Código ético

Manusa Gest, S.L and its subsidiaries (hereinafter referred to interchangeably as “Grupo Manusa” or “the Organisation”), whose origins date back to 1966, is a leading company in the automatic doors and access control systems market. More than 50 years of experience enable us to offer a wide range of access solutions adapted to each specific need. The Organisation currently employs more than 250 qualified people, which allows us to manufacture over 18,000 doors per year. Grupo Manusa has its own offices in Spain, Portugal, Brazil, China and the United Arab Emirates, and is present in more than 80 countries worldwide. Our objective is to position ourselves and grow sustainably in the market, progressively and orderly achieving our targets, striving each day in that mission to respect and comply with the Organisation’s values and guidelines. For this reason, we have drafted this Code of Ethics and Conduct (hereinafter also referred to as the “Code”), which is aligned with and defines the objectives, principles and values that we observe and expect our Stakeholder Groups to observe when engaging in commercial relationships with our Organisation. Through this document, Grupo Manusa wishes to send a ZERO TOLERANCE message regarding any unlawful or criminal act, or any action contrary to the provisions of this Code, and therefore we will disseminate the content of this Code and actively promote its adherence by all those who intend to establish professional and/or commercial relationships with the Organisation.

This Code, together with the policies and internal regulations that implement it, shall be complied with by all Members of the Organisation in the performance of their duties and in their commercial and professional relationships, irrespective of the place where the activity is carried out, and always in accordance with the laws, customs and common practices of the countries in which they operate. Members of the Organisation are likewise obliged to comply with applicable law and other internal regulations of the Organisation.

3.1 alta dirección
Person or group of persons who direct and control an organisation at the highest level.

3.2 conflicto de interés
Situation in which external, financial, family, political or personal business interests could interfere with the judgement of members of the organisation when carrying out their duties in the organisation.

3.3 parte interesado o grupo de interés
Person or organisation that can affect, be affected by, 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, the following are considered interested parties or stakeholders: members of the organisation, business partners, the Regulator, administrative or judicial authorities, the Tax Authority and Social Security.

3.4 miembros de la organización
Members of the governing body, managers, employees, workers or temporary employees or those under a collaboration agreement, and volunteers of an organisation, and other persons under the hierarchical subordination of any of the foregoing.

3.5 organización
Person or group of persons that have their own functions, with responsibilities, authorities and relationships for achieving their objectives.

3.6 órgano de Compilance penal
Body of the organisation vested with autonomous powers of initiative and control that is entrusted with the responsibility to supervise the operation and observance of the criminal Compliance management system.

3.7 política de Compilance penal
The will of an organisation, as formally expressed by its top management or governing body, in relation to its criminal Compliance objectives.
NOTE 3 The criminal Compliance policy may be recorded in a single document or in several documents that integrate the criminal Compliance management system.

3.8 sistema de gestión de Compilance penal
Set of interrelated or interacting elements of an organisation to specify and measure the level of achievement of objectives in the field of criminal Compliance, as well as the policies, processes, procedures and associated controls to achieve those objectives.

3.9 socio de negocio
Any party, other than members of the organisation, with whom the organisation has, or intends to establish, some type of business relationship.
NOTE 4 Business partners include, but are not limited to, customers, joint ventures, joint venture partners, consortium partners, contractors, commission agents, consultants, subcontractors, suppliers, sellers, advisers, agents, distributors, representatives, intermediaries and investors.

3.10 tercero
Natural or legal person or body that is independent of the organisation.

This Code forms part of the Organisation's criminal Compliance policy and constitutes an instrument for expressing and developing its basic principles, which include, among others, the following: - A customer-oriented culture, offering real solutions, in compliance with consumer and user legislation. - Professionalism, Quality, Safety, Commitment and moral Integrity in our products and services, as well as in the conduct of our people. - Diligence, objectivity, transparency and honesty in all our decisions and in the performance of our activities. - Fair competition with other market participants, with the aim of safeguarding free competition. - Sustainable growth, with absolute respect for the Environment. - Responsibility and Social Commitment. - Observance and compliance with this Code and other internal regulations, professional ethics and good faith in commercial relations. Corporate Governance. - Zero tolerance for unlawful or criminal acts, fully respecting the law in the territories where the Organisation operates and its internal regulations. - Compliance with and defence of Human Rights and Public Freedoms. This Code does not cover every possible conduct and/or situation that may arise within the Organisation, but it sets out the principles and criteria that should govern the behaviour of the Organisation's Members.

Grupo Manusa's social commitment to each of its stakeholders is set out in the sections below. The Organisation will actively promote among its stakeholders adherence to, compliance with and respect for this Code, as well as for the internal policies and regulations that develop it. Persons who represent the Organisation to other companies or organisations, and those who by virtue of their position have personnel assigned to them, shall ensure compliance with the Code and act in accordance with it.

5.1 Workers 5.1.1. The workers of Grupo Manusa, defined as members of the organisation in this document, shall be treated with dignity, with their rights always respected and, above all, their privacy, equal opportunities within the Organisation and diversity. Under no circumstances will differential treatment or discrimination be tolerated on the grounds of age, sex, ideology, race or religion; nor any manifestation with connotations of harassment or abuse of authority or of an intimidating, offensive, degrading nature or that attacks moral integrity. In all processes for the selection of new personnel or promotion of existing staff, decisions shall be based on criteria of merit, aptitude and capability, according to the vacancy to be filled, without taking into account subjective or personal elements. Likewise, selection processes shall consider the candidate's ethical track record and professional and commercial reputation. The Organisation also actively undertakes to promote the personal and professional development of its employees, their learning and promotion, as well as the reconciliation of their work and family life. 5.1.2. Grupo Manusa is firmly committed to safeguarding the occupational safety and health of its workers, complying at all times with the applicable regulations in this area, especially in the field of Occupational Risk Prevention, and implementing the corresponding measures. Likewise, Grupo Manusa workers must comply with the Occupational Risk Prevention measures that the Organisation makes available to them at all times. In the same way, the Organisation guarantees its workers a healthy working environment that fosters teamwork and a strong corporate identity. Grupo Manusa recognises and respects the right of its workers to association and allows them to exercise it freely, as well as freedom of affiliation and the right to collective bargaining. 5.2 Members of the Governing Body and executives 5.2.1. Grupo Manusa guarantees the truthfulness of all information it makes available to its partners and/or shareholders and the achievement of common objectives that benefit both parties, through maximising corporate value by efficiently managing management resources, creating a favourable environment based on communication, mutual trust, transparency and loyalty. 5.2.2. Members of the Governing Body and executives must know, respect and comply with this Code in the performance of their functions, as a demonstration of the Organisation's ethical commitment and culture, and must set an example of conduct in this regard, both internally and for the market and Stakeholders. Executives and Members of the Governing Body shall ensure that all workers and Stakeholders under their responsibility are informed about the Organisation's internal values and rules, and shall provide appropriate training for the position they hold, in relation to those values and rules and their implications. For its part, Grupo Manusa undertakes to strictly comply with current and future laws on good corporate governance, as well as other recommendations issued by the public authorities on the matter. 5.3 Relations with Business Partners 5.3.1 Relations with Customers 5.3.1.1. Grupo Manusa promotes at all times the highest quality, satisfaction, safety and excellence in the products and/or services provided to its customers, as well as in customer service, complying with the applicable current regulations. Respect, professional responsibility, transparency and honesty lead all our commercial relationships. 5.3.1.2. The Organisation undertakes to offer customers: 1) all the information they need with due transparency and without ambiguous, equivocal or imprecise expressions that could cause confusion or induce error, always complying with the applicable regulations, with the aim of offering truthful and accurate product and/or service advertising and promotion, avoiding unfair competition practices or the use of false or misleading advertising instruments, 2) to avoid the influence of family and friendship relationships, conflicts of interest, all of which must be governed by objectivity and independence. In particular, actions shall be governed by objectivity and independence in the granting and setting of economic and/or financial conditions and in contracting in general. 5.3.2 Relations with Suppliers and contracted companies 5.3.2.1. The relationship with suppliers and contracted companies must be carried out on the basis that they are business partners of the Organisation; consequently, treatment must be on equal terms and within the framework of current legislation. 5.3.2.2. The selection, contracting and evaluation of suppliers and contracted companies shall be carried out guaranteeing transparency, equal treatment, and the application of objective and weighted criteria. Care must be taken to avoid dealing with suppliers and contracted companies that have commercial interests, personal ties, external activities or relationships that are contrary or potentially conflicting, directly or indirectly, with the interests, values and principles of the Organisation, in particular those contained in its Code of Ethics and Conduct and its internal implementing regulations. 5.3.2.3. The Organisation gives priority to relationships with suppliers and contracted companies that, in the course of their activity, incorporate: 1) quality, sustainability and regulatory compliance criteria, 2) sufficient technical, organisational and risk control capacity, 3) and the absence of significant incidents that could affect their professional or commercial reputation. 5.3.2.4. The Organisation will actively promote among the suppliers that provide services to it the adhesion to and compliance with this Code in all matters applicable to them, and non-compliance by such parties may be established as an express cause for contractual termination. For its part, the Organisation undertakes to treat its suppliers equally and transparently, and to treat confidentially those data that could affect the supplier's competitive position in the markets. 5.3.2.5. It is expressly prohibited to offer, give, solicit or receive any kind of favour, advantage, charge or payment outside the scope of a contract or transaction, such actions constituting a risk of bribery or corruption in business. 5.3.2.6. For the purposes of this Code, suppliers and contracted companies shall be considered Members of the Organisation in all matters applicable to them. 5.3.3 Relations with Agents, representatives, commission agents, distributors and assimilated business partners 5.3.3.1. At Grupo Manusa, business partners are an indispensable part of the Organisation's development and growth, as well as the achievement of other objectives, and therefore we continuously strive to build and maintain a solid and prosperous relationship with them, in order to achieve mutual benefit. 5.3.3.2. The selection, contracting and evaluation of Agents, representatives, commission agents, distributors and assimilated business partners shall be carried out guaranteeing transparency, equal treatment, and the application of objective and weighted criteria. Care must be taken to avoid dealing with collaborators who have commercial interests, personal ties, external activities or relationships that are contrary or potentially conflicting, directly or indirectly, with the interests, values and principles of the Organisation, in particular those contained in its Code of Ethics and Conduct and its internal implementing regulations. 5.3.3.3. In relations with its agents, representatives, commission agents, distributors and assimilated business partners the Organisation shall ensure respect for: 1) the free market and fair competition and respect for the rules relating to Competition Law, as well as all anti-corruption regulations, 2) ensuring the confidentiality of those data that may affect competitive behaviour in the market, as well as the commercial collaborations established with its business partners. 5.3.3.4. The Organisation will actively promote among its business partners the adhesion to and compliance with this Code of Ethics, and non-compliance by such parties may be established as an express cause for contractual termination. 5.3.3.5. For the purposes of this Code, agents, representatives, commission agents and assimilated business partners shall be considered Members of the Organisation in all matters applicable to them.

6.1. The Organisation undertakes to: 1) compete with other market participants in compliance with the principles of free competition, avoiding any conduct that constitutes an abuse of competition or a restriction thereof, complying with antitrust rules and with any other rules that may be applicable from time to time by the market regulatory authorities; 2) comply with any regulation applicable at local, national or international level in the area of competition law and to cooperate with the authorities that regulate the market; and 3) base its business decisions on the principles of independence, self-development and sustainability, always seeking organic decisions that respect and implement the values set out in this Code. 6.2. Among others, and without prejudice to further development through internal regulations, the following are not permitted: 1) agreements relating to prices or elements of prices; 2) price increases, or agreements relating to other terms and conditions of business; 3) allocation of markets with competitors; 4) participation in unofficial meetings with competitors; meetings must always be official, with clear, transparent and specific purposes, and must always be scheduled; in case of doubt, prior consultation with line management or the Criminal Compliance Body is required; 5) infringement of third parties' intellectual or industrial property, undertaking not to make use of such property without the authorisation or licence of the rights holders, nor to make use of any information supplied illegally, or information for which the Organisation has a duty of confidentiality; and 6) the dissemination of misleading or unlawful advertising that could harm other competitors, consumers or users. The Organisation will carry out reliable promotion, disclosure and marketing, which will always be linked to the applicable legislation and will always respect it. The Organisation applies a zero-tolerance policy with respect to anticompetitive conduct and, therefore, before initiating or continuing any conduct, in case of doubt, line management or the Criminal Compliance Body must be consulted.

7.1. Grupo Manusa respects all current and future regulations of the countries in which it operates, guaranteeing in all cases its political neutrality and the good reputation of the Organisation. 7.2. The Organisation will not be part of any project that compromises adherence to the principles set out in this Code. Any relationship between Grupo Manusa and public bodies, authorities and administrations will be conducted on the principles of cooperation and transparency, retaining and recording the necessary evidence in accordance with the applicable legislation at all times. 7.3. Relations with public institutions and bodies, both national and international, will be based exclusively on forms of communication that ensure maximum transparency. Contacts with institutional counterparts shall be made through representatives who have been expressly appointed by the Organisation. 7.4. Grupo Manusa recognises the right of employees to exercise their freedom of expression and, in general, to participate in public and political life, provided that this does not interfere with the performance of their professional duties or violate the principles of this Code, and is carried out outside working hours.

8.1. Members of the Organization, regardless of the contractual relationship that binds them to the Organization, undertake to give absolute respect to the precepts, principles and rules of conduct contained in the various sections of this Code, its policies and internal regulations that develop it, assuming each and every one of the commitments, as well as the following stipulations: 1. to respect and comply with this Code, a mandatory rule for the Organization, with the aim of generating an ethical and professional environment in which to carry out the activity. 2. to know, comply with and implement the regulations, policies, procedures and internal controls in force at all times and that apply to them according to their role, responsibility and place of work. 3. to respect the law, customs and common practices of the countries in which they operate at any time. Lack of knowledge may not be invoked as a reason to justify non‑compliance. 4. to adjust their professional conduct to the principles of loyalty and good faith towards the Organization, their hierarchical superiors, peers, collaborators and Stakeholders, as well as towards third parties with whom they interact in the exercise of their professional activity, and under no circumstances shall they follow orders that violate current legislation, the Code or the Organization’s internal regulations. 5. to consult any doubt with their hierarchical superiors or with the Criminal Compliance Body prior to making a decision. 6. to provide truthful, necessary, complete and timely information to their hierarchical superiors, in particular regarding all aspects that affect the conduct of activities within their area of competence, as well as to Stakeholders, in all matters necessary for the proper performance of their functions for the Organization, providing the collaboration required. 8.2. Members of the Organization who become aware of any irregular situation in relation to the content of this Code must immediately notify their hierarchical superior or the Criminal Compliance Body.

9.1. Members of the Organisation are actively and responsibly committed to the preservation of the Environment and Public Health, and must comply with the contractual and legal obligations applicable and associated with their position in that area, arising from the Organisation's commitments to the Environment and Public Health, as well as with the regulations, policies, procedures and internal controls that are in force at all times within the Organisation. 9.2. Members of the Organisation shall act with the utmost diligence in addressing any risk or contingency that could harm the Environment and/or Public Health, contributing to sustainable development, and minimising or eliminating any negative impact that their activity may cause.

10.1. Members of the Organisation undertake to avoid any situation that may give rise to a conflict of interest with Grupo Manusa, refraining from participating in that project or decision, and to report it immediately to their hierarchical superior or to the Criminal Compliance Body. 10.2. The nature of the personal interests of Members of the Organisation that may give rise, directly or indirectly, to a conflict with the interests of Grupo Manusa may be very varied, notably financial, business or family relationships of Members of the Organisation with suppliers, partners/shareholders, competitors, clients, public authorities or persons linked to them. 10.3. Conflicts of interest shall be reported and managed by the Organisation, and may be expressly and justifiably authorised, with the adoption of the necessary measures in this regard. 10.4. Any business decision shall be taken according to criteria of transparency, objectivity and impartiality, such as price, quality and service, and always in the best interest of the Organisation. 10.5. Members of the Organisation shall under no circumstances: 1) use their position or any information to which they have had access by reason of their role, in order to obtain an advantage, either for themselves or for any person linked to them, 2) hold any office, perform functions or act as a representative in competing organisations or in suppliers, 3) nor in organisations that hold a position of dominance or control over competing organisations, 4) accept positions, functions, representation, appointments or any nomination arising outside the Organisation that may affect their independence and professional dedication to the Organisation or that may constitute a breach of this Code, without prior consultation.

11.1. Grupo Manusa considers information to be one of its principal assets, essential for the management of business activities. For that reason, Members of the Organisation shall observe the utmost confidentiality and diligence in the custody of all information obtained as a consequence of the performance of their professional activity, which is not of a public nature, relating to the Organisation, its Stakeholders or third parties. 11.2. Information deemed confidential, secret or privileged, belonging to the Organisation, the Stakeholders or third parties, to which Members of the Organisation gain access, shall not be used, disseminated, transferred and/or disclosed under any circumstances, either for their own benefit or that of third parties, without the prior and express authorisation of the owner thereof, as well as of the hierarchical superior or the Criminal Compliance Body, irrespective of whether the contractual relationship that links the Members of the Organisation with such owner is still in force. 11.3. At the termination of the contractual relationship, Members of the Organisation are obliged to return the confidential information to which they had access, regardless of the storage format, and the duty of confidentiality shall subsist indefinitely. 11.4. In this regard, Members of the Organisation undertake to comply strictly with the Organic Law on Data Protection and other applicable privacy legislation, as well as current legislation on Intellectual Property and Industrial Property, always acting under the legal requirements applicable at any given time, thereby guaranteeing the preservation of documentation and data, and their integrity and availability. 11.5. Intellectual and Industrial property owned by third parties may not be used by Members of the Organisation, whether for the benefit of the Organisation, for their own benefit or for that of third parties, whether such property is owned by the Organisation, its Stakeholders or third parties, without the prior and express authorisation of the owner thereof, of the hierarchical superior or of the Criminal Compliance Body. 11.6. Specifically, Members of the Organisation who, in the course of their professional duties, access any information relevant to the pricing of any class of securities or instruments traded on any organised, official or recognised market, must refrain from carrying out, directly or indirectly, any act, contract or transaction involving them.

12.1. Members of the Organisation must avoid any conduct intended to influence, for their own benefit or that of the Organisation or a third party, decisions taken by authorities, agents and public officials.
12.2. Members of the Organisation may not offer, give, solicit, receive and/or accept, whether for their own benefit or that of the Organisation or a third party, promises, gifts or money, undue advantages or compensation, with the aim of bribing authorities, agents or public officials, or with the aim of unduly favouring another in the purchase or sale of goods, the contracting of services or in commercial relations, whether natural or legal persons, of a public or private nature. All of the foregoing is excepted where it may be considered reasonable or in accordance with the usages and customs of the territory in which they are operating.
These prohibitions extend to all those persons closely linked, familiarly or affectively, to influential officials, agents or public or private authorities from whom something is intended to be obtained in return.
12.3. In any case, when employees have doubts about the reasonableness or acceptability of a gift, compensation, offer or invitation, they must consult in writing with their hierarchical superiors or with the Criminal Compliance Body.

13.1. The Organisation does not make donations, direct or indirect, to political parties. Any donation must be made in compliance with applicable law, must ensure that it does not damage the Organisation's image, that it is transparent, and that the recipients can be easily identified. The Organisation will refrain from carrying out any activity prohibited in relation to the financing of political parties. 13.2. The Organisation does not provide aid to organisations or associations with which a conflict of interest may exist, but may cooperate on specific projects if their mission is aligned with the Organisation's values, provided they have a clear purpose, that resources are documented, and that the relevant authorisation is issued by the appropriate person within the Organisation.

14.1. Grupo Manusa, in line with its strong commitment to society, may carry out sponsorship, donation and patronage projects. Such contributions must always be made in accordance with the principles of integrity and transparency and by persons expressly authorised by the Organisation. Grupo Manusa undertakes to collaborate exclusively with those institutions that have sufficient means to manage the contribution effectively and to record it properly in accordance with the General Accounting Plan. Finally, Grupo Manusa guarantees the monitoring of the contribution and its effective control. 14.2. In any case, when selecting sponsorships, donations and patronage, the Organisation will take particular care to avoid any possible conflict of interest, whether personal or business, always leaving accounting evidence of the sponsorships and donations, as well as of the destination and traceability of the beneficiaries' use of the funds.

15.1. Members of the Organisation actively commit to preventing any conduct that may be classified or related to money laundering and terrorist financing. The following may be considered behaviours that could give rise to a risk of money laundering and terrorist financing: 1. Receipts or payments in which it is not possible to determine who the recipient is or it is not possible to ascertain the origin of the transferred funds. 2. Unusual cash receipts or payments in relation to the nature of the transaction. 3. Receipts or payments to/from natural or legal persons resident in tax havens or holding a bank account in such jurisdictions. 4. Receipts or payments made by bearer cheques (non‑nominative). 5. Receipts or payments effected in currencies different from those stipulated in the contract or invoice. 6. Receipts or payments made to/for third parties not mentioned in the contract.

16.1. Members of the Organisation shall not engage in conduct aimed at committing fraud in the fulfilment of legally required tax, fiscal and social security obligations, nor in the improper obtaining of benefits, grants, incentives, allowances and/or public subsidies in tax, fiscal and social security matters, arising from or committed on the occasion of the Organisation's business activity and in any territory in which it may operate.

17.1. The Members of the Organisation shall ensure, with due certainty, that the economic and financial information, in particular the accounting books, annual accounts and financial statements, faithfully reflect the economic and financial reality of the Organisation. To that end, applicable accounting standards and principles, as well as the regulations and recommendations in force on the subject, shall be strictly complied with. 17.2. Any illicit payment made by Members of the Organisation using Grupo Manusa's funds is strictly prohibited. 17.3. In addition, it shall be required that, for every economic transaction involving Grupo Manusa's funds, the following conditions are met: - that the transaction is related to Grupo Manusa's activity; - that the amount disbursed is appropriate and reasonable according to economic and market criteria; - that the transaction is duly authorised by the persons within the Organisation entitled to do so; - that the outflow of funds is effected by bank transfer or by a nominative instrument, unless, expressly due to being of a small amount, it is decided otherwise; - that it is properly documented and recorded in the accounts; - that the lawful purpose of the payments made is guaranteed. Members of the Organisation shall refrain from engaging in the following conduct in the performance of their professional activity: - keeping parallel accounting records to the official accounts; - failing to record a transaction or, conversely, recording a non-existent transaction; - manipulation of accounting entries or the use of falsified documents; - deliberate destruction of accounting and tax documentation before the minimum period established by law.

18.1. The assets owned by Grupo Manusa, which may be movable or immovable property, tangible or intangible, corporeal or incorporeal, shall be made available to the Members of the Organisation exclusively for their use for professional purposes. 18.2. Both tangible and intangible assets of Grupo Manusa may only be used for the benefit of the Organisation and never for interests unrelated to it. 18.3. Likewise, the acquisition of goods and services shall always be carried out under conditions that ensure transparency and objectivity and prevent conflicts of interest.

19.1. Members of the Organisation shall not in any way acquire goods or rights of which the Organisation is the lawful owner, nor enter into any legal transaction with them. 19.2. Notwithstanding the foregoing, Grupo Manusa may authorise such transactions or acquisitions provided that the applicable law in the matter is complied with, transparency and ordinary market conditions are observed, and no privilege exists.

20.1. Members of the Organization undertake to actively participate in the training programmes made available to them by Grupo Manusa in order to acquire new knowledge and to improve business activity. 20.2. When selecting, promoting and granting access to training delivered by the Organization, consideration shall be given to integrity in the professional record and to the competencies and duties assigned.

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 in this regard. Of particular protection for Grupo Manusa are all matters relating to the protection of the rights of children and of minority groups or those at risk of social exclusion or discrimination. 21.2. The Organisation will ensure the use of the official templates to issue letters of invitation for suppliers, clients or any third party who must have access to Spain, and, in the case of hiring foreign workers, the legality of their status will be verified. 21.3. Likewise, the Members of the Organisation warrant that under no circumstances will they undertake projects with institutions or organisations that do not respect Human Rights and Public Freedoms.

22.1. Members of the Organisation must be treated with dignity in the exercise of their employment relationships, always respecting the rights legally recognised under the labour legislation applicable to the Organisation, particularly in the areas of privacy, equality and diversity. 22.2. It is strictly prohibited for Members of the Organisation to make distinctions in treatment or to discriminate on the grounds of age, sex, ideology, race or religion; nor to engage in any behaviour with connotations of harassment or abuse of authority that is intimidating, offensive, degrading or that undermines the moral integrity and respect owed to individuals. 22.3. Members of the Organisation are also prohibited from any conduct or act that infringes upon individuals' sexual freedom.

23.1. The Organisation will promote measures that enable the reconciliation of work and family life, ensuring they are respected. 23.2. Under no circumstances may such reconciliation give rise to discriminatory conduct to the detriment of the beneficiary, particularly with regard to internal promotion and access to training.

24.1. Manusa Group implements and promotes the adoption of all preventive measures to foster and maintain a safe working environment. 24.2. Members of the Organisation must be familiar with the occupational health and safety regulations applicable to their position, and comply with the training, prevention and safety measures that the Organisation makes available to them at all times.

25.1. As an expression of its commitment to ethical values and good practices in matters of compliance, integrity and transparency, and of its intention to promote a culture of information and communication as a mechanism to prevent and detect irregularities at an early stage and to proceed immediately with their effective handling, Grupo Manusa makes available to members of the Organisation and to all persons referred to in article 3 of Law 2/2023, of 20 February, a Whistleblowing Channel to report: - Any breach or risk of breach of the Code of Ethics, as well as of the internal or external regulations that implement it, and of those related to the Corporate Crime Prevention Models adopted by the commercial companies in which Grupo Manusa holds a stake. - Acts or omissions that, within the personal and material scope of application of Law 2/2023, of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption, may constitute infringements of Union law or serious or very serious criminal or administrative offences under national law (art. 2 of Law 2/2023, of 20 February). 25.2. This Whistleblowing Channel is managed by the Person Responsible for the Internal Reporting System, who integrates all of Grupo Manusa’s internal reporting channels into a single mailbox. This also includes communications relating to sexual and workplace harassment. The Whistleblowing Channel is not, in any case, to be used as a complaints or enquiries channel. 25.3. The Whistleblowing Channel guarantees the confidentiality and secrecy of the information transmitted, the identity and personal data protection of the reporting person, and of third parties mentioned in the communication, as well as of the person affected by the report, during all stages of the processing and follow-up of the communication, and throughout any internal investigation or proceedings carried out on the basis of the reported facts. It also guarantees protection against retaliation occurring internally in the reporting person’s work or professional environment. 25.4. Specifically, the means that Grupo Manusa makes available for these purposes are: - Written. Via the online platform: https://manusa.ulisesgrc.net/#/channels/manusa/ES_ES; - By postal mail addressed to the Person Responsible for the Internal Reporting System at Avda. Via Augusta, 85-87, 6th floor, 08174, Sant Cugat del Vallès. - Verbal: by telephone with the Person Responsible for the Internal Reporting System at 93 591 5700, or via an in-person meeting, which will be held within 7 days from the request for a meeting. 25.5. Grupo Manusa makes the Whistleblowing Channel Policy and Procedure available on its website.

26.1. This Code, together with any internal policies and regulations implementing it, is mandatory for Members of the Grupo Manusa Organisation regardless of the activity they carry out, the position they hold, or the contractual relationship that binds them to the Organisation. 26.2. Members of the Organisation may under no circumstances request that other members of the Organisation or stakeholders contravene the provisions and principles set out in this Code, nor shall conduct contrary to this Code be considered justified on the grounds that an employee was following the orders of a hierarchical superior. 26.3. Any breaches that may arise of this Code of Ethics and Conduct, as well as the commission of any unlawful, irregular or criminal conduct, shall be regarded as a very serious breach, for violation of contractual good faith, and shall be processed and sanctioned in accordance with the disciplinary sanctions regime applicable to the Organisation. All of the foregoing is without prejudice to any other legal or contractual liabilities that may arise from such conduct.