Code of Ethics

0. Introduction

In this Code of Ethics, the Básico Group intends to reflect the ethical criteria by which we have been governed until now. In this Code of Ethics we have tried to establish certain minimum standards of behaviour. Each of the actions and decisions we make every day must always be aimed at "doing the right thing" in order to continue strengthening the good reputation that characterises us. This reputation stems from our values, which have guided us to this day.

Being part of the Básico Group implies the commitment to know, respect, maintain and grow these values.


1. Code of Ethics

1.1. Definition and purpose

The Code of Ethics, code of conduct or code of good practices (hereinafter the "Code") contains a compilation of ethical standards and behavioural guidelines that should guide the daily performance of each of the employees, defined as any person remunerated by Básico, including middle management and executives, whose obligation, by virtue of their position, is to be a model in terms of compliance with the Code; this code is equally extensible to personnel collaborating with the Básico Group.

The purpose of this Code is to establish the principles and values that should govern the actions of the Básico Group and all its employees in order to ensure ethical and responsible professional behaviour in the professional performance of its activity, while reflecting the commitment of the Básico Group with the principles of business ethics and transparency.

El The Code of Ethics is binding and contains provisions aimed at making it effective, such as reporting channels and the assigning of responsibilities. This relationship includes obligations, and therefore, any violation of the Code of Ethics and the policies that develop it will result in a disciplinary sanction.

The Code is based on our values (see section 2.2), and, consequently

  1. It strengthens employees' sense of belonging to the Básico Group.
  2. It provides unity and coherence to the self-regulation system of the Básico Group.
  3. It signals to third parties the corporate culture of the Básico Group.
  4. It improves the reputation of the Básico Group.

It should be added, and always in compliance with the law, that certain matters covered by this Code shall be supplemented by the more detailed rules specified in the various sectoral Codes (1)The Code of Ethics will also be complemented with policies of the Básico Group that, based on the provisions of the Code, regulate specific sectors or a particular activity within the Group in greater detail. 

The Code takes into account the principle of criminal liability of legal entities and serves as a basis for avoiding irregular and improper behaviour that may result in criminal liability of the companies that are part of the Básico Group.

1.2. Development, drafting and contents

A transparent code of ethics has been drawn up so that all those affected are aware of how this may affect them and have sufficient information about it.

The Code of Ethics will contain those subjects that are of most concern to the Básico Group, and in turn, the Básico Group's policies should be in charge of developing these subjects and also allow the code to be balanced.

The Code of Ethics is subject to limits, such as respect for fundamental rights, the need for it to be exercised in a proportionate manner, and, above all, the limits imposed by the labour regulation.

1.3. Scope of application

This Code of Ethics shall apply to the entire company that is part of the Básico Group, binding all its personnel regardless of the position they hold or their duties. Thus, it will bind employees, officers, directors and even third parties such as suppliers, contractors or business partners of the Básico Group.

External consultants, self-employed workers and temporary employees shall also be linked when rendering services to the Básico Group.

The Code also binds the employer with the employee since the statements made in the Code create legitimate expectations of behaviour that must become part of the employer's obligations to act in good faith.

The Básico Group will promote and encourage among its suppliers and collaborating companies the adoption of behavioural guidelines consistent with those defined in this Code of Ethics, and if necessary, may request suppliers formalise their commitment to comply with the Code or the guidelines establishes therein.

1.4. Knowledge, acceptance and compliance

The Code of Ethics is mandatory for all employees of the Básico Group and for those third parties that have voluntarily committed to comply with it.

The Code of Ethics shall be made known to all members of the Básico Group, who shall be obliged to attend the training sessions scheduled by the Básico Group for this purpose.

The Básico Group management will participate in training programs, sharing workshops with employees or participating in these workshops as a way of demonstrating the importance of regulatory compliance. The Básico Group will also make every effort to disseminate the values and principles of the Básico Group and enforce compliance with the standards of conduct contained in the Code. They will be a role model in their behaviour and level of compliance with the Code.

The Code must be expressly accepted by each of the addressees, who must expressly undertake to comply with it, so that the principles and values that comprise it govern the conduct of its addressees.

Each recipient within the Básico Group will confirm that he or she has had access to this Code, that he or she accepts it and understands what it entails.  The document will be uploaded to the Factorial platform for reading and express acceptance by means of electronic signature and a record will be kept of the agreements received by the employees.

No member of the Básico Group, regardless of their level or position, is authorised to ask an employee to contravene the provisions of this Code of Ethics, and no one may justify their conduct on the grounds of an order from a superior or unfamiliarity with this Code.

The Code of Ethics is part of the management power of the employer, so its content is effectively part of the obligations to be fulfilled by the employee as part of his or her work. Thus, in addition to the obligations expressly contained in the employment contract, it also includes those arising from the general principle of good faith.


2. General ethical principles and values

2.1. Principles

The ethical principles of the organisation are the foundation on which the Básico Group's activities are based. These principles are as follows:

  • Integrity as acting ethically, honestly and in good faith.
  • Respect for legality, human rights and ethical values.
  • Respect for people, avoiding any kind of harassment, intimidation, abuse or disrespect, and not tolerating any kind of physical or verbal abuse. The Básico Group will take appropriate and timely action in the event of any such situation, including disciplinary action. Any report of harassment or discrimination will be promptly and thoroughly investigated, while maintaining the utmost confidentiality. Any retaliation against persons who report situations of this type or who collaborate in their investigation will be inadmissible, giving rise to the adoption of disciplinary measures in case of occurrence.
  • Responsibility and prudence in the actions of the recipients of this Code, which will be translated into the scrupulous monitoring of the established internal procedures, especially in matters of occupational risk prevention, in compliance with the legal or internal regulations related to the activity carried out and in the training and education for the best development of the activity.
  • Transparency and impartiality in making any type of decision.
  • Equal opportunities, professional development and non-discrimination in access to and promotion in the workplace. Discrimination on the basis of sex, race, religion, marital status, sexual orientation or any other differentiating factor shall not be admissible.
  • Enhancing innovation and efficiency of the processes in order to better serve our customers and drive our growth.
  • Lead by example: Managers will be a role model in their behaviour and level of compliance with the Code. 

 
2
.2 Values

These are the values of the Básico Group: they are our hallmark, our behavioural pattern and the way we do our work::

  • Team
  • Enthusiasm
  • Personal Growth
  • Determination
  • Adaptation to change
  • Proactivity
  • Constant effort
  • Commitment
  • Generosity
  • Good humour

 

3. Compliance

3.1. Compliance with applicable legislation and internal regulations

The companies bound by the Code undertake to comply with the laws in force, Básico Group's internal procedures and the principles contained in this Code.

They also undertake to report any non-compliance they detect in their surroundings.

Employees must avoid any behaviour that could damage the Básico Group's reputation or adversely affect its interests. All employees must be aware of the laws that affect their job, requesting, if necessary, the necessary information from their superior.

No employee shall knowingly collaborate with third parties in the violation of any law, or participate in any action that compromises the rule of law.

The Básico Group shall ensure that all members of the Básico Group are aware of the external and internal regulations relevant to their duties.

In the event of any situation of non-compliance with the law, employees must inform the Básico Group through the reporting channels detailed in this Code of Ethics.

3.2. Compliance with standards, covenants and agreements

The Básico Group undertakes to comply with and integrate as internal regulations the provisions of national or international agreements and covenants that, due to the activity carried out by the Básico Group, may bind it.

All employees of the Básico Group must comply with the laws in force in the countries where they carry out their activities, in accordance with their spirit and purpose, and behave ethically in all their actions.

3.3. Internal relations: employees

The Básico Group's employees are its greatest asset and will be considered as such.

The Básico Group will promote the personal and professional development of its members and foster a positive work environment. Respect, courtesy and assistance shall govern relations between employees who shall remain vigilant against any form of violence, abuse or discrimination of any kind in the workplace. Failure to comply may result in disciplinary action as per established protocols.

Básico Group employees must treat each other with respect in a pleasant, healthy and safe work environment, with the obligation to treat their colleagues, subordinates and superiors fairly and respectfully, in compliance with their corporate social and ethical responsibility. 

The Básico Group shall ensure compliance with labour regulations regarding employment. 

Employees must collaborate in the fulfilment of these objectives, preventing, detecting and reporting any irregularities they may detect. 

Special attention will be paid to the labour integration of people with disabilities. 

3.4. External relations: customers and market

The Básico Group and each of its members are committed to comply with competition regulations, avoiding any practice that limits or restricts competition.

The Básico Group and each of its members shall ensure that truthful information is provided in the Básico Group's promotional activities and shall not be permitted to provide false information to customers which could mislead them.

Any type of misleading advertising is also prohibited, always acting fairly. Information from competitors that could reach the Básico Group in breach of confidentiality will be rejected.

Secure means of payment, data protection and fraud prevention will be ensured.

Any employee who enters any type of information into the Básico Group's computer systems must ensure the information is credible and accurate.

3.5. External relations: suppliers

Ethics and respect will govern relations with suppliers, who will be selected based on objective and transparent criteria.

In this case, compliance with the Code shall be part of the supply or service contracts and non-compliance may lead to the possibility of withdrawing from the contract. For this purpose, the Code may be supplied as an annex to the contract.

Internal procurement procedures shall be strictly followed, decisions shall be justified and the related documentation shall be kept for possible internal or external auditing.

Extreme care shall be taken to protect suppliers' confidential information.

Suppliers must commit to respect human and labour rights in their own companies.

It is expressly forbidden to accept, offer, or solicit, either directly or indirectly, gifts, favours or any type of compensation that may influence decision-making in relation to the supply chain. The receipt or offer of gifts of "low value" not exceeding a value of €30 may be accepted. Any doubts as to what is included in this concept shall be referred to the body in charge of compliance with this Code. In any case, cash gifts shall be prohibited.

Every employee who participates in supplier and external collaborator selection processes has the obligation to act objectively and impartially, applying transparent criteria and complying with internal regulations on the matter.

3.6. Relations with institutions, authorities, officials

International standards for the prevention of corruption and bribery shall govern the relations of members of the Básico Group with authorities, institutions and public officials.

Any decision made in this area must comply with the applicable internal and external rules and shall be documented for possible internal or external control.

Under no circumstances shall the Básico Group offer, request or accept gifts, favours or compensation from authorities, institutions or officials. Gifts or hospitality of little economic value, proportionate and reasonable in accordance with local practice, shall be exempt from this rule. In any case, cash gifts shall be prohibited.

Payments are prohibited to expedite any type of processing.

A meticulous and expressly vigilant control will be maintained in the fulfilment of the obligations derived from the granting of any type of subsidy or aid.

 

4. Conflict of interest and policy

4.1. Description

Employees shall avoid situations that involve a conflict of their personal interests with those of the Básico Group.

Employees, regardless of their rank or function, may not use their position in the Básico Group to obtain personal advantages or business opportunities or provide services to competing companies.

If there is any doubt as to whether an activity to be carried out may involve a conflict of interest, the body in charge of compliance with this Code shall be consulted.

The Básico Group believes that the relationship with its employees should be based on loyalty born of common interests. The participation of employees in other financial or business activities will be respected as long as they are legal and do not conflict with their responsibilities as employees of this Group.

All employees must disclose outside activities, financial interests or relationships that may present a potential conflict of interest or the appearance of a conflict. They must also comply with the law and the Group's policies.

4.2. Policy on gifts, commissions or remuneration from third parties

Giving or receiving gifts and entertainment may affect objectivity and judgement, and may also violate anti-corruption and anti-bribery regulations and laws in extreme cases, so every member of the Básico Group will be very diligent in this matter.

The solicitation and acceptance of any type of payment, gifts or commissions in connection with the professional activity and coming from clients, intermediaries, suppliers or third parties is prohibited. Excluded from this prohibition are invitations, promotional items, attentions, occasions or courtesies that are not in cash and that are within reasonable limits in the context of normal courtesy practices. In the event of any doubt in this regard, the body in charge of compliance with this Code shall be consulted.

4.3. Use of Group goods and services

Efficiency will inspire the use of goods and services of the companies that are part of the Básico Group.

The Básico Group provides employees with access to e-mail, Internet, Intranet, telephones and other forms of communication technologies to make their performance more productive and effective. It is everyone's responsibility to maintain the confidentiality, integrity and availability of our technology and communications infrastructure.

All rooms provided by the Básico Group for its employees shall be maintained in a good state of repair, operation, safety, cleanliness and effective use. It is the employee's responsibility to use the resources of the Básico Group in a responsible, efficient and appropriate manner when carrying out their professional duties, taking the necessary precautions to avoid the deterioration or destruction of the different elements that make up the office, among others, the equipment, computer or otherwise, electrical installations, plumbing, wiring, materials, consumables, as well as any other element that is used.

Technological infrastructures and communication tools shall be used only for professional purposes, except in exceptional situations. Reasonable personal use is allowed, as long as it is moderate and occasional and being aware that it does not enjoy privacy because it is a tool provided for the performance of the job and, therefore, for professional purposes.

The downloading or installation of illegal or unlicensed software, applications or content is not permitted. In any case, intellectual property laws shall be complied with.

No user is authorised to download software onto his or her computer or to redirect a business email account owned by the Básico Group. In the event that a specific program is needed to carry out your work or to redirect an e-mail account owned by the Básico Group, you must inform the IT manager, who will be responsible for carrying out the appropriate actions.

All information relating to user names, passwords and authentication devices for computer systems must be controlled and kept secret, and any possible security risks or incidents in this regard must be reported.

The IT resources and services of the Básico Group, as well as the information contained therein, may be subject to review, supervision, inspection or audit by the Group's General Management, as well as by the Management of each Department and/or Area, in all cases respecting the regulations in force on the matter.

All of the above will apply both for duties carried out on company premises as well as in the teleworking modality. Both the material and the information are considered assets of the Básico Group and the same security measures will be applied regardless of the modality of work.

4.4. Data Protection Policy

The companies that are part of the Básico Group shall strictly comply with data protection legislation, depending on the processing of personal data that they carry out and that which is determined in accordance with binding rules or agreements adopted within the Group. Likewise, the Básico Group shall promote that the basic principles relating to the processing of personal data are taken into account: (1) in the design and implementation of all procedures involving the processing of personal data; (2) in the products and services offered by them; (3) in all contracts and obligations entered into with individuals; and (4) in the implementation of all systems and platforms that allow access by the Group's professionals or third parties to personal data and the collection or processing of such data.

Any document, file or information generated by employees on any support: paper, analogue or digital (CD, DVD…), is the property of the Básico Group in application of the current regulations on Data Protection. A Corporate Information Use Manual is available to all employees of the Básico Group on the Intranet. This document addresses the policy to be followed on the appropriate use of e-mail, Internet and computer resources in general provided by the Básico Group to its employees for the performance of their work duties and which are required to be known and used by all employees.

Confidentiality and diligence in the use of data shall preside over the actions of the recipients of this Code. This principle must be respected even when the relationship with the Básico Group has ended.

Any information to which the employee has access will be considered confidential information, except for information expressly identified by the Básico Group as information of a public nature. To this end, it is urged not to leave on printers, photocopiers, tables, meeting rooms or any other premises, documentation or printed information of customers, especially identifying documents, pay slips, work life documents, etc. Repeat violations of this will be considered a minor or serious offence depending on the number and importance of the documentation, giving rise to sanctions by the company.

In view of the foregoing, the employee is obliged to use all the information to which he/she has access, only within the framework of the labour relationship and for its best performance, and to preserve the secrets of the Básico Group, customers and/or third parties, keeping them in strict confidentiality. The information may not be used for private benefit, nor communicated to third parties, this information will be considered confidential and must be used exclusively for the purpose for which it was obtained. Confidential information includes trade secrets, pricing regulations, strategic or business operating plans, new products, contracts, agreements, lists of employees, customers, suppliers, software or computer programs, HR information, personnel plans, internal communications, subscription lists and, in general, data affected by data protection regulations.

Respect for the personal and family privacy of persons to whose data we have access is required.

 

 

 

All personnel must know and respect the internal procedures of the Básico Group on storage, custody and access to data and act diligently to ensure the secrecy of the information they receive in order to prevent its loss or access to third parties. In this order, the documentation, when not being worked with, shall not be kept in sight on the table or at the workstations, trying to keep it stowed in the cabinets and/or drawers to preserve the confidentiality of the documents and information.

Employees who violate this policy will be subject to disciplinary action..

Any indication, doubt, question or incident related to the confidentiality of the data or possible security breaches in data protection will be communicated as soon as possible to the e-mail address proteccion.datos@basico.es with a copy sent to the corresponding Delegate/Director or Department Manager.

4.5. Industrial and intellectual property rights

The Básico Group recognises its commitment to the protection of copyrights, patents and trademarks, both its own and those of others, and requires the same commitment from its suppliers.

We are all committed to report any irregularities in this area.

Special attention shall be paid to the inclusion of copyright notices on materials, information, products, services and any of Básico Group's documents intended for public distribution.

In their relationship with third parties, employees shall strictly follow the rules and procedures in this area to avoid infringing the rights of third parties, respecting the valid intellectual property rights of others.

4.6. Prevention of money laundering and terrorist financing policy

The Básico Group identifies with the international community's growing concern about the problem of money laundering and the financing of terrorism and will strictly comply with legislation on the prevention of money laundering and the financing of terrorism

The Básico Group believes that the best way to fulfil its commitment is to establish effective internal rules and procedures aimed at:

  • Carry out the activity in accordance with current regulations and international best practices.
  • Strictly comply with the laws against ML/FT, as well as the recommendations issued in this area by the Financial Action Task Force (FATF) and national and international authorities.
  • Implement policies and procedures to prevent our organisation from being used for money laundering or to channel funds or resources to individuals or entities linked to terrorist groups or organisations.
  • Ensure that all employees are aware of and comply with the internal policies and procedures established for the prevention of money laundering and the financing of terrorism, especially those related with the identification and knowledge of the client and operations classified as "Suspicious Transactions".
  • Collaborate closely with the competent authorities in the fight against money laundering and the financing of terrorism.

The Básico Group will train employees in the prevention of money laundering and financing of terrorism, keeping an internal record of the training provided. Every employee agrees to complete any training activity that is scheduled to improve his or her ability to comply with the responsibilities that the measures and procedures defined and established in the Manual for the Prevention of Money Laundering and Financing of Terrorism.

All employees shall remain alert and report any fact or situation that may constitute a violation of the regulations using the Whistleblower Channel described in section 5 of this Code.

Employees who violate this policy will be subject to disciplinary action..

4.7. Occupational health and safety and occupational risk prevention policy

The Básico Group will ensure a safe working environment, in compliance with current occupational health and safety regulations. The Group will train employees in occupational risk prevention, keeping an internal record of the training provided. All employees agree to complete any training activities that are scheduled to improve their ability to perform their duties safely and to make responsible use of the Básico Group's materials and equipment. It is important that each employee understands the hazards and safety practices that must be observed for any job.

The Básico Group will require that the contractors and suppliers with which it collaborates comply with the regulations on occupational risk prevention.

All employees shall remain alert at the workplace and report any safety concerns they have to their manager, the HR department or the body in charge of compliance with this Code.

It is also strictly forbidden to conceal work accidents or very serious incidents, falsify safety records or order personnel to not follow safety regulations.

Employees who violate this policy will be subject to disciplinary action.

 

The HR department will ensure that the Básico Group's records contain their updated emergency contact information.

4.8. Recording of transaction and information

A proper record of financial and accounting records shall be maintained. It is essential to ensure that financial and accounting records are complete, accurate and not misleading, as this information is the basis for both internal and external reporting to governmental, regulatory and other entities.

All books, records and accounts, including time sheets, sales records, invoices, receipts and expense reports, must be complete, accurate and reliable.

The falsification of any document or any type of distortion of data related to a particular transaction is not allowed. Transactions must be recorded in a timely manner and supported by the corresponding documentation. No expenditure shall be incurred or paid from the Básico Group's funds unless authorised by the appropriate person.

4.9. Retaining of documents

The Básico Group complies with legal and regulatory requirements regarding the retention and disposal of documents and records. All records and information shall be treated in a manner to ensure that:

The archiving, storage and retrieval of recorded information is always done in an organised manner. Record keeping, in whatever format, meets legal, fiscal, regulatory and operational requirements. Records and their backups are protected.

The necessary documentation is available in the event of legal proceedings.

The disposal of documents that are no longer of value, both in printed and electronic format, is carried out in an appropriate and timely manner.

The Básico Group has a records retention plan that identifies by title each of the categories of records it maintains. The retention plans indicate, for each category of record, the identification of the records to be kept, when the retention period begins and for how long they should be kept.

4.10. Environmental commitment

The Básico Group is committed to ensure respect for the environment, to minimise the environmental impact in all its activities and to disseminate among its employees the culture of respect for the environment as a principle of conduct in its actions.

In order to fulfil and implement these commitments and achieve the established objectives, the Básico Group has established the following fundamental principles:

  1. To ensure the protection of the environment, working in a respectful way, preventing pollution and minimising the environmental impact produced as a consequence of the activity carried out in the different territories and work centres.
  2. To implement this policy through communication, training, awareness and sensitisation of all employees, promoting responsible environmental behaviour.
  3. To ensure compliance with current environmental legislation and regulations applicable at the European, national, regional and local levels.
  4. To integrate the environmental management system into the global and strategic management of the Básico Group.
  5. To use the best available techniques and adopt the appropriate protocols for contamination control and prevention.
  6. To acquire a commitment to continuous improvement in the separation of waste, consumption of natural resources, environmental pollution and in all activities carried out as part of the daily activity. Promote activities related to recycling, something that the Básico Group already has and that employees should be made aware of and comply with

The Básico Group is committed to providing its employees with a safe and healthy work environment and we are all committed to conducting our operations in a manner that ensures compliance with environmental regulations, avoiding any negative impact on the environment.

The employees of the Básico Group must be familiar with and assume this policy and act at all times in accordance with the criteria of respect and sustainability, and adopt habits and behaviours of good environmental practices and contribute positively to the achievement of the established objectives. Employees must also strive to minimise the environmental impact of their activities and the use of the facilities, equipment and available work resources.

These principles shall be conveyed in relations with external contractors or collaborating companies.

4.11. Reconciliation policy

The Básico Group is committed to employees to promote the improvement of their quality of life and that of their families, therefore, measures aimed at reconciling the requirements of work with the needs of their personal and family life will be promoted following the established protocols.

4.12. Compliance with the Code, control and disciplinary system

The Ethics Committee shall be the body in charge of ensuring compliance with and dissemination of this Code among all Básico Group personnel. This body shall be responsible for receiving communications regarding complaints of non-compliance with this Code or queries on its interpretation.

This body may act on its own initiative or at the request of any addressee of the Code and its decisions shall be binding for Básico Group companies and their employees.

Failure to comply with the Code may entail labour consequences, which may include the imposing of labour sanctions, including dismissal, in addition to any administrative or criminal consequences that may be implied.

 

5. Complaints channel

5.1. Whistle-blower channel

Any member of the Básico Group, as well as suppliers and even third parties with an employment relationship with the corporation, must report, in good faith and without fear of retaliation, any irregularity, non-compliance or unethical conduct by an employee or officer of the Group as it relates to this Code of Ethics or any other irregularity detected in the Básico Group.

Any member of the Básico Group shall report any irregularity detected or non-compliance affecting this Code of Ethics or any other irregularity detected in the Group. 

Complaints or queries, if any, may be sent by e-mail to the following address: buzondenuncias@basico.es

Information received as complaints and irregularities, as well as the identity of the complainant, shall always be treated with the utmost confidentiality. However, when a report is to be made anonymously, the Básico Group recommends that the person filing the report does not use a corporate or personal email and creates a free email account with any of the most common email providers (Gmail, Outlook, etc.). It is recommended to use alphanumeric characters in the e-mail address (e.g. a1b2c3d4@gmail.com) to guarantee the intended anonymity.

The Básico Group is committed to protecting the rights of individuals who report concerns in good faith, and will not retaliate against any recipient of this Code who reports what he or she believes to be a violation of the Code; seeks advice about a particular practice, action or decision; or cooperates with an investigation of a possible violation. 

Retaliation against an employee who in good faith reports an act through this channel constitutes a violation of this Code, and the retaliatory acts themselves may be subject to reporting. 

Reports made in bad faith, knowing them to be false or for the purpose of harming a colleague or superior shall be subject to disciplinary sanction, without prejudice to possible criminal liability for the possible commission of a crime of slander or libel, or civil liability for injury to the right to honour.

*Consumers, former employees who did not file a complaint at the time and, in general, all those who are affected in any way by the Group's activities must resort to alternative complaint channels.

5.2. Advertising, updating and availability of the Code

The Code comes into force on the day of its publication and will be sent to all members of the Básico Group, and will remain in force until its annulment is approved. It will be updated every time the Ethics Committee detects the need or is made aware of the need to update the Code as a result of an alert reported by an employee.