Elanta

Code of ethics

Última actualización: Enero 2024
Code of ethics

1. Purpose, scope and objectives

The Code of Ethics contains a catalogue of principles and rules of conduct that must govern the actions of all professionals and third parties with whom elanta deals with.

SUBJECTS OF THE CODE

— The members of the board.

— Manager.

— Employees.

— Interested third parties: those with whom elanta has a relationship (e.g. suppliers, subcontractors, partners, investors, customers or public administrations).

GOALS

— Express the commitment of elanta with compliance with applicable legislation, good corporate governance and the principles of corporate social responsibility.

— To inform the subjects of the Code of the ethical principles and criteria of conduct pursued by elanta.

— Inform those subject to the Code of the consequences that may arise from engaging in conduct contrary to its provisions.

— Ensure the effectiveness of control standards and procedures that minimise the risk of illegal behaviour by those subject to the Code.

— Inform those subject to the Code that elanta has made two communication channels available to them (complaints channel and harassment channel) so that they can get in contact with the greatest possible confidentiality and with appropriate protection against reprisals.

2. Ethical principles

The ethical principles developed in this Code form the basis for the activities of elanta.

PRINCIPLE OF LEGALITY

elanta undertakes to carry out its business activities in accordance with the provisions of the legislation in force at any given time..

PRINCIPLE OF DISTINCTIVE ETHICAL BEHAVIOUR

elanta undertakes to conduct its business activities in an ethically irreproachable manner, with honesty, integrity, loyalty, efficiency and respect towards its employees, customers and suppliers and undertakes to demand the same behaviour from all those subject to the Code.

ETHICAL PRINCIPLE OF SUSTAINABILITY

elanta assumes the obligation to act in a socially responsible manner and to ensure that a balance between economic growth, environmental protection and social justice is maintained.

In addition, elanta also requires that those subject to the Code maintain behaviour in accordance with these criteria.

3. Behavioural criteria

PROFESSIONAL AND HUMAN DEVELOPMENT

elanta is committed to respecting rights and freedoms, promoting a working environment that facilitates the professional and human development of its employees and is compatible with a balance of private and family life.

PREVENTING HARASSMENT AND DISCRIMINATION

elanta promotes diversity and relationships based on respect, fairness and reciprocal collaboration and does not allow or tolerate discriminatory actions of any kind or for any reason.

elanta has mandatory protocols for those subject to the Code to prevent any discriminatory or harassing behaviour. These protocols are as follow:

— Protocol to prevent and combat harassment in the workplace.

— Protocol to prevent and combat sexual and/or gender-based harassment.

— Protocol to prevent and address harassment based on sexual orientation, gender identity and/or gender expression.

GOOD USE OF RESOURCES

Those subject to the Code must make proper and efficient use of the resources that elanta makes available to them for the performance of their professional activity. These resources must not be used for private purposes.

All material is the property of elanta and must be returned elanta  when its return is necessary, when it is no longer necessary for the development of professional activity and in any case when the employment or professional relationship ends.

SAFETY AND HEALTH

elanta will provide the Third Parties concerned with a safe working environment, complying at all times with the regulations in force on occupational health and safety.

Those subject to the Code will at all times respect the preventive measures in force regarding health and safety at work, using the resources established by elanta and ensuring that team members carry out their activities safely.

PREVENTING CORRUPTION

elanta is committed to complying with the regulations on corruption prevention and money laundering prevention.

Those subject to the Code shall remain alert to cases where there may be indications of a lack of integrity on the part of persons or entities with which elanta maintains relations.

Gifts, invitations, meals and travel:

Gifts or invitations of a value of more than 300 euros must be authorised by the CEO of elanta, after informing the Compliance Officer.

Gifts or invitations for meals and trips of a purely professional nature (business meals or trips, business merchandising, etc.) of a reasonable value shall be exempt from the above point.

RESPECT FOR THE IMAGEN AND THE COMPANY INTERESTS

elanta considers its image and corporate reputation as fundamental assets to maintain the trust of interested third parties.

Therefore, those subject to the Code must exercise the utmost care to protect the image and reputation of elanta for all actions carried out within the framework of an employment relationship.

Therefore, those subject to the Code are responsible for ensuring that their actions and decisions are oriented towards the best interests of elanta, and that they are not motivated by personal or third-party considerations or interests.

All situations of conflict of interest, both potential and real, must be brought to the attention of the company’s Compliance Officer as soon as they are perceived, and prior to the execution of any action that could be affected by them.

RELATIONSHIP WITH INTERESTED THIRD PARTIES

elanta interacts with various third-parties interested in the development of its activities and the provision of services.

In this sense, employees, managers and members of the Board of Directors of elanta, will act with integrity in their professional relationships with third parties:

— Promoting ethical and honest conduct with them.

— Providing the highest quality services to their customers, complying with the commitments made.

— Responding in a timely manner to complaints received.

— Selecting suppliers on the basis of fair, equitable and impartial criteria, as stipulated in the Responsible Supplier Policy.

— Demonstrate an attitude of transparency, respect and collaboration that promotes trust in business relationships.

INFORMATION PROCESSING AND DATA PROTECTION

elanta considers the confidentiality and integrity of information to be the cornerstone of the company. Persons subject to the Code must maintain the confidentiality of all matters known to them as a result of their professional activities and use them only for the intended purpose.

Those subject to the Code must truthfully and appropriately convey all the information they are required to communicate both internally and externally.

elanta professionals shall ensure that the privacy and integrity of personal data is protected.

Those subject to the Code must comply with the provisions in force on personal data protection and information security, as well as with internal regulations stipulated by elanta on these matters.

Security must also take into account the factors of physical security in order to prevent accidents or to act in critical security incidents such as theft and credit card fraud.

4. Compliance officer and disciplinary policy

COMPLIANCE OFFICER

elanta has appointed a Compliance Officer who is responsible, among other things, for compliance with this Code.

elanta reserves the right to carry out controls within the framework of the applicable legislation in order to verify the application of the by those subject to it and to prevent activities that could affect compliance with the provisions of this Code and the applicable legislation.

DISCIPLINARY POLICY

As the provisions of this Code are mandatory for those subject to the Code, it is expressly stated that failure to comply with them may result in the imposition of the corresponding sanctions according to the disciplinary policy in force and, where appropriate, the termination of the professional relationship between elanta and the offender, and the demand for liability from the offender.

5. Communication channels

elanta provides those subject to the Code with two communication channels to report unlawful behaviour with the greatest possible guarantee of confidentiality and adequate protection against retaliation.

COMPLAINT CHANNEL

Email:

codigoetico@elanta.com

Ordinary mail:

Paseo de la Castellana, 259D.

Edificio Torre Emperador, planta 44.

28046, Madrid. España.

CHANNEL AGAINST HARASSMENT

Additionally, elanta has protocols in place to prevent and address workplace harassment, sexual and/or gender-based harassment, and harassment based on sexual orientation, gender identity and/or gender expression, and is committed to investigating all complaints received relating to these infractions. .

Email: prevencionacoso@elanta.com

6. Acceptance and compliance

All elanta employees and managers must sign the contents of this Code and expressly accept the rules of conduct set forth herein.

No one, regardless of level or position, is authorised to request a person subject to the Code to contravene its provision.

No employee or manager may justify improper conduct on the grounds of a superior order or ignorance of this Code.