Code of Conduct

3.1 COMPLIANCE WITH THE LAW

All SOLDAVIGIL, S.L. employees and managers shall maintain, in the performance of their work and professional activities, strict compliance with current legislation, in accordance with its spirit and purpose.

The actions of a manager that are contrary to the law or the indications or orders that he/she may give in this sense do not relieve the employees who act according to such indications or orders of responsibility.

All employees must be aware of the laws that affect their work, requesting, where appropriate, the necessary information through their superior or the corresponding bodies.

SOLDAVIGIL, S.L. undertakes to comply with the tax regulations in force in each territory or country where it is present, avoiding the concealment of relevant information, the illegal avoidance of tax payments or the obtaining of undue tax benefits. Likewise, employees shall collaborate with the Tax Authorities to provide the required tax information in accordance with current legislation.

3.2  INTEGRITY AND ETHICS

All SOLDAVIGIL, S.L. employees must carry out their activities with objectivity, professionalism and honesty. Therefore, they must always:

• Provide value and offer Quality and Service in all businesses in which SOLDAVIGIL, S.L. participates.
• Not collect confidential information about markets, products or competition in an unlawful manner.
• Protect confidential information.
• Compete fairly and honestly, avoiding spreading malicious or false information about competitors.
• Respect the intellectual and industrial property rights of both suppliers and customers.
• Oppose all forms of illicit trade and those that violate the regulations in force in each country or territory.
• Not to participate in activities that may involve a conflict of personal and SOLDAVIGIL, S.L. interests.
• Treat all suppliers impartially, selecting them rigorously and objectively, avoiding any conflict of interest or favouritism in their selection.

3.3  RESPECT FOR HUMAN RIGHTS

All actions of SOLDAVIGIL, S.L. and of the people who form part of it shall scrupulously respect the Human Rights and Public Freedoms included in the Universal Declaration of Human Rights of the United Nations.

3.4  SUPPLIERS

SOLDAVIGIL, S.L.’s relationship with its suppliers is based on product and service quality, business and commercial practices, including ethical behaviour, transparency, compliance with applicable legislation and respect for human rights.

The selection of suppliers shall be governed by criteria of objectivity and transparency, reconciling the company’s interest in obtaining the best conditions with the convenience of maintaining stable relationships with ethical and responsible suppliers. Any conflict of interest or favouritism in their selection shall be avoided.

SOLDAVIGIL, S.L. employees shall not request information from suppliers or accept information regarding the conditions set for other companies competing with SOLDAVIGIL, S.L.

No employee of SOLDAVIGIL, S.L. may offer, grant, request or accept, directly or indirectly, gifts or handouts, favours or compensation, in cash or in kind, whatever their nature, which may influence the decision-making process related to the performance of the functions derived from their position.

Specifically, SOLDAVIGIL, S.L. employees may only offer or accept reasonable invitations or token gifts that are appropriate under the circumstances, good customs and generally accepted business practices. In case of doubt, the Compliance Committee must be informed so that it can assess the suitability or otherwise of their acceptance. Cash gifts are expressly prohibited.

3.5  CUSTOMERS

All employees and managers of SOLDAVIGIL, S.L. are obliged to act, in their relations with customers, in accordance with criteria of consideration, respect and dignity, taking into account the different cultural sensitivity of each person and not allowing discrimination in treatment on the grounds of race, religion, age, nationality, gender or any other personal or social condition prohibited by law.

Likewise, they will contribute their utmost collaboration, professionalism and service mentality to seek the greatest customer satisfaction and will make an effort to anticipate their needs.

3.6 OUR PERSONNEL

SOLDAVIGIL, S.L. supports and endorses the principles embodied in the Universal Declaration on Human Rights, Workers’ Rights and the Conventions of the International Labour Organisation.

Therefore, all employees must respect the principles set out below:

3.6.1  Discrimination and harassment

Any form of discrimination shall be avoided, from the selection process, the definition of profiles and functions, always seeking promotion linked to merit, skills and individual abilities.

A working environment free of any discrimination and of any conduct involving harassment of a personal nature, including abuse of authority, whether physical, psychological or moral, shall be maintained. Under this premise, no discrimination on the grounds of race, nationality, social origin, age, sex, marital status, sexual orientation, ideology, political or trade union opinions, religion or any other personal, physical or social condition will be tolerated.

3.6.2  Professional development and training

SOLDAVIGIL, S.L. is committed to maintaining a training policy for the learning and personal and professional development of its employees in order to achieve the highest performance, quality and satisfaction in the performance of their duties, as well as to provide greater value to customers.

SOLDAVIGIL, S.L. personnel, for their part, shall participate in training programmes to the extent required and shall strive to obtain the maximum benefit from them.

3.6.3  Freedom of association

SOLDAVIGIL, S.L. promotes and respects the rights of freedom of association and collective bargaining in the workplace, in accordance with current legislation.

3.6.4  Health and safety at work

SOLDAVIGIL, S.L. promotes the adoption of health and safety at work policies and adopts the preventive measures established in current legislation and undertakes to provide the necessary means to minimise risks at work, both for its own staff and subcontracted personnel.

All employees, whether in-house or subcontracted, are responsible for strict compliance with health and safety regulations. They shall also make responsible use of the equipment assigned to them according to the activities they carry out and shall disseminate appropriate knowledge to colleagues and promote compliance with risk protection practices.

3.6.5  Eradication of forced labour and child labour

Neither SOLDAVIGIL, S.L. nor any supplier company shall use child labour, and shall ensure compliance with the provisions of the International Labour Organisation in relation to child labour.

Likewise, neither SOLDAVIGIL, S.L. nor any of its supplier companies shall resort to forced or coerced labour and shall ensure a balance between the professional and personal spheres of all its employees.

3.6.6  Protection of personal data and information management.

SOLDAVIGIL, S.L. employees shall not disclose personal data obtained from customers, partners, suppliers, collaborating companies, contractors, other employees, public administrations and the general public so that, in accordance with applicable laws, the privacy and trust placed in the company by these groups is ensured.

SOLDAVIGIL, S.L. and its employees shall observe the personal data protection regulations established by law and internal regulations and to this end shall not collect, process, store, retain, communicate or use personal data in a manner that contravenes the aforementioned regulations and shall respect the legitimate rights of the data subjects. In particular, the Privacy Policy set by the company shall apply.

3.7  Relationship with the market and the community

3.7.1  External communication

SOLDAVIGIL, S.L. considers its image and reputation as one of its most valuable assets in order to preserve the trust of its customers, suppliers, authorities and its own staff. Therefore, employees and managers must be especially careful with regard to the information that is transmitted to the outside world and may not issue messages or communications that damage the image and reputation of the company, nor express personal opinions on behalf of the company that are contrary to the company’s values.

3.7.2  With regard to free competition

SOLDAVIGIL, S.L. competes in the market in a fair manner, promoting free competition for the benefit of consumers and under no circumstances accepts misleading, fraudulent or malicious conduct.

The employees of SOLDAVIGIL, S.L. will avoid any type of conduct that could constitute an abuse or illicit restriction of competition, will not carry out unfair actions or illicit advertising of the activity of the company’s business, or that of its competitors or third parties; and will avoid any conduct that constitutes or could constitute an abuse or illicit restriction of competition. Obtaining information from third parties, including competitor information, must be done in a lawful manner.

3.7.3  Accuracy of Financial Information

SOLDAVIGIL, S.L. undertakes to provide complete and accurate information about the company. Likewise, it undertakes to cooperate with supervisory or inspection bodies or entities in all that is required in order to facilitate administrative supervision.

SOLDAVIGIL, S.L. staff shall ensure that all transactions with economic significance that are carried out on behalf of the company are clearly and accurately recorded in appropriate accounting records that represent a true and fair view of the transactions carried out.

Accounting standards and principles shall be strictly followed, financial reporting shall be complete and accurate, and adequate internal controls and procedures shall be in place to ensure that accounting and financial reporting comply with applicable laws, regulations and regulatory requirements.

Conduct aimed at avoiding tax obligations or obtaining benefits to the detriment of the Treasury, Social Security and equivalent bodies is expressly prohibited.

3.7.4  Prevention of money laundering

In order to prevent and avoid money laundering or terrorist financing operations, SOLDAVIGIL, S.L. employees, managers and administrators must pay special attention to cash payments that are unusual in relation to the nature of the operation, those made by means of bearer cheques, those made in currencies other than those previously agreed, those made to countries that have no relation to the operation itself, or those that include unknown or unnecessary intermediaries.

In those operations or activities in which there is a risk of money laundering, SOLDAVIGIL, S.L. is obliged to adopt compliance measures based on the identification of the client and collaboration with the competent authorities.

It is expressly forbidden to make payments or collections in cash in excess of the limits set by the local jurisdiction under any circumstances.

3.7.5  Relationship with administrations and political parties

SOLDAVIGIL, S.L. declares its political neutrality in the territories in which it operates and does not finance political parties or their representatives.

All relations with the Administration will be carried out with total transparency, collaborating with Public Bodies in a disinterested manner.

3.7.6  Fighting bribery and corruption

All SOLDAVIGIL, S.L. employees must behave in such a way that their conduct does not induce a public official, authority or private individual to violate their duties of impartiality or any legal precept. From this obligation derives:

• The absolute prohibition to offer any public official, authority or private individual, directly or indirectly, any type of gift, retribution of any other type or undue advantage, with the aim of violating their obligations in order to favour SOLDAVIGIL, S.L.
• The prohibition to carry out any type of behaviour or activity aimed at unlawfully influencing the behaviour of a public official or authority to adopt or not to adopt a decision that could favour the company or related parties.
• The prohibition of receiving, requesting or accepting an unjustified benefit of any nature, with the aim of favouring against third parties the person who grants or from whom the benefit or advantage is expected in breach of his obligations.

These prohibitions also extend to persons closely linked by family or friendship to the public official, authority or private individual.

3.7.7  Protection of the environment

SOLDAVIGIL, S.L. is committed to the protection and conservation of the environment and, therefore, carries out its activity under the premises of optimising the consumption of natural and energy resources, minimising the waste generated, as well as its recycling, reuse and reduction; and controlling the polluting spills and emissions associated with the activity.

All SOLDAVIGIL, S.L. personnel must comply with the environmental legislation and regulations applicable to their area of activity.