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Code of Ethics DEPOT ZONA FRANCA S.A.

BASIC PRINCIPLES THAT GUIDE THE BEHAVIOR OF DEPOT ZONA FRANCA AND ITS EMPLOYEES AND MANAGERS

INDEX

 

1. PURPOSE AND SCOPE
2. RESPONSIBILITIES OF EMPLOYEES AND MANAGERS
2.1. Employee Responsibilities
2.2. Additional Responsibilities of Managers
2.3. Code Violations
3. BASIC PRINCIPLES OF BEHAVIOR
3.1. Respect for legality
3.2. Ethical Integrity
3.3. Respect for human rights
4. RELATIONSHIP WITH AND BETWEEN EMPLOYEES
4.1. Respect for and promotion of non-discriminatory treatment
4.2. Abolition of child labour
4.3. Equal Housing
4.4. Occupational safety and health
4.5. Respect for the privacy and confidentiality of employee information
4.6. Promotion of personal and professional balance
5. COMPLIANCE WITH APPLICABLE LAWS
5.1. Relationship with Administrations
5.2. Anti-Corruption Laws
5.3. Insider trading
5.4. Anti-Money Laundering Laws
5.5. Fair Competition
5.6. Accuracy in Books and Records
6. COMMITMENTS TO THIRD PARTIES AND THE MARKET
6.1. Quality
6.2. Confidentiality Regarding Third Party Information
6.3. Transparency, Value Creation and Corporate Governance
6.4. Protection of corporate assets
6.5. Conflicts of interest
6.6. Relationship with suppliers and customers.
7. COMMUNITY ENGAGEMENTS
7.1. Environment
7.2. Social Commitment

1. PURPOSE AND SCOPE

The objective of this Corporate Code of Ethics is to establish the basic principles to which the following individuals and entities must behave in the scope of their activities related to Depot Zona Franca, S.A.:

  • Depot Zona Franca, S.A. and all its business divisions regardless of their business area, geographical location or activities.
  • The members of the administrative bodies of Depot Zona Franca S.A.
  • Employees of any of your business divisions.

For the purposes of this Code, Depot Zona Franca, S.A. or its business divisions refer to both Depot Zona Franca, S.A. and all companies that it controls or may control, directly or indirectly. “Control” is understood to exist when the majority of the voting rights of the governing body are held.

If there are domestic laws, practices or procedures applicable to natural and legal persons subject to this Code that are stricter than its provisions, they shall enjoy pre-eminence. Depot Zona Franca, S.A. will ensure that the principles established in this Code are observed in all the companies in which it participates.

2. RESPONSIBILITIES OF EMPLOYEES AND MANAGERS

  • 2.1. Employee Responsibilities
  • 2.2. Additional Responsibilities of Managers
  • 2.3. Code Violations

All employees shall adhere to the principles and requirements contained in this Code and ensure that other individuals or groups doing business on behalf of Depot Zona Franca, S.A., including contractors, agents, consultants and other business partners, do so. Employees must correctly understand the policies, procedures and other requirements of Depot Zona Franca, S.A. that are applicable to the exercise of their duties, and must ask for help from their superior or legal counsel if necessary.

All employees who have knowledge or reasonable suspicion of a breach of this Code must notify their superiors or communicate it through the established mechanisms for making suggestions and submitting complaints. Depot Zona Franca, S.A. shall take the necessary measures to prevent negative repercussions due to notifications made by employees in good faith and under this Code.

All managers must ensure that their employees are aware of and respect the behaviours set out in this Code. Likewise, they must ensure that all surveillance procedures established to ensure compliance with this Code and the policies and procedures of Depot Zona Franca, S.A. are functioning correctly, notifying their superiors if they do not.

Failure to comply with this Code may constitute a labor violation and may be subject to appropriate sanctions, regardless of other liabilities that the employee may have incurred. To resolve incidents or doubts regarding the interpretation of this Code and propose measures for improvement, a Compliance Committee will be created.

3. BASIC PRINCIPLES OF BEHAVIOR

  • 3.1. Respect for legality
  • 3.2. Ethical Integrity
  • 3.3. Respect for human rights

The business and professional conduct of entities and persons subject to this Code shall comply with the following basic principles:
The activities of Depot Zona Franca, S.A. will be carried out in strict compliance with applicable legislation.

The business and professional activities of Depot Zona Franca, S.A. and its employees will be based on the values of integrity, honesty, avoidance of all forms of corruption and respect for the particular circumstances and needs of all the subjects involved in them. Depot Zona Franca, S.A. will promote among its employees the recognition and appreciation of behaviors that are in accordance with the principles established in this Code.

All actions of Depot Zona Franca, S.A. and its employees shall scrupulously respect the Human Rights and Public Freedoms included in the Universal Declaration of Human Rights. These basic principles will be translated into the fulfilment of the commitments set out below.

4. RELATIONSHIP WITH AND BETWEEN EMPLOYEES

  • 4.1. Respectful treatment and promotion of non-discriminatory treatment
  • 4.2. Abolition of child labour
  • 4.3. Equal Housing
  • 4.4. Occupational safety and health
  • 4.5. Respect for the privacy and confidentiality of employee information
  • 4.6. Promotion of personal and professional balance

Depot Zona Franca, S.A. assumes the responsibility of maintaining a work environment free of all discrimination and any conduct that implies harassment of a personal nature. Every worker must be treated fairly and with respect by his superiors, subordinates and colleagues. Any abusive, hostile or offensive conduct, whether verbal or physical, will not be tolerated.

Depot Zona Franca, S.A. will not resort to child labor or incorporate any product or service from it into its business activity and will ensure compliance with the provisions of the International Labor Organization (ILO) in relation to the labor of minors. Depot Zona Franca, S.A. requires all its employees and suppliers to strictly observe this principle.

All employees shall enjoy equal opportunities for career development regardless of age, sex, marital status, race, nationality and beliefs. Depot Zona Franca, S.A. is committed to establishing an effective equal opportunities policy for its employees to carry out their professional activity on the basis of the principle of merit.

Promotion decisions will always be based on objective circumstances and assessments.

Likewise, Depot Zona Franca, S.A. is committed to maintaining an investment policy for the learning and personal and professional training of its employees. The employees of Depot Zona Franca, S.A. will respect the equal opportunities policy in their professional field and will support the personal and professional learning of their colleagues.

Depot Zona Franca, S.A. will provide its employees with a safe and stable environment, keep occupational risk prevention measures up to date and scrupulously respect the applicable regulations in this area in all places where it carries out its business activities.

All employees are responsible for strictly adhering to health and safety regulations in order to protect themselves and other employees or third parties. Likewise, they must make responsible use of the equipment assigned to them when carrying out risky activities and will disseminate knowledge among their colleagues and subordinates and promote compliance with risk protection practices.

Depot Zona Franca S.A. undertakes to request and use only those employee data that are necessary for the effective management of its business or whose proof is required by the applicable regulations. Likewise, Depot Zona Franca S.A. will take all necessary measures to preserve the confidentiality of the personal data in its possession and to guarantee that the confidentiality in the transmission of the same, when necessary for business reasons, is in accordance with current legislation. Employees who, in the course of their professional activity, have access to information from other employees shall respect and promote the confidentiality of this information and shall make responsible and professional use of it.

Depot Zona Franca S.A. values the benefits for the employee and the company of a balance between the professional and personal responsibilities of its employees, and will therefore promote measures aimed at reconciling these two areas.

5. COMPLIANCE WITH APPLICABLE LAWS

  • 5.1. Relationship with Administrations
  • 5.2. Anti-Corruption Laws
  • 5.3. Anti-Money Laundering Laws
  • 5.4. Fair Competition
  • 5.5. Accuracy in Books and Records

Employees interacting with Administrations on behalf of Depot Zona Franca S.A. shall ensure that all communications, both direct and through intermediaries, are accurate and comply with all applicable laws and regulations.

Depot Zona Franca S.A. requires compliance with all applicable laws prohibiting bribery, especially bribery of officials, including the Spanish Penal Code and any other anti-corruption legislation that may be applicable.

Employees will be required to comply with all anti-money laundering laws, maintain business only with partners in good standing, and receive funds only from legitimate sources. Employees must take reasonable steps to detect and prevent unacceptable or suspicious forms of payment, and report them to their superiors or report them through established channels if they have any suspicion or concern.

Depot Zona Franca S.A. prohibits any action that involves the exercise of illegal unfair competition practices and undertakes to ensure compliance with the applicable antitrust laws.

Depot Zona Franca S.A. and its subsidiaries must have in place accounting practices that help ensure the accuracy of their books and records.

6. COMMITMENTS TO THIRD PARTIES AND THE MARKET

  • 6.1. Quality
  • 6.2. Confidentiality Regarding Third Party Information
  • 6.3. Transparency, Value Creation and Corporate Governance
  • 6.4. Protection of corporate assets
  • 6.5. Conflicts of interest
  • 6.6. Relationship with suppliers and customers.

Depot Zona Franca S.A. establishes as a guideline of its business action the search for quality in its products and services and will make available to its employees the necessary means for the development of the most appropriate quality management systems at all times.

Depot Zona Franca S.A. will seek to best meet the expectations of its customers and will strive to anticipate their needs.

Depot Zona Franca S.A. guarantees respect for the confidentiality and privacy of the data of third parties in its possession. Depot Zona Franca S.A. undertakes to preserve the confidentiality of the data it has referring to third parties, without prejudice to the legal, administrative or judicial provisions that require them to be delivered to entities or persons or made public.

Likewise, Depot Zona Franca S.A. guarantees the right of affected third parties to consult and promote the modification or rectification of the data when necessary. The employees of Depot Zona Franca S.A., in the performance of their professional activity, will keep the confidentiality of the data in the terms set forth above and will refrain from any inappropriate use of this information.

Depot Zona Franca S.A. and its employees will base their relationships with customers, suppliers, competitors and partners, as well as with other market players on the principles of integrity, professionalism and transparency.

Depot Zona Franca S.A. and its employees will always seek, within their scope of action and their obligations, the greatest protection of all assets and rights that constitute the assets of the companies of the Group, preserving the confidentiality of the information relating to it, which may only be used in relation to the activities of the company. Employees are responsible for protecting the assets of Depot Zona Franca S.A. entrusted to them and preserving them from any loss, damage, theft, or illegal or dishonest use.

All employees of Depot Zona Franca S.A. must avoid situations that may involve a conflict between their personal interests and those of Depot Zona Franca S.A. and refrain from intervening or influencing decision-making when, directly or indirectly, they or a third party linked to them by any significant economic, personal or professional relationship has a personal interest. Employees who find themselves in a situation of conflict are obliged to report it to their line manager.

Operations with suppliers and customers are carried out according to objective, impartial criteria that guarantee equal opportunities, avoiding favourable treatment or interference from conflicts in the selection processes.

Depot Zona Franca S.A. requires its suppliers to have an adequate level of commitment to socially responsible practices that are compatible with this Code of Conduct (Respect and promotion of non-discriminatory treatment, abolition of child labor, equal opportunities, occupational safety and health, respect for the privacy and confidentiality of employee information, Promotion of personal and professional balance).

All requests for external procurement must be followed with maximum transparency, avoiding any favourable treatment. It is not allowed to participate in or influence the procedures for the contracting of products or services with companies or people with whom the collaborators and members have some economic or family relationship.

The concurrence of these circumstances will be brought to the attention of the Member in the Head of Organization of Depot Zona Franca S.A., as soon as he or she becomes aware of it. The transmission of values and the generation of an honest and transparent dialogue with customers are the principles that govern the development of the activity of Depot Zona Franca S.A. All members of the organization will interact with customers in a lawful, ethical and respectful manner. It is necessary to have an open and empathetic attitude to the suggestions transmitted by the client and a permanent willingness to adopt any actions that may be necessary to clarify doubts and correct deficiencies and errors, as well as to introduce the pertinent improvements in the activity.

It is not permitted to offer, promise and/or deliver any type of gifts, commissions, advantages or gifts to companies, institutions or clients with which Depot Zona Franca S.A. has a relationship and that may improperly influence their decision-making processes. On the other hand, the members of Depot Zona Franca S.A. may not make or accept from individuals, companies or customers, gifts, invitations or payments in kind that go beyond the uses of mere courtesy. In other words, its value may be considered excessive or exaggerated because it exceeds thresholds that in the usual practice of the sector are considered reasonable, current or ordinary.

7. COMMUNITY ENGAGEMENTS

  • 7.1. Environment
  • 7.2. Social Commitment

Depot Zona Franca S.A. will seek the greatest possible respect for the environment in which it carries out its activities and will minimize the negative effects that these may eventually cause. It shall provide its employees with the most appropriate means to do so. It will also contribute to the conservation of natural resources and those spaces of ecological, landscape, scientific or cultural interest. To this end, it will establish best practices and promote knowledge and use among its employees. Depot Zona Franca S.A. is committed to strict compliance with applicable environmental legislation.

Depot Zona Franca S.A. is committed to acting in a socially responsible manner, in compliance with the law of the countries in which it operates and, in particular, assumes the responsibility of respecting cultural diversity and the customs and principles in force among the people and communities affected by its activities.