Code of Ethics for PROSERTEK: A Guide to Professional Conduct and Corporate Values, Lecture notes of Ethics

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CODE OF ETHICS

Document approved by the Board of Administrators of PROSERTEK Group 26 April 2018

TABLE OF CONTENTS.

1.- INTRODUCTION .................................................................................................................... 3

2.- SCOPE OF APPLICATION ................................................................................................... 4

3.- PROSERTEK'S CORPORATE VALUES .............................................................................. 5

4.- BEHAVIOURAL GUIDELINES……………………………………………………………………

4.1 Regarding Legality. 4.2 Integrity in professional conduct. 4.3 Prohibition of discriminatory behaviour. 4.4 Balancing personal life with professional activity. 4.5 Right to privacy. 4.6 Health and Safety in the workplace. 4.7 Hiring and Training programmes. 4.8 Courtesies and Gifts. 4.9 Resources for carrying out professional activity. 4.10 Confidential and reserved information for internal use. 4.11 External activities. 4.12 Respect for human and labour rights. 4.13 Relations with clients, suppliers and the market. 4.14 Information transparency. 4.15 Social actions and donations. 4.16 Environmental protection. 6.- COMMUNICATION, ACCEPTANCE AND INTERPRETATION OF THE CODE OF ETHICS………………………………..…………………………………………………………….......… 4 7.- COMMUNICATING BEHAVIOURS THAT CONTRADICT THE CODE OR ARE ILLEGAL……………………………………………………………………………………………...….... 8.- VALIDITY AND UPDATING THE CODE OF ETHICS………………………………….....…

SCOPE OF APPLICATION Compliance with this Code of Ethics is mandatory for all entities comprising PROSERTEK and shall therefore be binding for all these entities' staff (employees and directors), regardless of the type of contract determining their relationship, the position they occupy and the location where they carry out their work, as well as all collaborators who participate in conducting social activities. To this end, administrative bodies of Group entities shall adhere to this guide and share it with all employees, so they are aware of its content and applicable standards. They all have the obligation to be aware of it and follow it when providing their services in name and on behalf of PROSERTEK to third parties, notwithstanding that they may also be subject to other codes of conduct or any other inherent duties that they have undertaken due to their professional activity or the specific duties they carry out. Thus, all individuals employed at PROSERTEK are subject to the following obligations:

• Being aware of this code of ethics and making decisions in accordance with the principles, behavioural guidelines and policies therein.
• Responsibly communicating any sign of the existence of processes or actions that contradict provisions in this Code. All directors and leaders at PROSERTEK also have the following responsibilities:
• Sharing the Code with their teams, leading compliance.
• Establishing mechanisms, in time and in form, to guarantee compliance with the Code in the areas under their responsibility.
• Informing the Compliance Manager of processes and actions that go against provisions in this Code. Regardless of their position in the Group, nobody is authorised to request that an individual falling under the scope of the Code contravene its provisions. Nobody, whether a group employee or an individual subject to compliance, may justify behaviour that goes against the Code, or mal praxis alleging an order from above or lack of knowledge of the Code's content. The scope of application of this Code of Ethics may be extended to any individual related to the group other than the aforementioned when, due to the nature of said relation, their actions may affect the Group's reputation in some way, or transfer liability to the Group.

PROSERTEK'S CORPORATE VALUES Legality and Liability PROSERTEK is committed to following the law in all scopes, and to extend this commitment when the work or activities are conducted by third parties as essential and unavoidably relevant to maintain the best reputation and implied, responsible organisation in defence of developing society and the people comprising it. As proof of this commitment, PROSERTEK has a legal compliance verification system. Different managers at PROSERTEK must provide the individuals under their responsibility with the information and clarifications necessary for them to carry out their duties in full compliance with legal obligations. Comprehensive professional behaviour focused on excellence The guiding criteria which PROSERTEK'S professionals' behaviour must follow are professionalism, integrity and self-control in actions and decisions:

1. Professionalism is diligent, responsible, efficient action, focused on excellence, quality and innovation.
2. Integrity is loyal, honourable, good-faith, objective action in line with PROSERTEK'S interests, principles and Code of Ethics.
3. Self-control in actions and in decision-making, so that all actions are conducted on the basis of four basic premises: (i) the action must be ethically acceptable; (ii) it must be legally valid; (iii) it must be desirable for Society; and (iv) the individual must be willing to take responsibility for it. All this is with the commitment to achieve top quality at an individual level, as a team and corporately, with the understanding that PROSERTEK'S reputation depends on the quality of the services it provides, which is the responsibility of each and every one of its members.

religion or any other personal, physical or social condition of its professionals, and promotes equal opportunity for all.

2. In the same fashion, PROSERTEK shall promote equal treatment between men and women regarding access to employment, training, promoting professionals and working conditions.
3. PROSERTEK rejects all forms of violence, physical, sexual, psychological, emotional and other harassment, abuse of authority at the workplace and all other behaviours that create an intimidating or offensive environment for the personal rights of its professionals. Specifically, it shall promote measures to prevent sexual harassment and gender-based harassment when deemed necessary. All this is notwithstanding standards of mandatory compliance set forth in the policy to reject harassment, violence or discrimination applied in the group.

4.4.- Balancing personal life with professional activity

PROSERTEK respects the personal and family life of its professionals and shall promote programmes to better balance between personal life and professional responsibilities.

4.5.- Right to privacy

1. PROSERTEK respects its professionals' right to privacy, in all forms, especially regarding personal, medical and financial data.
2. At PROSERTEK, there is respect for its professionals' personal communications online and, in general, in any other fashion. Moreover, PROSERTEK'S staff undertake to responsibly use communication resources, IT systems and, in general, any other resources the organisation makes available, according to the policies and criteria set forth to this end. These resources are not provided for personal, non-professional use, and are therefore not suitable for private communication. For this reason, there is no expectation of privacy in the event that they must be supervised by PROSERTEK in proportionately carrying out its verification duties, as set forth in the IT RESOURCE POLICY document.
3. PROSERTEK'S professionals commit to not reveal its professionals' personal data, barring consent of interested parties, and in cases where the law stipulates doing so or to comply with legal or administrative rulings. Personal data must always be processed according to applicable laws in force, with the commitment to respect confidentiality.

4.6.- Health and safety at the workplace

For PROSERTEK, constantly improving working conditions and safety at all facilities is a priority, as well as the safety of its employees and collaborators at facilities, both its own facilities and those where it takes action. To this end, it actively foments adopting occupational health and safety policies and adopts preventive measures, providing an occupational environment that is respectful of the health and dignity of people.

All of PROSERTEK'S people and collaborators must know and comply with occupational health and safety protection regulations and ensure their own safety and the safety of those who may be affected by them carrying out their activities. Consequently, all members of the organisation and those that work for it or on its behalf shall actively seek to create and maintain a safe workplace, scrupulously following the laws applicable in the location where they conduct their activities and anticipating the preventive measures necessary to create the best possible occupational health and safety conditions. PROSERTEK shall promote compliance with its occupational health and safety standards and programmes amongst the suppliers with which it operates. Additionally, PROSERTEK considers the consumption of illegal drugs or alcohol abuse to be entirely incompatible with upright and responsibility occupational and professional activity, so carrying out the position's duties under the effects of these substances shall be sanctioned.

4.7.- Hiring and Training Programmes

1. PROSERTEK shall maintain the most rigorous and objective hiring process, attending exclusively to academic, personal and professional merits of candidates and the organisation's needs.
2. Training for its professionals shall be promoted. Training programmes shall encourage equal opportunity and professional career development, contributing to achievement of the organisation's objectives.
3. Professional commit to constantly update their technical and management knowledge, and to use the organisation's training programmes. 4.8.- Courtesies and gifts
4. PROSERTEK'S professionals may not give or accept gifts and, in general, courtesies in conducting their professional activity. Exceptionally, giving and receiving gifts may be permitted when the following circumstances occur simultaneously: a) their economic value is irrelevant or symbolic. b) respond to usual social or commercial signs of courtesy. c) are not prohibited by law or generally accepted commercial or social practises. d) Under no circumstances may they be considered "in poor taste" or violate the organisation's ethical principles. Gifts falling under the circumstances set forth above shall not be subject to application of behavioural guidelines regarding "social actions and donations".
5. Members of PROSERTEK may not, directly or through an intermediary, offer or grant or request or accept unjustified advantages or benefits whose immediate or mediate purpose is to obtain a present or future benefit for the organisation, for themselves or for a third party. Particularly, they may not give, receive or offer any kind of bribe, gift, compensation or commission, coming from, created by or carried out by any other party

All this is notwithstanding the mandatory standards set forth in the IT resource regulatory policy.

4.10.- Confidential and reserved information for internal use

1. In general, non-public information owned by PROSERTEK shall be considered information for internal use, unless classified as reserved or confidential. In any event, it shall be subject to professional secrecy, and its content may not be provided to third parties, unless doing so falls under normal exercise of one's work, profession or duties, and provided that the parties receiving the information are legally or contractually bound by a confidentiality obligation and have confirmed to the Company that they have the resources necessary to protect it.
2. It is the responsibility of PROSERTEK and all its professionals to provide sufficient security resources and to apply the established procedures to protect information that is for internal use, confidential and reserved, recorded in physical or digital format, from any internal or external risk of non-consented access, manipulation or destruction, both intentional and accidental. To this end, PROSERTEK'S professionals shall keep the content of their work confidential in relations with third parties, unless they have express authorisation to share it.
3. Revealing confidential or reserved information, or using it for personal reasons, contravenes the Code of Ethics.
4. Any reasonable sign of leaked confidential or reserved information for personal reasons must be communicated by those who are aware of the circumstance to PROSERTEK'S Supervision and Control Body, who shall indicate the appropriate procedure.
5. In the event of termination of the relationship with PROSERTEK, all internal, confidential and reserved information must be returned by the professional to the organisation, including documents and media or storage devices, as well as information stored on any corporate or personal electronic device. In any event, the professional's confidentiality duty shall persist.

4.11.- External activities

1. Professionals shall dedicate PROSERTEK all professional ability and personal effort necessary to carry out their duties.
2. Providing labour or professional services, whether freelance or hired, to companies or entities other than PROSERTEK, must be authorised.
3. The Group respects that its professionals conduct social and public activities, provided they do not interfere with their work at PROSERTEK.
4. The relation, belonging or collaboration of professionals with political parties or other kinds of public entities, institutions or associations shall be such that it is made clear that these are personal circumstances, thus avoiding any relation with PROSERTEK.

5. The creation, belonging, participation or collaboration of professionals on social media, forums or online blogs, and opinions and statements made therein, must be such that their personal nature is clear. In any event, professionals must abstain from using PROSERTEK'S image, name or brands to open accounts or to register on these forums or social media networks.

4.12.- Respect for human and labour rights

1. PROSERTEK states its binding commitment to strictly respect human and labour rights recognised in domestic and international law, and the principles upon which the United Nations World Pact and International Labour Organisation's Social Policy are based, as well as documents or texts that may replace or complement the aforementioned.
2. Specifically, PROSERTEK states its total rejection of child labour and forced or mandatory labour and commits to respecting freedom of association and collective bargaining.

4.13.- Relations with clients, suppliers and the market

1. Under all circumstances applying transparency, information and protection standards, PROSERTEK commits to offering services and products with quality equal to, or greater than legally-established requirements and quality standards.
2. PROSERTEK shall guarantee the confidentiality of its clients' data, and undertakes not to reveal them to third parties, barring client consent or legal obligation or to comply with legal or administrative rulings. The collection, use, and processing of clients' personal data must be such that it guarantees their right to privacy and compliance with personal data protection laws, as well as rights recognised for clients by information society services and e-commerce law, as well as other applicable provisions.
3. Contracts with PROSERTEK'S clients shall be written in a simple, clear fashion. In pre- contractual or contractual relations with clients, transparency shall be fostered, and information on different alternatives available shall be provided, especially as far as services, products and rates are concerned.
4. Professionals must avoid all kinds of interference or influence from clients or third parties that may alter their impartiality and professional objectivity and cannot receive any sort of compensation from clients or, in general, from third parties, for services related to the professional's own activity at PROSERTEK.
5. PROSERTEK shall adapt supplier selection processes to objective and impartial criteria, avoiding all conflict of interest and favouritism in its selection. PROSERTEK'S professional must commit to complying with internal procedures established for awarding processes, including and especially, those for approving suppliers.
6. Prices and information provided by suppliers in a selection process shall be processed confidentially and shall not be revealed to third parties, barring consent from interested parties or due to legal obligation, or in compliance with legal or administrative rulings.

4. PROSERTEK states its firm commitment to behavioural standards against corruption and fraud and to prevent crime, and in particular, to not incur in practises deemed irregular in carrying out its relations with clients, suppliers, competitors, authorities, etc., including those related to money laundering. To this end, professionals shall receive suitable training on applicable law in these matters. All this is notwithstanding the mandatory standards set forth in the policy to manage the risk of fraud, bribery and corruption established in the group.

4.15.- Social actions and donations

Whether on their own or through intermediaries, it is strictly forbidden for PROSERTEK companies to make, both directly and indirectly, donations, not even as loans or advances, to Spanish political parties, including federations, coalitions or groups of voters.

4.16.- Environmental protection

1. PROSERTEK conducts its activity in an environmentally respectful fashion, complying with standards set forth in applicable environmental regulations and reducing its activities' environmental impact.
2. PROSERTEK undertakes behavioural guidelines to reduce waste and pollution and to preserve natural resources.
3. Additionally, PROSERTEK commits to respecting the requirements set forth in applicable law on this matter wherever it may be conducting its duties, with all workers, employers and collaborators.
4. The individuals subject to this Code must be aware of, undertake and contribute to reaching this commitment, and make an effort to reduce the environmental impact of their activities and of their use of the facilities, equipment and work resources provided to them.
5. In its relations with clients, public authorities, bodies and institutions, external collaborators and other entities, PROSERTEK shall communicate these principles and promote compliance with environmental procedures and requirements applicable in each case.

COMMUNICATION, ACCEPTANCE AND INTERPRETATION OF THE CODE OF ETHICS PROSERTEK shall communicate and share the content of this Code of Ethics with all its professionals and other affected parties. All individuals falling under this Code's scope of application are bound to know it and comply with it, so they must be aware of the guiding Values and Principles, regardless of whether they have expressly signed it. PROSERTEK requires a high level of commitment in complying with this Code of Ethics from all its professional and external collaborators. All external professionals and collaborators providing their services at PROSERTEK, and those joining and/or who will be collaborating in the future, must expressly accept the Values and Principles and comply with the action guidelines established therein (through a confirmation process). Any questions that may arise regarding the interpretation or application of this document must be brought to the Supervision and Control Body, who has the obligation to encourage knowledge of and compliance with the Code and interpret it in the event of uncertainty. To this end, this body may be contacted through the following channels:  Email info@prosertek.com  Inbox provided by the organisation

VALIDITY AND UPDATING THE CODE OF ETHICS This document was approved by the administrative body of each one of the entities comprising PROSERTEK and is fully valid provided no amendments are made to it. Amendments made to the Code of Ethics may be proposed by the SCB, after issuing a prior report justifying them. They must be approved by the administrative body of each one of the group's entities and shall be applicable the day that they are made known to all individuals subject to the Code.