Code of Ethics and Conduct - Grupo Antolin...The Code of Ethics and Conduct 2 an action model CORPORATE CULTURE CODE OF ETHICS AND CONDUCT OUR COMMITMENT THE TEAM WHISTLEBLOWING CHANNEL

Code of Ethics and Conduct

GRUPO ANTOLIN

This Code replaces all the previous Codes of Ethics and Conduct and completes the policies and

guidelines that govern our Group and our companies. This text remains the only Code valid

throughout the entire scope of Grupo Antolin and if necessary, due to special and extraordinary

circumstances of a local nature, it will be supplemented by a special appendix adapted to the

corresponding country.

Compliance with the code is a condition for forming part of the team of professionals at Grupo

Antolin. However, this conduct requirement does not imply an employment contract or a job offer.

Grupo Antolin prefers to work and interact with people, groups of people, institutions or any other

form of organization that share the principles and commitments contained in this code;

encouraging the adoption of international standards of conduct and action in line with that

described in this document.

This code does not specifically address each and every one of the situations that could arise in the

running of our business. It also does not provide a list of responses to be able to deal with all the

business situations that could occur on a daily basis, nor can it replace common sense when

deciding how to act or behave.

Grupo Antolin reserves the right to review, amend and update the content of this code or its

sections at any time, in order to make it more flexible to the changing expectations and needs of

the company, its stakeholders, the current legislation and the commitments acquired in any or all

of the matters contemplated in it.

The content of the Ethical Code may not be unilaterally amended as this is the exclusive

responsibility of the Ethics Committee which, where necessary, will establish the corresponding

local appendix in order to complement it and meet local demands in each specific matter.

Any amendment, whole or part, of its content will be communicated promptly to all its recipients,

again obtaining their adherence to the procedures and systems designed for such purpose.

The original language of this document is Spanish (Castilian). The text is available in the languages

of the countries in which Grupo Antolin operates, in order to facilitate its understanding and

acceptance by the entire workforce. In the event of any conflict, the reference document is the

Spanish version which will prevail over all others.

This publication is the property of Grupo Antolin. For any queries concerning the Code or its

content, please contact:

Grupo Antolin - Code of Ethics and Conduct

Ctra. Madrid-Irún, km. 244.8

09007 BURGOS – SPAIN

Tel.: +34 947 47 77 00

Fax: +34 947 48 49 19

Email: [email protected] / [email protected]

www.grupoantolin.com

The text of the Code of Ethics and Conduct has been approved by the Board of Directors ofGrupo Antolin within the framework of its meeting held on October 8, 2015.

“One team,

one model of conduct.”

Being a leading sustainable company has always been the goal for Grupo

Antolin, a family company created more than 50 years ago as a result of the

dream of two entrepreneurs which, thanks to people like you, has become one of

the main suppliers of technology for car interiors.

The inclusion of sustainability in the company's business strategy has allowed us to

embrace aspects of an ethical, social and environmental nature, beyond the

vision of the traditional company. Innovation, financial strength and

internationalization are combined with ethics, good governance and

transparency as the pillars of our progress, reinforced with the publication of our

first Code of Ethics and Conduct in 2010.

The development of the Group, its adaptation to the new growth scenarios and

the new demands from customers and expectations of the other stakeholders,

have prompted the development in 2015 of a new version of this document, as a

mandatory corporate standard, with responsibilities shared by all of us who form a

part of this great team.

Given the impossibility of covering each and every one of the situations that could

arise when running our business, the Code is conceived as a roadmap that

summarizes our firm commitment to complying with human rights, dialog with

stakeholders, respect for strict compliance with legislation, the creation of a safe

working environment, the fight against corruption and, finally, environmental and

socially responsible commitment wherever Grupo Antolin is present. Additionally,

we must strive to ensure that these commitments are also shared by any person or

organization who maintains a business relationship with the Group.

I would like to take this opportunity to encourage you to make any suggestions or

comments, through the channels provided, regarding anything contained in this

Code or its application, which allows us to be a unique role model, a true

reflection of the company's values since its creation.

L e t t e r f r o m t h e P R E S I D E N T

Ernesto AntolínPresident

Contents

1. I Our Corporate Culture…………………5

2. I The Code of Ethics and Conduct…...6

3. I The Code: Our commitment……….....8

4. I The Code: The Team……………....….10

5. I The Transparency Channel……........14

6. I The Ethics Committee……………...…17

7. I Action Protocol………...................….18

8. I Acceptance………………………..….19

About the Code……………….………...….21

Glossary of terms

Internal legal references

Summary Annex

GRUPO ANTOLIN

Code of Ethics and Conduct4

M

A

I

Ns t r e a m i n g

Customer focus LeadershipCreativityI Positive response to change

I Innovative thinking

I Drive to be the best

I Communication

I Trust

I Development of people

I Sense of belonging

I Professionalism

I Pro-activity

M I S S I O N

V I S I O N

Ethics

Good

Governance

Transparency

V A L U E S

To be the leader in solutions for interior

car trims due to our technological

capacity, providing competitive interior

car trim solutions.

To be the preferred market option due

to our capacity for innovation and

competitiveness, offering an attractive

return to our shareholders and being a

sustainable leading company for our

employees and society.

competencies

O u r CORPORATE CULTURE shared values for sustainable development

CORPORATE

CULTURE

CODE OF ETHICS

AND CONDUCTOUR COMMITMENT THE TEAM

WHISTLEBLOWING

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COMMITTEE

ACTION

PROTOCOL

GRUPO ANTOLIN


5

1

T h e C o d e o f E t h i c s a n d C o n d u c t

WHAT is it?

I The Grupo Antolin Code of Ethics and Conduct (together with the Grupo Antolin Policies and

Guidelines, hereinafter the Code) is a living document approved by the Ethics Committee

and endorsed by the Board of Directors. Its main aim is to ensure ethical and responsible

behavior when running our business.

WHY do we have it?

I With this document, Grupo Antolin makes public its commitment to the guidelines in the

Universal Declaration of Human Rights, the Guiding Principles on Business and Human Rights,

Children's Rights and Business Principles, as well as with the principles of the United Nations

Global Compact (of which it has been a founding partner in Spain since 2004) and the

guidelines and principles of the International Labor Organization (ILO) and the Organization

for Economic Co-operation and Development (OECD).

WHAT is it for?

I This text is a reflection of the values that must guide the conduct of the company and the

people who work for it. It must lead to honesty, ethics, professionalism and transparency in our

relations with the customers, shareholders, employees, suppliers and society in general.

WHO has written it?

I The Grupo Antolin Ethics Committee, consisting of internal and external professionals, experts

in matters of Corporate Responsibility and labor and legal issues, has been responsible for

producing the final text.

In producing it, the needs and expectations of our main stakeholders have been taken into

account, as well as the regulatory and market requirements applicable to our business.

TO WHOM does it apply?

I The Code applies to all employees connected to Grupo Antolin, regardless of the

employment contract that determines their relationship with the company, the position they

occupy in the organization and the country in which they work.

Grupo Antolin extends its commitment to all subsidiary companies in which it is the majority

shareholder or has management control, as well as to its supply chain.

WHEN does it apply?

I The Code of Ethics and Conduct enters into force on the very day that Grupo Antolin makes

its commitment public.

Those who violate the Code or the policies and procedures of Grupo Antolin will be subject to

disciplinary measures proportionate to the offense, and will be punished to the full extent

allowed by the current regulations. Disciplinary action will also be taken against anyone who

orders or approves infringements or is aware of them and does not immediately act to

remedy them.

2an action model

CORPORATE

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ACTION

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HOW is it applied?

I The Code is not a set of internal rules, nor does it replace any collective agreements or

national, European or international legislation. However, the company places great

importance on compliance with this Code, so all Grupo Antolin employees must be aware of

and respect the content and spirit of the document.

The Code must be read and interpreted jointly with Grupo Antolin's Policies, Guidelines and

Management Model. These Policies and Guidelines implement the commitments contained in

the Code and are available in the systems provided by the company through the Intranet

page and on its website.

In the event that the rules existing in a certain jurisdiction are more permissive than those

contained in this Code, the guidelines contained in the Code will prevail.

However, the current law, employment contracts and application of specific policies may

vary depending on the geographical location. See the different appendices to obtain

specific information about your country or region where applicable.

In the event of a conflict between local laws or employment contracts and a company

policy, these will take priority over the company policy. Furthermore, local policies and

practices must be adapted to reflect the Company's international policies.

Lastly, we must always call on our sense of responsibility and good judgement and in the

event of any doubt over the correct business conduct talk to our line managers, to the

Management or to the Ethics Committee, if deemed necessary.

WHERE can I find it?

I The Grupo Antolin Code of Ethics and Conduct is available to everyone working in any of the

companies that form part of the organization.

http://intranet.grupoantolin.com/sites/apps/EC

A printed version of the text is included in the procedure for welcoming new joiners, and a

copy of it can be requested at any time from the Human Resource department of each

company.

The official Spanish version and the English version are available to the general public on the

Grupo Antolin website. http://www.grupoantolin.com/en/people

T h e C o d e o f E t h i c s a n d C o n d u c t

2an action model

CORPORATE

CULTURE

CODE OF ETHICS

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CHANNEL

THE ETHICS

COMMITTEE

ACTION

PROTOCOL

GRUPO ANTOLIN


7

Compliance with the Code of Ethics and Conduct is a necessary condition for forming part

of the team of professionals at Grupo Antolin. This applies from the moment their

relationship starts with the company. The company will request that, after reading it, the

employee agrees to it through signing it or providing online acceptance.


http://www.grupoantolin.com/en/people

T H E C O D E : O u r

Human RightsGRUPO ANTOLIN supports Fundamental Human

Rights, avoiding and reporting any commercial,

economic and industrial activities that abuse

those rights.

GRUPO ANTOLIN acts with due diligence to

identify, prevent, mitigate and remedy any

possible negative impact and consequences

that its activities may have on human rights,

either directly or through its supply chain.

.

Through its international expansion Grupo Antolin is contributing to the global development

of the economy and society. It focusses on creating a sustainable future and working on the

impact of our activity on the environment, people and the social environment in which we

operate. We are committed to universal values that govern the behavior of the Group in all

its activities.

Labor StandardsGRUPO ANTOLIN defends the freedom of

association and the effective recognition of the

right to collective bargaining.

I It supports the elimination of all forms of forced

and compulsory labor.

I It respects the current legislation on working hours

in each country.

I It applies wage policies that are consistent with

the local legislation, including respecting

minimum wage conditions.

I It supports the abolition of child labor.

I It is in favor of the abolition of discriminatory

practices in employment and occupation.

I And it implements an occupational health and

safety management system.

The EnvironmentGRUPO ANTOLIN aspires to act in a way that

minimizes the harmful impact on the

environment of its industrial, commercial and

economic operations.

I It encourages initiatives that promote

greater environmental responsibility.

I And it promotes the development and

dissemination of environmentally-friendly

processes and technologies.

GRUPO ANTOLIN is committed to preventing,

detecting and eradicating any illegal actions

carried out within the scope of its

responsibilities, in its name or on its behalf and

for its benefit, by any of its legal

representatives, de facto or de jure

administrators and employees. For this

purpose, Grupo Antolin has a model which

organizes and manages criminal risks.

GRUPO ANTOLIN bases its relationships with

employees and ex-employees and their

family members, as well as with candidates,

customers, suppliers and other groups of

people directly or indirectly related to the

company, on the protection of confidential,

secret and personal data.

3 as a company, as a customer, as a supplier

Diversity and equalityGRUPO ANTOLIN establishes and develops policies

that include equality of treatment and

opportunities between men and women without

directly or indirectly discriminating on the basis of

sex, race, color, language, religion, opinion, origin

or any other personal and/or social condition or

circumstance.

GRUPO ANTOLIN considers diversity in all policies

regarding people management, treating it as a

cross-cutting factor that is used as the foundation

for all decisions taken in this area.

Safety in operationsGRUPO ANTOLIN provides mechanisms* that act across the entire organization and govern the

environment of control and the information and communication systems, effectively eliminating

the risks of errors with a material impact in the area of financial information.

* set of monitoring procedures and activities that include controls over the processes, systems, accounts and transactions, as well

as general controls for the Company, which include the control activities belonging to the Board and Senior Management which

affect everything.

GRUPO ANTOLIN

Code of Ethics and Conduct8

Data protection

GRUPO ANTOLIN recognizes, respects and complies with the international, regional and national

standards for behavior, including the legislation on tax and town planning issues in the countries

and territories where it operates; as well as their culture, customs and history.

Legislation

GRUPO ANTOLIN respects and promotes children's rights within its sphere of influence

Anti-corruptionGRUPO ANTOLIN is committed to supporting international

and local efforts to eliminate corruption and financial

crime, always complying with the anti-money laundering

laws that apply in any competent jurisdiction.

GRUPO ANTOLIN will not tolerate any type of corruption

(accepting or offering money to obtain improper

commercial gain), preparing organizational models to

assess and ensure compliance with the Ethical Code

where convenient or when the laws require this.

GRUPO ANTOLIN operates its business without breaching

the national or international laws relating to international

trade, economic embargoes and export controls that

apply in the countries in which it operates.

GRUPO ANTOLIN defines a fiscal strategy and a policy for

the control and management of risks, as well as the

approval of investments and operations with special risk,

based on compliance.

GRUPO ANTOLIN will facilitate the work of auditing or

supervisory individuals, organizations and inspection

bodies.

C O M M I T M E N T 3

Information transparencyGRUPO ANTOLIN ensures, through its

appropriate management and control

bodies, that it provides a true

representation through its information,

paying special attention to the financial

and economic information that reflects

the company's economic, financial and

equity position in accordance with the

generally accepted accounting

principles.

External relationsGRUPO ANTOLIN is committed to

competing in the market vigorously and

fairly, and will do so in full compliance

with all the anti-trust laws in the different

countries in which its commercial

practice is carried out.

GRUPO ANTOLIN is committed to

collaborating with people, groups of

people, entities, associations and public

and private organizations on research

and development into innovative

solutions for intelligent mobility that

contributes to the ongoing

development of society.

InnovationGRUPO ANTOLIN incorporates

innovation into our daily activity

throughout the entire value chain,

promoting technological progress and

positively contributing to the sustainable

future of the car.

Non-funding of the political,governmental and terrorism spheresGRUPO ANTOLIN strictly limits the use of the company's

resources with regards to supporting political causes or

campaigns. It will not pay any amount, or provide any

services, to political parties, holders of public office or

candidates for those offices, administrative authorities or

their employees, even if those contributions are

considered legal by virtue of the laws of the country

where those payments may be made.

However, GRUPO ANTOLIN respects the right of everyone

providing their services in any of the businesses forming

part of the company to be involved in political or religious

activities or in private non-profit initiatives, provided that

they are carried out outside working hours and do not

interfere with the professional development of their

activity and that they are not carried out using the name,

conditions or resources of the organization.

as people and as members of society

GRUPO ANTOLIN


9

GRUPO ANTOLIN may be involved in sponsorship, patronage or social welfare activities, on its own

behalf or in association with third parties, always seeking projects and alliances that offer value to

the company and/or its stakeholders and that apply the values and principles contained in this

Code.

Any form of economic action, aid or mediation that provides financial or any other type of support

to the activities of terrorist elements or groups is PROHIBITED.

SustainablecontributionGRUPO ANTOLIN contributes directly and

indirectly, as a result of its business,

products, technology and services, to

the global and local development of the

economy, society and the environment

of the communities where it operates.

GRUPO ANTOLIN is committed to protecting and maximizing the value of the investments made by

shareholders, promoting the reasonableness of the return on these.

Economic sustainability

10

The

company

HUMAN RIGHTS LEGISLATIONLABOR

STANDARDS

THE ENVIRONMENT DATA

PROTECTION

SAFETY

IN THE

OPERATIONS

DIVERSITY AND

EQUALITY

ECONOMIC

SUSTAINABILITY ANTI-CORRUPTION

NON-FUNDING

OF THE POLITICAL,

GOVERNMENTAL

AND TERRORISM

SPHERES

SUSTAINABLE

CONTRIBUTION

INFORMATIVE

TRANSPARENCY INNOVATION EXTERNAL

RELATIONS

an extension of the company's projectT H E C O D E : T h e t e a m

OUR ACTION MODEL

GRUPO ANTOLIN


Our staff INTEGRITY RESPECT CONFIDENTIALITY

INDEPENDENCE WELLBEING, HEALTH AND SAFETY

RESPONSIBLE MOBILITY KNOWLEDGE MANAGEMENT

RESPONSIBLE ENVIRONMENTAL BEHAVIOR RESPONSIBLE USE

OF RESOURCES QUALITY IN MANAGEMENT IMAGE AND

REPUTATION FREEDOM OF EXPRESSION PRIVACY OF

INFORMATION MAINSTREAMING SUSTAINABILITY

PROHIBITING CONTRIBUTIONS ON BEHALF OF THE GROUP

ABSENCE OF A CONFLICT OF INTERESTS CULTURE OF

COLLABORATION AND MANAGEMENT

4

WELLBEING, HEALTH AND SAFETYLooking after their health and ensuring a healthy

and safe environment by complying with and

enforcing the standards and measures on healthand safety, as well as responsibly using the Group's

resources and facilities, regardless of where the

work is carried out; never working under the

influence of alcohol, drugs or any other substance

that may impair the professional behavior and/or

safety of the person themselves and those who

surround them.

Nobody may use, posses, manufacture, distribute,

administer, transport, promote or sell legal, illegal or

illicit substances, or drugs paraphernalia, in the

performance of the Company's economic,

industrial and commercial activities or in the

Company's facilities.

INTEGRITYBeing honest and trustworthy, basing our

competitiveness on the quality of ourproducts and services, avoiding situations

that muddy professional and ethical

responsibilities, ensuring that any

payment, expense or gift by or on behalf

of the company is legal and for legitimate

purposes, in accordance with the

international and national laws against

corruption.

RESPECTTreating in a polite, respectful and fair

manner all professionals in Grupo Antolin,

as well as the customers, serviceproviders and other stakeholders,

applying the company's policies in

matters of diversity and tolerance, without

any discrimination on the basis of birth,

race, color, sex, language, religion,

opinion, origin, or any other personal

and/or social condition or circumstance.

Not carrying out or tolerating violent

behavior, threats, coercion or any form ofintimidation or harassment by the

managers and colleagues or the

customers, suppliers or any other agent

related to the company.

Striving to create a pleasant andrespectful working environment, using the

tools provided by the company available

to all employees in order to express our

degree of satisfaction with the policies

and processes of Grupo Antolin.

CONFIDENTIALITYMaintaining the necessary confidentiality, within the

professional ethical framework, in all those aspects

relating to the work where it is necessary to maintain

professional secrecy, both internally and externally,

with suppliers, customers, competitors and potential

investors; even after the termination of the labor

relationship.

INDEPENDENCEEnsuring our independence, not allowing ourselves

to be influenced by factors other than ourprofessional judgement, avoiding involving ourselves

in any situation or service where, due to a possible

conflict of interest or any other circumstances, our

impartiality or the objectivity of our judgement may

be affected.

RESPONSIBLE MOBILITYDriving safely, respectfully and responsibly, in

accordance with the applicable legislation, road

standards and signs and taking the necessary

precautions for our own safety and the safety of

the passengers in our professional and/or work

related journeys.

OUR STAFF

11GRUPO ANTOLIN


an extension of the company's projectT H E C O D E : T h e t e a m4

PRIVACY OF INFORMATIONEnsuring the accuracy and integrity of all the information andcommunication disseminated internally and externally with due

prior authorization from the company.

Respecting the private life of people and refraining from sharing

information relating to their professional and/or personal life

obtained during the development of their work or professional

activity, either informally or by chance.

KNOWLEDGE

MANAGEMENTPreserving the knowledge ofthe company, facilitating its

dissemination to other

employees in the Group and

making it available through

the knowledge management

systems enabled in the

company for such purpose.

RESPONSIBLE ENVIRONMENTAL BEHAVIORContributing to the continuous improvement of ourenvironmental behavior, integrating the environmental policy of

Grupo Antolin into our daily conduct and activities within the

company.

RESPONSIBLE USE OF

RESOURCESUsing the technical and

material resources made

available by the companywith due diligence, in order to

prevent damage arising from

their misuse, being

responsible for both their

custody and suitable storage,

as well as for ensuring that

they are used in accordance

with the current internal laws

and regulations.

QUALITY IN MANAGEMENTApplying the processes defined by the Organization forachieving objectives in the running of our business and

reasonably ensuring compliance with the standards

applicable to the company, the effectiveness and efficiency

of the operations, the reliability of the information and the

safeguarding of the company's assets, staff and information.

Undertaking to achieve the best possible quality as an

individual, as a team and as a corporation, always seeking

continuous improvement.

IMAGE AND REPUTATIONRepresenting Grupo Antolin in a responsible manner whilecarrying out our professional activity, always and everywhere,,

being aware that any action, omission or decision on our part

directly or indirectly affects the reputation of the company.

Contributing to the prestige of the Group, avoiding criticizing it,

starting or supporting any boycott, negative campaign orcommunication or any other action that harms the company,

regardless of its nature or the means used, including the mass

media and social networks.

FREEDOM OF EXPRESSIONFeeling the right to express ourconcerns and points of view

through the consultation

channels established to ensure

the freedom of expression.

Reporting any situation that

violates the fundamental

principles and rights of the staffand/or the environment in the

companies to which this code

applies.

MAINSTREAMING SUSTAINABILITYIntegrating social, environmental and economic issues into the actions and decisions adopted,

taking into account the interests of all parties involved at all times.

12GRUPO ANTOLIN



ABSENCE OF A CONFLICT OF INTERESTChecking the available information, including financial, on its potential business partners andsuppliers before establishing business relations with third parties, in order to establish their

respectability and the legitimacy of their activities.

Not providing services to competing companies or those in the same sector or undertaking or

carrying out business or commercial activities similar to those carried out by Grupo Antolin, which

interfere with their obligations and interests towards the Group, cause it harm or imply preferentialtreatment as a result of the existing relationship that goes beyond the professional area.

Not forming part of the Board of Directors of other companies or investing directly or indirectly in

the capital of a customer, supplier or other public or private entity of any kind that has relationswith the Group, either in the parent company or its subsidiaries; nor taking advantage of their

belonging to the Group in order to benefit from personal purchases made on the same

beneficial terms agreed for Grupo Antolin, unless the contract between these individuals and

Grupo Antolin expressly authorizes this and/or it respecting the company's procedures in this

regard.

PROHIBITING CONTRIBUTIONS ON

BEHALF OF THE GROUPNot offering or accepting any contributions,

payments or any other valuable item on behalfof Grupo Antolin in relation to political

candidates, government officials, customers,

suppliers or any other person or organization,

with the intention of influencing them or

obtaining an unfair advantage for the

company or on its behalf for its own benefit.

Always precisely documenting, in the systemsand records provided by the company, any

payment, expense or contribution made on

the behalf of, by and/or for Grupo Antolin,

including expenses and any gift or reward,

following the procedures defined by the

organization in this regard.

CULTURE OF COLLABORATION AND

MANAGEMENT Creating a model for conduct in

accordance with the ethical principles

contained in this Code and encouraging apositive climate for the transparent

exchange of ideas, mutual support and

shared information in an open and

reciprocal way with sufficient thoroughness

that allows us to act and decide.

Offering leadership and guidance that

demonstrates to others that respecting the

Code is a fundamental element of their workthrough the continuous communication,

notification and explanation of the

obligations and authorizations relevant to

their area of work.

Relying on the members of the team,

agreeing on clear, measurable and realistic

objectives, giving them their own

responsibility and significant room for

maneuver, recognizing a job well done and

especially valuing the most importantachievements, without ceasing to monitor

compliance with this code and the

standards existing within their area of

responsibility.

13GRUPO ANTOLIN



14GRUPO ANTOLIN


5Whistleblowing

T h e T r a n s p a r e n c y C h a n n e l

CORPORATE

CULTUREOUR COMMITMENT THE TEAM

WHISTLEBLOWING

CHANNEL

ACTION

PROTOCOLCODE OF ETHICS

AND CONDUCTTHE ETHICS

COMMITTEE

It is the RESPONSIBILITY of

each and every person

who forms part of Grupo

Antolin to apply the

content of this Code of

Ethics and Conduct

appropriately, helping

others to do the same.

All managers must ensure

that the employees in

their area of responsibility

are aware of it and

comply with the

commitments and

principles included in this

Code.

We would like to

encourage you to

express your concerns

and report, in good

faith, with impartiality

and respect, any

behavior or situations

contrary to the

commitments outlined

here.

Taking Grupo Antolin as a whole as an international business, when we are

faced with situations relating to business conduct on international trips, we

must consider the policies in place in the country of destination and those of

the country of origin so that we can take the right decisions. However, in the

event of any doubt, each professional must examine their own conscience to

determine the best way to deal with the situation, seeking help from

colleagues, managers and, where necessary, the company itself, referring

the issue to the Ethics Committee [email protected]

MANAGING TRANSPARENCY

mailto:[email protected]

15GRUPO ANTOLIN


5Whistleblowing


I What is it? The Transparency or Whistleblowing Channel at Grupo Antolin is the official

channel made available to all employees of Grupo Antolin by the company, also

accessible to people outside the organization, used to send any complaints and/or reports

under the scope of this Ethical Code considered necessary, including those of an

economic, financial and/or accounting nature, that may arise in the running of the

business.

The Transparency Channel is also the means to facilitate the secure formulation of any

query about the scope and applicability of the Group's model for organizing and

managing criminal risks, as well as for notifying or reporting situations of breach or risk in

relation to the conducts regulated by it.

I What is considered appropriate to report? In general, any violation, omission or

legal or moral attitude that goes against any of the values, commitments or principles

contained in the text of the Grupo Antolin Code of Ethics and Conduct, the model for

organizing and managing criminal risks or any company policy and the applicable

legislation should be reported.

Any type of threat or reprisal against anyone who in good faith has reported any possible

infringements or has requested clarification about the application of anything set out in the

previous paragraph is considered an infringement.

Additionally, also considered as an infringement will be the behavior of anyone who in bad

faith accuses other people of violations, conduct or omissions and/or misuses this channel

without any grounds for that, with the sole purpose of personally or professionally harming a

person.

I What is the procedure to follow? The first person to turn to with any queries or

doubts regarding compliance or otherwise with this code is your immediate line manager

or their immediate line manager, the local Department of Human Resources and, where

appropriate, the company's Committee, if applicable.

If the query or doubt regarding the reported event is not dealt with, could compromise the

responsibility of the person reporting it, seriously affects the physical or moral integrity of this

or another person and/or poses a significant risk to the activity or reputation of the

company, the Transparency Channel must be used as the official channel for reporting

these types of situations.

I How can I access it? Reports may be made in writing either through the company's

website for those with access to a computer or through the following PO Box:

https://extranet.grupoantolin.com/Web/GA.CanalTransparencia.Web/Default.aspx?Lang=

EN

Grupo Antolin

PO Box 2069

09007 Burgos (Spain).

I Is it anonymous? Anyone making a report must identify themselves, providing all the

necessary details along with the details of the person being reported. However, this is while

at all times guaranteeing the confidentiality of the identity of the complainant and the

information provided, preventing any other person from accessing any details that could

identify them. Anonymous complaints will not be accepted.

CORPORATE


WHISTLEBLOWING

CHANNELACTION


AND CONDUCT

THE ETHICS

COMMITTEE

https://extranet.grupoantolin.com/Web/GA.CanalTransparencia.Web/Default.aspx?Lang=EN

16GRUPO ANTOLIN


5Whistleblowing


I What guarantee of protection do I have? Grupo Antolin is committed to supporting a

culture in which any legal or ethical concerns may be expressed without fear of reprisal. The

company's policy prohibits any form of reprisal, threat or disciplinary and/or discriminatory

measures against people who, in good faith, use this channel to report omissions, conduct or

behavior that is suspected to be contrary to the current legislation or the principles and

policies of the company, including this code.

I Who can see my request? This information is only received by the Corporate

Department for Corporate Social Responsibility who will be responsible, in view of the details or

information provided, for deciding whether to launch the appropriate procedure for each

type of request.

The documentation is regularly submitted to the Ethics Committee and, where appropriate,

the Audit Committee. This determines whether a complaint is founded and, if it is, the

complaint is dealt with following the defined process which will be adapted, where

appropriate, to the specific case and country.

Any exchange or transfer of details and information coming from the Transparency Channel

between subsidiaries and/or investees of Grupo Antolin considered necessary for the correct

analysis and resolution of the reported situation will require the consent and approval of the

interested parties from the moment that their request is made official through the

Transparency Channel.

The start of proceedings will be communicated to the person being reported as soon as

possible, and in any case within the period of three months from the making of the complaint,

always respecting the principle of confidentiality for the Transparency Channel mentioned

above.

The decision will be communicated exclusively to the interested parties and will be made

following the instructions contained in the Internal Regulation that governs the Committee,

representing the position of the company with regards to the conflict.

I How long does it take to resolve a complaint? There is no estimated time as each

request is dealt with personally and varies depending on the reported situation, information

available, people involved, languages and any other circumstance involved that affect its

resolution.

I For how long is the data saved? The personal data collected as a result of the process

for making a complaint via the Transparency Channel will be deleted as soon as all the

internal audit and/or legal measures resulting from the investigation carried out and

necessary for its resolution have been performed.

The Transparency or Whistleblowing Channel is corporate in nature.

Please consult the local appendix, where relevant, for any possible amendment

of the foregoing depending on the country in order to adapt it to local

legislative requirements.

CORPORATE


WHISTLEBLOWING

CHANNELCODE OF ETHICS

AND CONDUCT

THE ETHICS

COMMITTEEACTION

PROTOCOL

17GRUPO ANTOLIN


6guidance, support and guaranteeT h e E t h i c s C o m m i t t e e

Grupo Antolin has created an Ethics

Committee that is entrusted with the task of

ensuring the creation, updating and fulfilment

of the Code of Ethics and Conduct, with the

power to resolve ethics-related conflicts that

arise in the company.

CORPORATE


WHISTLEBLOWING

CHANNEL

CODE OF ETHICS

AND CONDUCTTHE ETHICS

COMMITTEE

WHAT IS IT?

The Grupo Antolin Ethics Committee is a

collegiate deliberation body, of a

consultative and interdisciplinary nature,

created to analyze and provide advice on

questions of an ethical nature which may

arise in the working environment, with the

ultimate aim of contributing to increasing

respect for and compliance with the

content of the Grupo Antolin Code of

Ethics and Conduct.

The Ethics Committee is a body with

autonomous initiative and control powers

and the responsibility to develop, monitor

and apply the Grupo Antolin model for

organizing and managing criminal risks.

OBJECTIVES

1.- To assess the level of alignment

between the company's values and its

social and cultural reality.

2.- To develop and update the values

and this Code on the basis of the needs of

the environment.

3.- To monitor appropriate compliance

with the ethical principles and values

within Grupo Antolin.

4.- To develop, monitor and apply the

model for organizing and managing

criminal risks.

5.- To serve as a guide and support for the

company's professionals.

6.- To identify, analyze and respond to

infringement situations.

The Committee also undertakes to

regularly report to the Management of

Grupo Antolin about the number and

seriousness of the incidents detected, the

number of interventions by the

Committee and any corrective actions

undertaken, as well as the degree of

awareness of the Ethical Code amongthe professionals of Grupo Antolin.

WHO IS IT?

The Committee is formed by a minimum of

3 and a maximum of 7 professionals who

are internal or external to the company,

experts in Corporate Responsibility and,

labor, judicial and legal issues. Their

appointment and dismissal is the

responsibility of the "Appointments and

Remuneration Committee".

WHEN DOES IT ACT?

The Grupo Antolin Ethics Committee

analyzes possible ethical conflicts arising in

relation to employees in any of the Grupo

Antolin companies or in relation to people

external to the organization who directly or

indirectly affect the company, reported

through the Transparency Channel at the

request of the Corporate Social

Responsibility team.

TO WHOM DOES IT REPORT?

The Grupo Antolin Ethics Committee carries

out a dual reporting of its activity: to the Chief

Executive Officer -CEO- of the company and

to the Audit Committee.

Contact: [email protected]

…

Board of Directors

Audit

CommitteeAppointments

and

Remuneration

Committee Ethics

Committe

eCEO

… HR

CSR

ACTION

PROTOCOL

mailto:[email protected]

Alleged situation subject to a complaint

Complaint

Website

SPANISHhttps://extranet.grupoantolin.com/Web/GA.Canal

Transparencia.Web/Default.aspx?Lang=ES

ENGLISHhttps://extranet.grupoantolin.com/Web/GA.Canal

Transparencia.Web/Default.aspx?Lang=EN

PO Box 2069

09007 BURGOS (SPAIN)

Receipt of complaint by CSR

Transferred to the Ethics Committee

Preliminary investigation

Filing of the proceedings Continuation of the proceedings

Internal Investigation by the Ethics or

Audit Committee for members of the Boards of Directors

Preparation of final report

Yes it is confirmed No it is not confirmed

Adoption of appropriate

measures for the

Accused Party

consistent with the application

of the current legislation for

this type of conduct

if necessary, or the model for

organizing and managing

criminal risks when applicable.

Adoption of measures to

improve the working

environment if necessary

Monitoring of the reported

situation until the risk

disappears

If the report was intended to

damage someone:

Adoption of appropriate

measures for the

Accusing Partyconsistent with the

application of the current

legislation for this type of

conduct

if necessary

Filing of the proceedings

Monitoring of the reported

situation until the risk

disappears

Filing of the proceedings

18GRUPO ANTOLIN


7in the event of breaches or misconduct

A c t i o n p r o t o c o l

CORPORATE


WHISTLEBLOWING

CHANNEL

ACTION


AND CONDUCT

THE ETHICS

COMMITTEE

Possibility of an

ex-officio

initiation by the

Ethics

Committee if it

detects

misconduct or a

breach

https://extranet.grupoantolin.com/Web/GA.CanalTransparencia.Web/Default.aspx?Lang=ES

https://extranet.grupoantolin.com/Web/GA.CanalTransparencia.Web/Default.aspx?Lang=E

19

I have read, understood and am committed to

respecting the spirit and letter of the Grupo Antolin


SignatureCORPORATE


WHISTLEBLOWING

CHANNEL

ACTION


AND CONDUCT

THE ETHICS

COMMITTEE

GRUPO ANTOLIN


A c c e p t a n c e

8

http://ganvmipw01.grupoantolin.com/GA.WinLogin/Login.aspx?ReturnUrl=/GA.EthicCode/DoAction.html?action=accept

http://ganvmipw01.grupoantolin.com/GA.WinLogin/Login.aspx?ReturnUrl=/GA.EthicCode/DoAction.html?action=accept

A b o u t t h i s C o d e

20

Glossary of Terms

A

APPOINTMENTS AND

REMUNERATION

COMMITTEE

[Committee appointed by the Board of Directors chaired by an independent

director, responsible, among other broader functions, for appointing the

members of the Ethics Committee.]

AUDIT COMMITTEE

[Committee appointed by the Board of Directors chaired by an independent

director, responsible for "monitoring" internal control, risk management, the

internal control of financial information system, as well as corporate governance

and the possible criminal liability of the legal entities; also ensuring compliance

with the "codes of ethics and conduct" (avoiding conflicts of interest) and to

which the Ethics Committee reports in our Group.]

B

BRIBERY[Offering or receiving any gift, loan, fee, reward or other advantage in relation

to any person in order to obtain something from them, generally illegal or

immoral.]

C

CHILD LABOR

[Any work or service performed under the general minimum age for admission

to work or employment, which is 15 years (13 for light work) and 18 years for

dangerous work (16 under certain strict conditions). There exists the option to first

establish the general minimum age at 14 years (12 for light work) when the

economy and educational services are insufficiently developed. ]

CODE [Set of rules or order on any matter.]

CODE of

BUSINESS ETHICS

[Document voluntarily written by a company which sets out a series of principles

and behaviors that must be followed and observed by the entire workforce of a

company or business.]

COLLECTIVE

BARGAINING

[Voluntary process through which employers and employees freely discuss and

negotiate their relationship, in particular the terms of employment and working

conditions. It involves the employers themselves or their organizations, and the

unions or, in their absence, representatives freely appointed by the employees.]

COMMITMENT[Declaration of principles, a promise or keeping to your word, formalized by

means of an agreement, promise or contract.]

COMPLICITY

[Involvement in any case of abuse, situation or activity that is illicit or contrary to

the ethical principles of conduct which the staff, companies, governments or

other types of entities are undertaking.]

GRUPO ANTOLIN


.

21

Glossary of TermsA b o u t t h i s C o d e

CCONDUCT [Set of actions with which a human being responds to a situation.]

CONFIDENTIALITY[Ownership of the information, which ensures that only authorized staff can

access this information.]

CONFLICT of INTERESTS

Institutional. [Arises when, as a result of other activities or relationships, an

organization cannot provide impartial services, when the objectivity of the

organization to carry out the work corresponding to the mandate is or may

be affected, or the organization has an unfair competitive advantage.]

Personal. [A situation in which the private interests of a person -such as

external professional relations or personal financial assets- interfere or may

be understood to interfere with the carrying out of their official or

professional duties.]

CORRUPTION[Abuse or misuse of the entrusted power, duties and/or resources for their

own benefit, be it financial or otherwise.]

D

DISCRIMINATION

[Any distinction, exclusion or preference that causes rejection or inequality in

opportunity or treatment as a result of race, color, sex, religion, political

opinions, nationality of origin, social background or any other personal

and/or social circumstance.

Indirect. Situation in which an apparently neutral provision, standard or

practice places some people at a particular disadvantage compared to

others, unless that provision, standard or practice can be objectively

justified as having a legitimate purpose and that the means to achieve this

purpose are necessary and appropriate.]

DIVERSITY

[Variety, dissimilarity, difference, distinction between large numbers of

different people, animals or things.

Cultural diversity. Reflects the multiplicity, coexistence and interaction of the

different cultures in the world and that therefore form part of the common

heritage of mankind in certain areas.]

E

ENVIRONMENT

[Surroundings formed by natural and artificial elements that are interrelated

and modified by human or natural action; in which the life of living beings is

developed and allows their interaction, determines the way of life of society

and includes the natural, social and cultural values that exist in a given

place and time.]

ETHICS [Set of moral rules that govern human behavior.]

ETHICS COMMITTEE

[Collegiate deliberation body, of a consultative and interdisciplinary nature,

created to analyze and provide advice on questions of an ethical nature

which may arise in the working environment, with the ultimate aim of

contributing to increasing respect for and compliance with the content of

the Grupo Antolin Code of Ethics and Conduct.]

GRUPO ANTOLIN


.

22


E

EQUALITY[Universal legal principle that recognizes that all people are equal in rights

and opportunities in the eyes of the law, which must take into account the

differences between individuals and groups.]

EXTORTION[Act of asking or enticing another to commit bribery, accompanying this

demand with threats that endanger the personal integrity or lives of the

people involved.]

F

FORCED LABOR [Any work or service obtained from a person under the threat of any penalty

and for which that individual has not offered themselves voluntarily.]

FREEDOM OF

ASSOCIATION

[Respect for the right of all employers and workers to freely and voluntarily

create groups in order to promote and defend their professional interests,

and to join these groups.]

FREEDOM OF

EXPRESSION[Fundamental right to freely speak, express and share one's own thoughts.]

G

GLOBAL COMPACT

[International initiative that promotes the implementation of 10 universally

accepted principles to promote corporate social responsibility (CSR) in the

areas of Human Rights, Labor Standards, the Environment and the Fight

against Corruption in the business activities and strategies of companies.]

H

HUMAN RIGHTS[Rights inherent to all human beings, irrespective of nationality, place of

residence, sex, national or ethnic origin, color, religion, language, or any

other condition. These rights are interrelated, interdependent and indivisible.]

I

ILO

[International Labor Organization. Tripartite United Nations organization

founded in 1919 dedicated to promoting labor rights, enhancing decent

employment opportunities, improving social protection and strengthening

the dialog in addressing work- related issues.]

IMPACT [Any type of contingency or event that may cause or result in damage.]

INVESTEE COMPANY [Entity in which another company with 50% or less of the share capital

participates but does not exercise control. ]

MMODEL FOR

ORGANIZING AND

MANAGING CRIMINAL

RISKS

[Structured and organic system of procedures and control activities, which

should be carried out in a preventative manner, aimed at preventing and/or

detecting the carrying out of different types of crimes that may generate

criminal liability for the legal entity.]

MONEY

LAUNDERING

[Set of mechanisms or procedures designed to give the appearance of

legitimacy or legality to goods or assets that are the proceeds of crime.]

GRUPO ANTOLIN


.

23


NN+1 [The direct manager of the employee.]

N+2 [The superior of the direct manager or N+1.]

O

OECD

[Founded in 1961, the Organization for Economic Co-operation and

Development (OECD) brings together 34 member countries and its mission is

to promote policies that improve the economic and social welfare of people

around the world.]

P

PATRONAGE

[Support in monetary form or in kind given to the community for carrying out

various projects of a social, cultural and scientific developmental nature, as

well as for environmental preservation, which operate more qualitatively and

over the long-term to improve the image of the company that is doing the

sponsoring.]

PREVENTION[Adoption of measures, even before having completed scientifically proven

tests, which help to prevent a delay in the application of these measures

being able to eventually cause injury or damage.]

R

REPUTATION[Strategic asset based on the favorable perception of the company by the

different stakeholders.]

RISK [Probability of an adverse event, impact or consequence occurring.]

S

SOCIAL ACTION

[Conduct or practice of the person or company who has influence over the

conduct or practice of other individuals, companies or society in order to

meet basic needs that, for different reasons, a group of the population

cannot meet and that contributes to the development and progress of

society.]

SPONSORSHIP

[Form of communication that enables a brand to be directly linked to an

event that is attractive to a certain audience, in order to increase the

recognition and image of the company and/or its products in the short-

term.]

GRUPO ANTOLIN


.

24


S

STAKEHOLDERS

[Entities or individuals that may be significantly affected by the activities,

products and/or services of Grupo Antolin; and whose actions may affect,

within reason, the ability of Grupo Antolin to successfully develop its strategies

and achieve its objectives.

Six main groups: Shareholders, Customers, Employees, Investors, Suppliers and

Society.]

SUBSIDIARY COMPANY[Entity controlled directly or indirectly by a parent company, either because

the latter holds more than 50% of the share capital or voting rights, or

because it effectively controls its management.]

SUSTAINABILITY[Sustainable quality, especially referring to the characteristics of

development that meet the needs of the present without compromising the

needs of future generations.]

T

TRANSPARENCY

CHANNEL

[Official channel made available to all employees of Grupo Antolin by the

organization, also accessible to people outside the company, used to send

any complaints and/or reports under the scope of this Ethical Code that are

considered necessary, including those of an economic, financial and/or

accounting nature, that may arise in the running of the business.]

U

UNIVERSAL

DECLARATION OF

HUMAN RIGHTS

[Common ideal through which all people and nations must strive so that,

both the individuals and the institutions constantly being inspired by it,

promote, through teaching and education, respect for these rights and

freedoms and ensure, through national and international progressive

measures, their universal and effective recognition and application, in terms

of both the populations of the Member States and those of the territories

placed under their jurisdiction]

GRUPO ANTOLIN


.

Page Policy. Commitment. WHERE CAN I FIND IT?

Page 5 Mission, Vision and Values http://sharepoint.grupoantolin.com/SiteDirectory/HR/Cor

porateDevelopment/corpculture/default.aspx

Page 6 The Code of Ethics and

Conduct



Page 6

Page 7Grupo Antolin Policies and

Guidelines

http://intranetga/Documentacion/Procedimientos/Index.

asp?tdoc=Proc&openMGG=yes&op=consultar&tipo=24

http://sharepoint.grupoantolin.com/Pages/Default.aspx

http://sharepoint.grupoantolin.com/sites/dci/how_to/def

ault.aspx

Page 6

Page 8United Nations Global

Compact Principleshttps://www.unglobalcompact.org/what-is-

gc/mission/principles

Page 6

Page 8Human Rights:

International Human Rights

Charter

http://www.un.org/en/universal-declaration-human-

rights/index.html

http://www.un.org/es/rights/overview/charter-hr.shtml

Page 6

Page 8Human Rights:

Guiding Principles on

Business and Human Rights

http://business-humanrights.org/en/un-guiding-principles

Page 6

Page 8Labor Standards:

Tripartite Declaration of the

ILO

http://www.ilo.org/empent/Publications/WCMS_094386/l

ang--en/index.htm

Page 6 Labor Standards:

Organization for Economic

Co-operation and

Development

http://www.oecd.org/

Page 8 Commitment:

CSR policy

http://intranetga/Archivos/Procedimientos//IN/Processes

//I-P02-K%20CSR%20POLICY.doc

Page 8

Page

12

The Environment:

Environmental

Management Model

http://intranetga/Redirect.asp?Destino=/documentacion

/medioambiente/Default.asp?Carpeta=&IdLanguage=IN

Page 8

Page

11

Page

12

Data Protection:

Law on the Protection of

Personal Data (LOPD)http://sharepoint.grupoantolin.com/SiteDirectory/LOPD/d

efault.aspx

Page 8

Page

11

Occupational Health and

Safety: Occupational

Health and Safety Model

http://intranetga/Documentacion/Prevencion/Default.as

p25GRUPO ANTOLIN


This list contains the corporate and international principles, policies and guidelines on which

the different commitments outlined throughout the Grupo Antolin Code of Ethics and

Conduct are based and implemented. Available on the website and/or Intranet of the

company, they must be read and interpreted in accordance with the current international,

regional and local legislation and behavior standards.

Internal legal referencesA b o u t t h i s C o d e

.

http://sharepoint.grupoantolin.com/SiteDirectory/HR/CorporateDevelopment/corpculture/default.aspx



http://intranetga/Documentacion/Procedimientos/Index.asp?tdoc=Proc&openMGG=yes&op=consultar&tipo=24

http://sharepoint.grupoantolin.com/Pages/Default.aspx

http://sharepoint.grupoantolin.com/sites/dci/how_to/default.aspx

https://www.unglobalcompact.org/what-is-gc/mission/principles

http://www.un.org/en/universal-declaration-human-rights/index.html

http://www.un.org/es/rights/overview/charter-hr.shtml

http://business-humanrights.org/en/un-guiding-principles

http://www.ilo.org/empent/Publications/WCMS_094386/lang--en/index.htm

http://www.oecd.org/

http://intranetga/Archivos/Procedimientos/IN/Processes/I-P02-K CSR POLICY.doc

http://intranetga/Redirect.asp?Destino=/documentacion/medioambiente/Default.asp?Carpeta=&IdLanguage=IN

http://sharepoint.grupoantolin.com/SiteDirectory/LOPD/default.aspx

http://intranetga/Documentacion/Prevencion/Default.asp


Page 8 Labor Standards:

Wage Policy

http://intranetga.grupoantolin.com/Redirect.asp?Destino

=/Documentacion/Procedimientos/ViewDoc.asp?doc=3

86



10

Page 8 Occupational Health and

Safety: OHSAS 18001http://www.aenor.es/aenor/normas/ediciones/fichae.as

p?codigo=4032

Page 8

Page

11

Diversity and Equality:

Principle of Diversity and

Equality

http://sharepoint.grupoantolin.com/SiteDirectory/Respon

sabilidadCorporativa/Diversidad/default.aspx

Page 8

Page

12

Safety of Information:

Telematic Code



35

Page 9 Economic sustainability.

Risk Management



148

Page 9 Anti-corruption:

Strategy Management



082


Purchase Management

http://intranetga.grupoantolin.com/Redirect.asp?Destino=/Documentacion/Procedimientos/ViewDoc.asp?doc=895



95


Financial controls:

. Investments

. Economic Control of

Projects

. Transfer Pricing

. Closure and

Consolidation of Financial

Statements



97



37



37



135

26GRUPO ANTOLIN



.



http://www.aenor.es/aenor/normas/ediciones/fichae.asp?codigo=4032

http://sharepoint.grupoantolin.com/SiteDirectory/ResponsabilidadCorporativa/Diversidad/default.aspx











Page 9 Information transparency:

Exterior informationhttp://www.grupoantolin.com/es/sala-de-prensa-inicio

Page 9 Information transparency:

Reconciliation of banking

and financial accounts

Cash Count



216



217

Page 9 Innovation:

Innovation Management



74

Page

11Integrity:

Management of travel and

representation expenses



74

Page

11Responsible Mobility:

European Mobility Charter

http://www.erscharter.eu/es/node

Page

12 Knowledge Management:

Knowledge Management

Model



210

Page

11Freedom of Expression:

Motivation and working

environment

http://intranetga.grupoantolin.com/Documentacion/Pro

cedimientos/ViewDoc.asp?doc=864

Page

12Use of Resources:

Resource Management



68

Page

12

Page

15

Freedom of Expression:

Transparency Channel

https://extranet.grupoantolin.com/Web/GA.CanalTransparencia.Web/Default.aspx?Lang=EN

Page

12 Image and Reputation:

Media Protocol

http://sharepoint.grupoantolin.com/sites/RIMK/ComProto

col/Forms/AllItems.aspx

Page

12 Quality in Management:

Management Model

http://intranetga/Documentacion/Procedimientos/Index.

asp

Page

13Collaboration and

Management:

Performance Management

System

http://intranetga/Aplicaciones/SGDv2/SGDIndex.asp

27GRUPO ANTOLIN



.

http://www.grupoantolin.com/es/sala-de-prensa-inicio





http://www.erscharter.eu/es/node


http://intranetga.grupoantolin.com/Documentacion/Procedimientos/ViewDoc.asp?doc=864


https://extranet.grupoantolin.com/Web/GA.CanalTransparencia.Web/Default.aspx?Lang=E

http://sharepoint.grupoantolin.com/sites/RIMK/ComProtocol/Forms/AllItems.aspx

http://intranetga/Documentacion/Procedimientos/Index.asp

http://intranetga/Aplicaciones/SGDv2/SGDIndex.asp

GRUPO ANTOLIN CODE OF ETHICS AND CONDUCT

The Code

I A living document.

I Approved by the Ethics Committee.

I Endorsed by the Board of Directors.

I A single code is valid throughout the entire

scope of Grupo Antolin.

I It applies to all employees linked to Grupo

Antolin, to all subsidiary companies in which it is

the majority shareholder and in those in which it

has management control, as well as to its supply

chain.

I Its compliance is a condition for forming part of

the team of professionals at Grupo

Antolin.

I It may not be unilaterally amended as this is

the exclusive responsibility of the Ethics

Committee.

I It is not a set of internal rules, nor does it

replace any collective agreements or

national legislation.

I It must be read and interpreted jointly with

Grupo Antolin's Policies, Guidelines and

Management Model.

I Available in 27 languages on the company's

Intranet and in Spanish and English on the

Group's website.

Objective I To ensure ethical and responsible behavior when running our business.

Human Rights

Compliance with the legislation

Labor Standards

Data protection

Diversity and equality

Economic sustainability

Anti-corruption practices

Sustainable contribution

Information transparency

Innovation

The absence of funding of the

political, governmental and

terrorism spheres

Collaboration and participation

of Grupo Antolin to:The Commitment

Integrity Respect Confidentiality Independence Well-being, health and safety Responsible

mobility Knowledge management Responsible environmental behavior Responsible use of

resources Quality in management Image and reputation Freedom of expression Privacy of

information Mainstreaming sustainability Prohibiting contributions on behalf of the group

Absence of a conflict of interests Culture of collaboration and management

Model of conduct

A b o u t

,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,00000000000

Grupo Antolin –

Code of Ethics and ConductCtra. Madrid-Irún, km. 244.8

09007 BURGOS – SPAIN

+34 947 47 77 00

+34 947 48 49 19

[email protected]

[email protected]


Always rely on your sense of responsibility

and good judgement and/or,

Talk to your direct line manger, their line

manager or the Management or;

To the Human Resources Department

and, where relevant, the Works Council if

appropriate or;

To the Ethics Committee, if deemed

necessary.

If your query or doubt does not obtain a

response, you may use the Transparency

Channel.

in the event of not receiving a

response or

if the event may compromise the

responsibility of the person who reported it or,

severely affects the physical or moral

integrity of this or another person

and/or,

poses a significant risk to the activity

or reputation of the company.

Is entrusted with the task of ensuring the creation, updating and fulfilment of the Code of

Ethics and Conduct with the power to resolve ethics-related conflicts that arise in the

company.

Develops, monitors and applies the Grupo Antolin model for organizing and managing

criminal risks

Formed by a minimum of 3 and a maximum of 7 professionals that are internal and

external to the company.

Carries out dual reporting of its activity: to the CEO of the company and to the Audit

Committee

CONTENT QUERIES Correct business conductText interpretation

It is the RESPONSIBILITY of everyone forming part of Grupo Antolin to apply the

content of this Code of Ethics and Conduct appropriately, helping others to do the

same.

The Ethics Committee

N+1

N+2

HR and/or

Works Council if necessary

WHISTLEBLOWING CHANNEL

1

COMPLAINTS or REPORTSBehavior contrary to the GA values, commitments and/or principles

23


[email protected]

+34 947 47 77 00

It's what's inside that counts

Code of Ethics and Conduct - Grupo Antolin...The Code of Ethics and Conduct 2 an action model CORPORATE CULTURE CODE OF ETHICS AND CONDUCT OUR COMMITMENT THE TEAM WHISTLEBLOWING CHANNEL

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