Ethical code

Chapter I.- Purpose and scope

 

Article 1.- Purpose

Manusa Gest, S.L and its subsidiaries (hereinafter known indifferently as the “Manusa Group” or “the Organisation”), the origins of which date back to 1966, is a leading company in the automatic door and access control system market. Our 50-plus years of experience enable us to offer a wide range of access solutions adapted to each specific need.

The Organisation currently employs over 250 qualified people, enabling us to produce more than 18,000 doors a year. The Manusa Group has its own branches in Spain, Portugal, Brazil,
China and the United Arab Emirates, and is present in more than 80 countries around the world.

Our aim is to position ourselves and grow sustainably in the market, progressively and orderly reaching our goals, making every effort to respect and fulfil the values and directives of the Organisation in this mission on a daily basis. We have therefore prepared this Code of ethics and conduct (hereinafter also known as the “Code”), which is in line with and defines the objectives, principles and values we observe and want our Stakeholders to observe when doing business with our Organisation.

Through this document, the Manusa Group wishes to give a message of ZERO TOLERANCE to any illegal or criminal act, or acts that are contrary to the principles of this Code. We will therefore distribute the contents of this Code and will active promote its adherence by all those wishing to establish a professional and/or business relationship with the Organisation.

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Article 2.- Scope

This Code, along with the in-house policies and regulations implementing it, must be followed by all Members of the Organisation when performing their duties and in their business and professional relationships, regardless of the place where they work and always in line with the law, customs and common uses of the countries where they operate.

The Members of the Organisation must also comply with the current law in force and other in-house regulations of the Organisation.

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Article 3.- Conceptual demarcation

3.1 senior management

Person or group of people who manage and control an organisation at the highest level.‍

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3.2 conflict of interest

Situation in which external business, financial, family, political or personal interests might interfere in the judgement of the members of the organisation when they are doing their jobs in the organisation. ‍

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3.3 stakeholder

Person or organisation that might affect, be affected, or be perceived as affected by a decision or activity of the organisation.

NOTE 1 By way of example and for the purposes of this document, stakeholders might include,
for example, the members of the organisation, the business partners, the Regulator, administrative authorities, legal authorities, Tax Department and Social Security.‍

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3.4 members of the organisation

The members of the board of directors, management, employees, temporary workers or employees or those working under a cooperation agreement, and volunteers of an organisation and all others under hierarchical subordination of any of the aforementioned. ‍

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3.5 organisation

Person or group of people with their own duties, with responsibilities, authorities and relationships to meet its objectives. ‍

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3.6 criminal compliance body

Body of the organisation with independent powers of initiative and control that is entrusted with the responsibility of supervising the operating and observance of the criminal compliance management system. ‍

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3.7 criminal compliance policy

The will of an organisation, as expressed formally by its senior management or its board of directors, with regard to its criminal compliance objectives.

NOTE 3 the criminal compliance policy may be included in a single document or in several documents integrated into the criminal compliance management system.‍

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3.8 criminal compliance management system

A set of elements of an organisation that are interrelated or that interact to specify and measure the extent to which the criminal compliance objectives are met, as well as the associated policies, processes, procedures and controls to meet said objectives. ‍

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3.9 business partner

Any party, except the members of the organisation, with whom the organisation has, or plans to establish, some kind of business relationship.

NOTE 4 Business partners include, but are not limited to customers, joint ventures, partners of joint ventures, partners of consortiums, contractors, commission agents, consultants, subcontractors, suppliers, vendors, advisors, agents, distributors, representatives, intermediaries and investors.

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3.10 third party

Physical or legal person or body that is independent from the organisation.‍

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Chapter II.- Principles

 

Article 4.- Ethical principles governing Manusa Group activity

This Code forms part of the Organisation’s criminal compliance policy and constitutes an instrument for expressing and implementing its basic principles, including the following:

1. The customer-approach culture, offering actual solutions with regard to consumer and user regulations.
2. Professionalism, Quality, Safety, Commitment, and Moral integrity in our products and services, and in the actions of our personnel.
3. Diligence, objectiveness, transparency and honesty in all our decisions and in the undertaking of our activities.
4. Fair competition with the rest of the market players in order to safeguard free competition.
5. Sustainable growth with full respect for the Environment.
6. Social Responsibility and Commitment.
7. Observance and compliance with this Code and other in-house regulations, professional ethics and good faith in business relationships.
8. Good Corporate Governance.
9. Zero tolerance towards illegal or criminal events, fully respecting the law in the territories where the Organisation operates and its in-house regulations.
10. Compliance with and defence of Human Rights and Public Freedoms.
    

This Code does not consider all the possible conducts and/or situations that may arise within the Organisation, but it does include the principles and criteria that must govern the behaviour of the Members of the Organisation.‍

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Chapter III.- Social commitments of the Manusa Group towards its Stakeholders

 

The social commitment of the Manusa Group with each of its Stakeholders is reflected in the sections provided below. The Organisation will actively promote adhesion to, compliance with, and respect for this Code among its Stakeholders, along with the in-house policies and regulations implementing them.

The people representing the Organisation in relation to other companies or organisations,
and those in charge of assigned personnel will ensure compliance with the Code and will act according to it.‍

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Article 5.- Members of the Organisation

5.1 Employees

5.1.1. The employees of the Manusa group, as indicated in the definition of members of the organisation contained in this document, will receive humane treatment, always respecting their rights and primarily their privacy, equal opportunities within the Organisation, and diversity.
Under no circumstances will different treatment or discrimination due to age, sex, ideology,
race or religion be tolerated, nor will any demonstration with connotations of harassment or abuse of authority or that are intimidating, offensive, degrading, or threaten moral integrity.

In all the selection processes for new personnel or for the promotion of existing personnel, criteria of merit, aptitude, and capacity will be considered depending on the vacancy to be covered, without considering subjective or personal issues. Likewise, the ethical background and professional and business honourability of the candidate will be considered during selection processes. The Organisation also actively undertakes to encourage the personal and professional development of its employees, their learning and promotion, and their work-life balance.

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5.1.2. The Manusa Group is firmly committed to ensuring the occupational safety and health of its employees, complying at all times with the applicable regulations in force regarding the matter and, more particularly, regarding Occupational Risk Prevention, implementing the corresponding measures. Employees of the Manusa Group must also comply with the Occupational Risk Prevention measures that the Organisation provides at all times.
The Organisation also ensures a healthy working environment for its employees, promoting teamwork and a solid corporate identity.

The Manusa Group recognised and respects the right of association its employees and enables them to freely exercise this right, as well as their freedom of affiliation and their right to collective bargaining.

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5.2 Members of the Board of Directors and managers

5.2.1. The Manusa Group guarantees the truthfulness of all the information it provides for its partners and shareholders, and the meeting of common goals that benefit both parties by maximising the corporate value through efficient administration by the management resources, creating a favourable environment based on communication, mutual trust, transparency and loyalty.‍

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5.2.2. The Members of the Board of Directors and managers must be familiar with, respect and comply with this Code when performing their duties as a sign of the commitment and ethical culture of the Organisation, and they must be exemplary in their behaviour regarding this matter, both internally and for the market and the Stakeholders. The managers and Members of the Board of Directors will ensure that all employees and Stakeholders under their responsibility are informed of the values and internal rules of the Organisation, and will ensure training in line with the position they hold in relation to said values and rules and their implications.

The Manusa Group undertakes to ensure its strict compliance with current and future laws regarding good corporate governance and other recommendations issued by the public authorities on the matter.‍

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5.3 Relationships with Business partners

5.3.1. Relationships with Customers

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5.3.1.1. The Manusa Group at all times promotes the utmost quality, satisfaction, safety and excellence in the products and/or services provided to its customers as well as their assistance, in compliance with all applicable regulations currently in force. Respect, professional responsibility, transparency and honesty lead all our business relationships.‍

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5.3.1.2. The Organisation undertakes to offer customers:

1. all the information they need with the due transparency and without ambiguous, mistaken or imprecise expressions that may lead to confusion or error, complying with the applicable regulations in order to offer the precise, true advertising and promotion of the product and/or service without incurring in unfair competition or using false or misleading advertising instruments,
2. to avoid influencing family relationships and friendships, conflict of interests, all of which must be objective and independent. More specifically, the activity will remain objective and independent in the granting and establishing of economic and/or financial conditions and contracting in general. ‍

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5.3.2. Relationships with Suppliers and contracted companies

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5.3.2.1. The relationship with suppliers and contracted company must be based on the fact that they are business partners of the Organisation and, therefore, they must be treated as equals and within the current legal framework. ‍

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5.3.2.2. The selecting, contracting, and assessment of suppliers and contracted companies will ensure transparency, equal treatment, and the application of objective and weighted criteria. Every effort must be made to avoid dealing with suppliers and contracted companies with business or personal interests, external activities or relationships that are directly or indirectly damaging to or potentially conflictive with the interests, values and principles of the Organisation, especially those contained in its Code of ethics and conduct and the internal regulations implementing it. ‍

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5.3.2.3. The Organisation prioritises the relationships with suppliers and contracted companies that include the following when performing their activity:

1. quality, sustainability and regulatory compliance criteria,
2. sufficient technical, organisational and risk-control capacity,
3. and the non-existence of relevant incidents that might affect their professional or business reputation. ‍

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5.3.2.4. The Organisation will actively promote adhesion to and compliance with this Code among its service providers in all applicable areas, and may establish a failure to do so an express cause for contract termination. The Organisation undertakes to treat its suppliers equally and transparently, and to treat any data that might affect the way in which the supplier competes in the market confidentially.‍

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5.3.2.5. Offering, giving, requesting or receiving any type of favour, benefit, charge or payment outside the scope of a contract or transaction is expressly forbidden, as this is a risk of bribery or corruption in business. ‍

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5.3.2.6. For the purposes of this Code, suppliers and contracted companies will be considered Members of the Organisation in all applicable areas. ‍

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5.3.3 Relationships with Agents, representatives, commission agents, distributors and similar business partners

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5.3.3.1. The business partners of the Manusa Group are essential for the development and growth of the Organisation and for ensuring other goals are met, which is why we are constantly striving to build and maintaining a solid, prosperous relationship with them for mutual benefits.

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5.3.3.2. The selecting, contracting, and assessment of Agents, representatives, commission agents, distributors and similar business partners will ensure transparency, equal treatment, and the application of objective and weighted criteria.

Every effort must be made to avoid dealing with collaborators with business or personal interests, external activities or relationships that are directly or indirectly damaging to or potentially conflictive with the interests, values and principles of the Organisation, especially those contained in its Code of ethics and conduct and the internal regulations implementing it. ‍

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5.3.3.3. In its relationships with agents, representatives, commission agents, distributors and similar business partners, the Organisation will ensure respect:

1. for the free market and fair competition, and respect for the rules regarding the Right to Competition and all anti-corruption regulations.
2. for ensuring the confidentiality of any data that might affect the way they compete in the market, and the business relationships established with their business partners. ‍

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5.3.3.4. The Organisation will actively promote adhesion to and compliance with this Code among its business partners, and may establish a failure to do so an express cause for contract termination. ‍

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5.3.3.5. For the purposes of this Code, agents, representatives, commission agents and similar business partners will be considered Members of the Organisation in all applicable areas.

Article 6.- Relationships with competitors

6.1. The Organisation undertakes to:

1. compete with the other market players, respecting the principles of free competition, avoiding any conduct that involves an abuse or restriction of competition, complying with anti-monopoly regulations and any that may apply in the future issued by the regulatory authorities of the market,
2. comply with any regulation applicable at local, national or international level in the area of the right to competition, and collaborate with the authorities regulating the market, and
3. base its business decisions on the principles of independence, self-development and sustainability, always seeking corporate decisions that respect and put into practice the values indicated in this Code.‍

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6.2. Among others, and notwithstanding any subsequent implementation by way of internal regulations, the following are not permitted:

1. agreements regarding prices or pricing elements,
2. increases in prices, or those relating to other terms and conditions of the business,
3. market allocations with competitors,
4. participation in unofficial meetings with competitors. Meetings must always be official, with clear, transparent and specific purposes, and always scheduled. In case of doubt, direct managers or the Criminal compliance body must always be consulted,
5. infringement of the intellectual and industrial property of third parties, undertaking not to use it without the authorisation or licence of its owners, or the unauthorised use of any illegally supplied information, or regarding which the Organisation has the duty to maintain its confidentiality, and
6. the distribution of misleading or unlawful advertising that could damage other competitors, consumers and users. The Organisation will ensure reliable promotion, distribution, and marketing, in abidance with the applicable law.

The Organisation shows zero tolerance for anti-competitive conduct and, therefore, direct managers or the Criminal compliance body must be consulted before starting or continuing with any conduct.‍

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Article 7.- Relationship with governments and authorities

7.1. The Manusa Group respects all current and future regulations in the countries in which it does business, guaranteeing its political neutrality and the good reputation of the Organisation at all times. ‍

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7.2. The Organisation will not be a party to any project that jeopardises the respect for the principles included in this Code. All relationships between the Manusa Group and the public bodies, authorities and administrations will take place in line with the principles of cooperation and transparency, preserving and recording the necessary evidence based on the applicable law at all times.‍

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7.3. Relationships with public, national and international institutions and organisations will be exclusively based on forms of communication that guarantee the utmost transparency. Institutional liaisons will take place through representatives who have been expressly appointed by the Organisation.‍

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7.4. The Manusa Group recognises the right of its employees to exercise their freedom of expression and, in general, to take part in public and political life, provided this does not interfere with the performing of their professional activity or infringe on the principles of this Code, and is conducted outside working hours.

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Chapter IV.- Mandatory rules

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Article 8.- Subscription and compliance

8.1. The Members of the Organisation, regardless of their contractual relationship with the Organisation, undertake to ensure full respect for the precepts, principles, and rules of conduct contained in the different sections of this Code, its policies, and in-house regulations that implement it, accepting each and every one of the commitments and the following stipulations:

1. to respect and comply with this Code, a mandatory rule for the Organisation,
   in order to generate an ethical and professional environment in which to conduct the activity.
2. to be familiar and comply with, and to execute the applicable regulations, policies, procedures and in-house controls in force at any given time according to their duties, responsibilities and jobs,
3. to respect the law, customs, and common uses of the countries in which they are working at all times. A lack of knowledge may not be used as a reason to justify failure to abide by the above,
4. adapting their professional activities to the principles of loyalty and good faith with regard to the Organisation, their direct managers, equals, colleagues, Stakeholders, and respecting third parties with which they have a relationship through work, under no circumstances taking orders that violate current law, the Code, or the internal regulations of the Organisation,
5. to consult any doubts their direct managers or the Criminal compliance body before making a decision, and
6. to provide truthful and necessary, full and specific information to their direct managers, especially on all aspects that have an impact on the progress of the activities within their relevant area, as well as to Stakeholders with regard to everything necessary to appropriately perform their duties for the Organisation, providing the necessary collaboration. ‍

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8.2. Members of the Organisation who become aware of an irregular situation regarding the contents of this Code must immediately inform their direct manager or the Criminal compliance body.‍

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Article 9.- Regarding the Environment and Public health

9.1. The Members of the Organisation actively and responsibly undertake to conserve the Environment and Public Health, and must meet all contractual and legal obligations required for and associated to their post in this area arising from the commitments of the Organisation regarding the Environment and Public Health, along with the internal regulations, policies, procedures, and controls in force in the Organisation at all times. ‍

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9.2. The Members of the Organisation will act with the utmost diligence when remedying any risk or contingency that might harm the Environment and/or Public Health, contributing towards sustainable development, and minimising or eliminating any negative impact that their activity might cause. ‍

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Article 10.- Regarding conflicts of interest

10.1. The Members of the Organisation undertake to avoid any situation that could involve a conflict of interest with the Manusa Group, abstaining from being part of that project or decision and informing their direct manager or the Criminal compliance body of such immediately. ‍

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10.2. The nature of the interests of the Members of the Organisation that could lead to direct or indirect conflict with the interests of the Manusa Group may be wide-ranging, highlighting patrimonial, business, or family relationships of the Members of the Organisation with suppliers, partners/shareholders, competitors, customers, public authorities or people related to them.‍

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10.3. The conflicts of interest will be communicated and managed by the Organisation, and may be expressly and justifiably authorised, adopting the necessary measures in this sense. ‍

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10.4. Any business decision will be made based on criteria of transparency, objectivity and impartiality, such as price, quality, service, and always in the best interests of the Organisation.‍

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10.5. The Members of the Organisation may under no circumstances:

1. use their position or any information to which they have had access when performing their job to obtain an advantage for themselves or for any person related to them,
2. hold any type of post, provide duties or representation in competing organisations or suppliers,
3. or in organisations in a situation of command or control in the organisations of the competition,
4. nor may they accept posts, duties, representation, designation or any appointment arising outside the Organisation that might affect their professional independence and dedication to the Organisation or that might involve a breach of this Code, without previously consulting as such.‍

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Article 11.- Regarding the confidentiality and privacy of information. Intellectual and Industrial Property

11.1. The Manusa Group believes information to be one of its main assets and essential for managing its business activities. Therefore, the Members of the Organisation will observe the utmost confidentiality and diligence in the safekeeping of all the information they obtain when performing their professional activity that is not public and is in relation to the Organisation,
its Stakeholders, or third parties.‍

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11.2. Any information deemed confidential, secret or privileged belonging to the Organisation, to the Stakeholders, or to third parties, to which Members of the Organisation have access,
will not be used, disclosed, transferred and/or revealed in any circumstances, either for their own benefit or that of others, without the express, prior authorisation of its owner and, in turn, of their direct manager or Criminal compliance body, regardless of whether there is a valid contractual relationship between the Organisation and its Members.

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11.3. Once the contractual relationship has ended, the Members of the Organisation must return the confidential information to which they have had access, regardless of the format in which it is stored, and the duty of confidentiality shall remain in force indefinitely. ‍

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11.4. Along these lines, the Members of the Organisation undertake to strictly comply with the Data Protection Law and other applicable regulations regarding privacy, as well as current regulations on Intellectual Property and Industrial Property, acting at all times in line with any legal requirements that may apply, and guaranteeing the preservation of the documents and data, their integrity and availability. ‍

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11.5. External intellectual and industrial property may not be used by the Members of the Organisation, or to benefit the Organisation, or for their own benefit or that of others, whether it is owned by the Organisation, its Stakeholders, or third parties, without the prior express authorisation of its owner, of their direct manager, or of the Criminal compliance body. ‍

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11.6. More specifically, the Members of the Organisation who, due to their jobs, have access to relevant information for the pricing of any type of security or instrument traded on any organised, official or recognised market must abstain from being directly or indirectly involved in any activity, contract or transaction regarding it. ‍

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Article 12.- Regarding the prevention of corruption, bribery, and influence peddling

12.1. The Members of the Organisation must avoid all types of conduct aimed at influencing,
for their own benefit or that of the Organisation or of a third party, the decisions made by authorities, agents, and public officials. ‍

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12.2. The Members of the Organisation may not offer, submit, request, receive and/or accept, either for their own benefit or that of the Organisation or of third parties, promises, gifts or money, undue advantages or compensation, in order to bribe authorities, agents or public officials, or that seeks to unduly favour another in the purchase or sale of goods, the contracting of services, or in business relationships, whether they are physical or legal persons of a public or private nature.
An exception to the above is anything that might be considered reasonable and in line with the uses and customs of the region in which it is operating.

These prohibitions include anyone with a close family or emotion tie to influential officials, agents or public or private authorities from whom something is sought in exchange.

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12.3. In all cases, when employees have doubts as to the fairness or acceptability of a gift, payment, offer, or invitation, they must ask their direct managers or the Criminal compliance body in writing.‍

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Article 13.- Regarding financial relationships with political parties, union organisations and associations

13.1. The Organisation does not make direct or indirect donations to political parties.
Any donation must be made in line with applicable regulations, and every effort made to ensure it does not harm the image of the Organisation, that it is transparent, and that the recipients can be easily determined. The Organisation will abstain from any type of forbidden activity in relation to the funding of political parties. ‍

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13.2. The Organisation provides no assistance to organisations or associations with which there might be a conflict of interest, but it may cooperate on specific projects if their mission is in line with its values, provided they have a clear purpose, the resources are recorded in writing, and the corresponding authorisation is given by the appropriate person within the Organisation. ‍

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Article 14.- Regarding aid and sponsorships

14.1. In its high degree of commitment towards society, the Manusa Group sometimes implements sponsorship, aid, and patronage projects. These contributions must always be made in line with the principles of integrity and transparency, and by people expressly authorised to do so by the Organisation. The Manusa Group undertakes to collaborate exclusively with institutions that have sufficient means to effectively manage the contribution made, and undertakes to duly record it in line with the General Chart of Accounts. Lastly, the Manusa Group undertakes to monitor and effectively control the contribution.

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14.2. In all cases, when choosing sponsorships, aid and patronages, the Organisation will be particularly careful with any possible personal or business conflict of interest, leaving proof in the accounts of the sponsorships and aid given along with the recipient, and traceability of the use of the beneficiaries’ funds.‍

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Article 15.- Regarding money laundering and the financing of terrorism

15.1. The Members of the Organisation actively undertake to ensure the prevention of any conduct that might be typified as or related to money laundering and the financing of terrorism. The following could be considered conduct that might be at risk of money laundering and the financing of terrorism:‍

1. Charges or payments for which it is impossible to determine their recipient or it is impossible to ascertain the source of the funds transferred.
2. Unusual cash charges or payments based on the nature of the transaction.
3. Charges or payments to/from physical or legal persons residing in tax havens,
   or with a current account in said tax havens.
4. Charges or payments made by cheques payable to the bearer (not nominative).
5. Charges or payments made in currencies different to those indicated in the contract or invoice.
6. Charges or payments made to/by third parties not mentioned in the contract.‍

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Article 16.- Regarding the Inland Revenue and Social Security

16.1. The Members of the Organisation may not behave in such a manner that might lead to fraud in the meeting of the legally required tax and social security obligations, or to unduly obtaining profits, aid, incentives, benefits and/or public subsidies on tax and social security issues arising from or committed through the business activity of the Organisation and in any region in which it may operate. ‍

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Article 17.- Regarding financial information

17.1. The Members of the Organisation will reliably ensure that the economic-financial information, especially the accountancy books, annual accounts and financial statements, are a true reflection of the economic and financial situation of the Organisation. To do so, they will closely abide by accounting regulations and principles, as well as the regulations and recommendations in force on the matter.‍

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17.2. Any unlawful payment made by Members of the Organisation using financial resources belonging to the Manusa Group is strictly forbidden. ‍

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17.3. Furthermore, all financial transactions involving resources belonging to the Manusa group must meet the following conditions:

1. the transaction must be related to the activity of the Manusa Group.
2. the amount paid must be reasonable and in line with financial and market criteria.
3. the transaction must be duly authorised by the appropriate people in the Organisation.
4. money must be sent via bank transfer or through a nominative instrument,
   except where expressly indicated otherwise and when it involves a small amount.
5. it must be duly recorded and accounting for in writing.
6. the lawful destination of the payments made must be guaranteed.

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The Members of the Organisation will abstain from the following conduct when performing
their jobs:

1. keeping accountancy books alongside the official accounts.
2. not recording a transaction or recording a non-existent transaction.
3. manipulating accounting entries or using false documents.
4. deliberately destroying accounting and tax documents before the minimum period established by law.‍

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Article 18.- Regarding the use of assets

18.1. The assets belonging to the Manusa Group, which might be moveable or non-moveable, tangible or intangible, material or immaterial, will be made available to the Members of the Organisation exclusively for use for professional purposes. ‍

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18.2. The tangible and intangible assets of the Manusa Group may only be used for the benefit of the Organisation and never for interests outside it. ‍

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18.3. Furthermore, goods and services will be acquired under conditions that guarantee transparency and objectivity and avoid a conflict of interests.‍

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Article 19.- Regarding related operations

19.1. The Members of the Organisation may under no circumstances acquire goods or rights of which the Organisation is the lawful owner, or conduct any legal business with them. ‍

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19.2. However, the Manusa Group may authorise such business or acquisitions, provided the current law on the matter is respected, along with transparency and the ordinary market conditions, and there is no privilege whatsoever.‍

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Article 20.- Regarding training

20.1. The Members of the Organisation undertake to actively take part in the training programmes provided by the Manusa Group in order to acquire new knowledge and improve the business activity. ‍

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20.2. The integrity of the professional background and the skills and duties assigned will be considered in the selection, promotion and access to the training given by the Organisation.

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Article 21.- Regarding Human rights and Public freedoms

21.1. The Members of the Organisation undertake to protect the Human Rights and Public Freedoms recognised in the Universal Declaration of Human Rights and in the main international agreements on the matter. Everything relating to the protection of the rights of children and minority groups or those at risk of exclusion or social discrimination are particularly protected by the Manusa Group.‍

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21.2. The Organisation will make sure it uses the official models to send invitation letters to suppliers, customers, or any others who are to enter Spain and, in the case of appointing foreign employees, the lawfulness of their situation will be checked. ‍

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21.3. The Members of the Organisation will also ensure that it is not involved in projects with institutions or organisations that do not respect Human Rights and Public Freedoms. ‍

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Article 22.- Regarding equality and protection against discrimination

22.1. The Members of the Organisation must ensure humane treatment in the exercising of its work relationships, respecting the rights legally recognised in the labour law applicable to the Organisation, especially in terms of privacy, equality and diversity. ‍

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22.2. It is strictly forbidden for Members of the Organisation to give different treatment or discriminate due to age, sex, ideology, race or religion be tolerated, nor will any demonstration with connotations of harassment or abuse of authority or that are intimidating, offensive, degrading, or threaten moral integrity and respect for people. ‍

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22.3. The Members of the Organisation are also forbidden from any conduct or activity that threatens the sexual freedom of people.‍

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Article 23.- Regarding the work-life balance

23.1. The Organisation will promote measures to ensure the work-life balance, ensuring this is respected.

23.2. Under no circumstances may this balance involve discriminatory conduct in detriment to the beneficiary, especially in terms of in-house promotion or access to training. ‍

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Article 24.- Regarding occupational health and safety

24.1. The Manusa Group provides for and promotes the adopting of all preventive measures to encourage and maintain a healthy working environment. ‍

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24.2. The Members of the Organisation must be familiar with applicable regulations regarding Occupational Risk Prevention associated to their job, and must comply with the training, prevention and safety measures that the Organisation provides at any given time. ‍

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Chapter V.- Supervision, assessment and disciplinary system

 

Article 25.- Supervision and assessment of compliance with the Code of ethics and conduct

25.1. In the event of any doubt or conflict, and before making a decision, any Member of the Organisation or Business Partner must consult with the direct manager or Criminal compliance body to solve it appropriately.‍

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25.2. Any breach of this Code or of the internal rules and controls implementing it by the Members of the Organisation may seriously affect the Organisation. Therefore, any breach may be detected and communicated through different means, but it must be noted that the Manusa Group provides the Members of the Organisation and its Business Partners with two means of communication so that anyone aware of an irregular or doubtful situation can inform the Organisation and must collaborate, where required. More specifically, the means that the Manusa Group provides for these purposes are:

• Reporting Channel. This is a way in which the Members of the Organisation and Business partners will communicate, in strict confidence and without the fear of reprisals, any actual risk of breach of this Code and other internal regulations implementing it, as well as any irregular, unlawful, or criminal conduct of which they are aware. Said communications may be made to the following addresses:

• e-mail: canal.denuncia@manusa.com
• Post: OCP – Avda.Via Augusta 85-87, 6 planta, 08174 Sant Cugat del Valles

All communications to either of the aforementioned addresses will be received and managed by the Criminal compliance body. Any communication will be processed and solved in line with the Internal Regulation or Procedure established.

• Enquiries Channel. This is a channel to pose any queries or enquiries to the Criminal compliance channel in relation to the interpreting and executing of this Code and the internal regulations implementing it. Said communications may be made to the following addresses:

• e-mail: canal.consulta@manusa.com
• Post: OCP – Avda.Via Augusta 85-87, 6 planta, 08174 Sant Cugat del Valles

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Article 26.- Disciplinary system for the Code of ethics and conduct

26.1. This Code, as well as the internal policies and regulations implementing it, must be followed by the Members of the Manusa Group Organisation regardless of the work they perform, the post they hold, and the contractual relationship they have with the Organisation.‍

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26.2. Under no circumstances may the Members of the Organisation ask other members of the Organisation or Stakeholders to violate the stipulations and principles set forth in this Code, nor will any conduct contrary to it based on an employee following an order from his or her direct manager be considered justified.‍

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26.3. Any breaches of this Code of ethics and conduct and the committing of any unlawful, irregular, or criminal conduct will be considered a very serious offence, a breach of contractual good faith, and will be processed and penalised in line with the disciplinary system applicable to the Organisation. All this notwithstanding any other type of legal or contractual responsibility that may arise from said conduct.