.

Definition of non-public information:

Non-public information is that which the company has not revealed or that is not normally available to the public, including, but not limited to employees, inventions, contracts, strategic and business plans, major management changes, new product launches, mergers and acquisitions, technical specifications, prices, proposals, financial information, and product costs.

Privacy

• Viña Anakena respects the privacy of all of its employees, business partners, and consumers.

• Personal information should be treated with respect and be in compliance with all applicable privacy laws.

• Employees who handle personal information of others must:

• Act in accordance with applicable laws and with all of the pertinent contractual obligations.

• Take care to avoid any non-authorized revelation of information.

Conflicts of Interest:

Employees are asked to act in the best interest of the company during their employment at Viña Anakena. This includes being responsible when representing the company in selecting and negotiating with suppliers. Personal interests and relationships must not interfere with the ability to make decisions in the best interest of the company. Suppliers must be selected in accordance with the company’s purchasing procedures.

Any element or action that could result in conflict of interest must be discussed with area management and general management prior to proceeding.

Termination of Employment

Upon termination of employment, but prior to signing the termination contract, all Viña Anakena property, documentation, or other medium that contains proprietary and/or confidential information must be returned to the company. It is also understood that no proprietary information may be used or divulged upon leaving the company.

External Employment

Viña Anakena employees may not be employed by, lend services to, or receive payment from any of the company’s customers, suppliers, or competitors.

Personal Relationships

Personal relationships in the workplace must not affect the ability of any employee to act in the best interest of the company nor should they affect any workplace relationship. Decisions must be based on the qualifications, performance, abilities, and experience.

Gifts, Meals, and Favors

Any gifts, meals, or other types of favors accepted from customers or providers must be reasonable and appropriate for the circumstances and must not compromise an employee’s ability to make objective business decisions on behalf of Viña Anakena.

Should a gift or favor exceed reasonable parameters, the employee must politely refuse the offer and explain the company rules.

Gifts, Meals, and Favors for customers and suppliers.

Any gifts, meals, or other types of favors for customers and suppliers must support the legitimate commercial interests of the company and must be reasonable and appropriate for the circumstances.

Negotiations

Viña Anakena’s external relationships are essential to our success. We must be reasonable and fair in our dealings with others.

Negotiations with the Government

Any interactions with government officials from around the world must be covered by the legislation of the country in which said interaction takes place and in no case should they take place for private businesses. Nothing should be offered to a government official in exchange for favorable treatment. Gifts must not be made to government officials.

Prohibition of Bribery

A bribe consists of giving or offering something of value to a government official to influence a discretionary decision, a payment to a government official to encourage a decision to enter into or continue business relations, to influence the outcome of a government audit or inspection or to influence tax law or any other type of legislation.

This type of conduct is strictly prohibited and any violation of the code in this matter should be reported to the ethics committee.

Negotiations with Customers, Suppliers, and Consumers

Viña Anakena values its associations with customers, suppliers, and consumers, and therefore its employees and representatives must always negotiate honestly and respectfully. It is important to emphasize that employees may not engage in unfair, deceptive, or misleading practices, and that the company’s products must be presented honestly and directly without offering or promising anything to the customer or supplier in exchange for an improper advantage for the company or individual.

Negotiations with Competitors

Viña Anakena competes fairly and adheres to the guidelines for competition that are applicable around the world.

Competitive Intelligence

When employees are asked to gather, share, and use information about our competitors, it must always and only be done in a legal and ethical manner that respects the non-public information of other companies. Likewise, employees must not engage in illegal activities to obtain that information.

Responsibility

The responsibility for administrating and enforcing the Code of Conduct falls to the Conduct Committee, which is composed of the company’s managers.

The current members of the Conduct Committee are:

- Ricardo Letelier, General Manager

- Luis Enrique Izquierdo, Marketing & Sales

- Carlos Pasten, Administration & Finance

- Jean Paul Veas, Operations

- Gavin Taylor, Enology

Investigation

The company will take under serious consideration all reports of potential violations of the Code and is committed to the confidentiality and thorough investigation of all accusations. Employees who are under investigation for a potential code violation will be given the opportunity to be heard prior to the making of a final decision.

Disciplinary Measures

Violations of the Code of Conduct may result in dismissal of an employee who commits a serious offense. The committee will evaluate the measures to be taken within the framework of the law.

Integrated Policy

We at Viña Anakena are fully committed to the National Sustainability Code for Chilean Wine, which aims to guide our management practices as well as our commitment to the processes of excellence, caring for the environment, and strong emphasis on the highest quality.

The ongoing expansion of increasingly demanding markets and destinations for Viña Anakena wines around the world guide these actions within the framework of our objectives and strategies for sustainability.

The United Nation’s 1987 Brundtlan Report defined sustainability as the development of that which satisfies the needs of the current generations without compromising the development of future generations. It includes three essential objectives with respect to the environment, social justice, and economic viability, and the convergence of these elements with respect to sustainability contributes to the pillars of Viña Anakena, one of the first wineries in Chile to be certified sustainable under the National Sustainability Code in 2011.

As a result, we have developed our new management policies based on the following commitments:

• Continuous improved of the Integrated Management System to ensure the quality and safety of products for our customers.

• Develop productive processes that eliminate or reduce workplace hazards.

• Prevent contamination through the rational use of natural resources and by decreasing the waste products generated.

• Comply with current legislation and commitments to sustainability.

• Work in conjunction with our suppliers to generate synergies and opportunities.

The development and implementation of this policy is the responsibility of the entire Viña Anakena team, and we are committed to continuing to develop and improve it over time.


Ricardo Letelier Querci
General Manager