Code of Ethics

Code of Conduct and Responsible Practices – TRIDIOM, S.L.

Objective of the code

TRIDIOM's Code of Ethics and Professional Conduct identifies the values and principles that should guide the behaviour of all its professionals as they carry out their activities.

Scope of application

The Code sets out the standards of conduct that must be observed at TRIDIOM while it carries out its professional responsibilities.

The objective of this Code is to ensure professional, ethical and responsible behaviour at TRIDIOM and by all its employees while they carry out their activities, as a fundamental part of company culture and basis for the training and personal and professional development of its employees. To this end, the principles and values that must govern TRIDIOM's relationships with its stakeholders (employees, clients, shareholders, business partners, suppliers and the societies in which it operates) are defined below.

To do so, the Code:

• Facilitates awareness and application of TRIDIOM's corporate culture, firmly grounded in compliance with human and social rights and in the effective integration within the company of all employees, respecting their diversity.
• Establishes the principle of due diligence for the prevention, detection and eradication of irregular conduct, whatever its nature, including, among other things, risk analysis, the definition of responsibilities, the training of employees and, where applicable, of third parties directly related to the company, and the formalisation of procedures, in particular for the reporting and immediate elimination of irregular conduct.
• Takes into account the principle of criminal liability of legal entities, as set out in the Spanish legal system in which TRIDIOM operates, and it prevents and prohibits conduct that could give rise to liability for the company among its legal representatives, directors, managers, employees or any other person subject to the authority of TRIDIOM staff.

GENERAL PRINCIPLES

The Code of Ethics and Professional Conduct applies to all TRIDIOM employees, regardless of their position in the company hierarchy, their geographical location or responsibilities. The Divisions that form part of TRIDIOM and would therefore be subject to compliance with this Unified Code of Ethics and Conduct are the following:

Control of distribution and maintenance

In case of doubts regarding this Code of Conduct and Responsible Practices, employees should contact their immediate superior. All professionals are required to know and understand the contents of this Code, as well as the values on which it is based.
Reporting Channel

TRIDIOM wishes to establish a specific communication channel with the management and governing bodies which serves as a way to report any possible misconduct, non-compliance, unethical or illegal behaviour or behaviour that breaches the rules stipulated in this Code of Conduct and Responsible Practices. Allegations should be sent by e-mail to ana@tridiom.com, in accordance with the instructions given for the same.

The function and principles that govern the Reporting Channel are outlined below.

Investigation of misconduct

Any reports of alleged violations of our Code or the law will be investigated immediately. The Audit Committee will begin an investigation process to analyse alleged violations of the Code, guaranteeing the confidentiality of the individuals involved.

All activities carried out by TRIDIOM are based on an attitude of respect, professionalism, honesty and integrity towards all professionals.

The main guiding principles that must govern our activities are the following:

Commitment to human and workers' rights

TRIDIOM is committed to respecting human rights, particularly in terms of complying with regulations related to child and forced labour.

Compliance with the law

TRIDIOM employees shall strictly comply with the law in force wherever they are working.

Protection of the environment

TRIDIOM will respect the environment while carrying out its activities, complying at all times with current legislation on the environment and minimising the impact of its activities and waste generation, as well as saving energy and water consumption in all its facilities.

A fundamental part of the TRIDIOM business model is Corporate Social Responsibility, understood as a commitment to the environment when carrying out its business activities and for the benefit of all its stakeholders.

TRIDIOM commits to minimising its environmental impact while carrying out all its activities.

Health and safety

TRIDIOM promotes occupational health and safety, informing and raising awareness among its employees so that they adopt responsible practices and take the necessary precautions to minimise risks in the workplace.

Work-life balance

TRIDIOM respects the family and personal life of its employees and will promote work-life balance programmes that help them to find a perfect balance between family life and work responsibilities.

Non-discrimination

TRIDIOM prevents any type of discrimination based on age, race, sex, ideology, religion, nationality, social background, sexual orientation, political opinions or any other personal, physical or social condition of its employees. In particular, TRIDIOM will promote equality of treatment for men and women as regards access to employment, training, promotion and working conditions.

Similarly, it forbids any type of intimidation, violence, physical, sexual, psychological or moral abuse or any other abuse of authority.

Data Protection

TRIDIOM respects its employees' right to privacy, especially in relation to personal, medical and financial information.

TRIDIOM undertakes not to disclose the personal data of its employees with third parties, unless the interested parties have given their explicit consent or in case of legal obligation.

TRIDIOM employees who have access to the personal data of other employees commit to maintaining the confidentiality of said information.

TRIDIOM maintains the confidentiality of the information we work with, including know-how, intellectual and industrial property and other intangible assets owned by TRIDIOM or third parties with whom we work.

Recruitment and training

TRIDIOM maintains a recruitment programme based exclusively on the academic, personal and professional merits of candidates and on TRIDIOM’s specific needs.

Said programme respects the principle of equal opportunities for all interested parties. It promotes training for its employees based on their role and responsibilities.

The training programmes promote equal opportunities and professional development that also contributes to TRIDIOM's own objectives.

Suppliers

The processes for choosing suppliers meet the criteria of objectivity, impartiality and transparent and loyal behaviour, as well as reciprocal collaboration that prevents any conflict of interest or favouritism.

All our suppliers must read our Code of Ethics as a condition before they can do business with us. Our suppliers include any third party such as: consultants, contractors, service providers, etc.

If you are responsible for choosing a supplier, you must base your decision on their merits, quality of service, competitiveness and reputation.

Clients

TRIDIOM's commitment to its clients means that we will always aim for maximum satisfaction with our products and services, building mutually beneficial long-term and sustainable relationships.

Market integrity requires each of us to treat our clients ethically, fairly and in compliance with all applicable laws. When dealing with our clients you should at all times:

• Win business based on the superiority of our services, level of customer service and thanks to our competitive prices.
• Present our services and products honestly and directly.
• Avoid unfair or fraudulent business practices.
• Explain our sales programmes clearly.
• Fulfil your promises.

International trade controls

As a global organisation, TRIDIOM sends goods, services and technology across Spanish borders. Our business transactions are subject to several controls and trade laws that regulate exports and imports.

If you are involved in sending goods or services across national borders in the name of our company or our clients, you must comply with trade laws and regulations, regardless of your location at that time.

Fight against corruption and bribery

Generally speaking, "corruption" refers to obtaining or trying to obtain a personal benefit or commercial advantage through improper or illegal means.

Bribery, meanwhile, is to promise or offer, directly or indirectly, any kind of gift, entertainment invite, benefit, advantage and/or anything of value to a politician, official or employee of public administration, or to private natural or legal persons in order to obtain some kind of commercial advantage.

It is strictly forbidden to pay and/or accept bribes or to participate in any kind of corruption.

Bribery is not only limited to cash payments, it also includes, among other things:

• Gifts or giveaways.
• Any kind of invitations to entertainment events and travel.
• Loans or credits.
• Any kind of personal favour.
• Reimbursement for entertainment and/or travel expenses.
• Contributions or donations to political parties or non-profit organisations
• Any kind of benefit or advantage to a member of someone's family in order to influence them.

Corrupt activities not only violate this Code but may also seriously violate the civil and criminal laws of the various countries in which TRIDIOM works.

These restrictions apply to every location where TRIDIOM carries out its activities, independently of the provisions of the different laws in that area.

Notwithstanding the above, any gifts or hospitality given that meet the following criteria will be permitted:

• They are permitted by the applicable legislation of each country.
• They do not breach the ethics and transparency values adopted by TRIDIOM.
• They are given or received as a matter of generally accepted business practice or social courtesy and consist of items or hospitality that are considered to be symbolic or financially irrelevant as a whole.

If you know of any act of corruption or bribery, you must report it.

Competitors

TRIDIOM competes fairly and in compliance with all applicable competition laws worldwide. Any employees that collect, share and use information about our competitors must only do so in a lawful and ethical manner.

Always compete with integrity and comply with applicable anti-trust and competition laws.

When working with our competitors, you should never make an agreement, whether formal or informal, written or verbal, to fix prices or other sales conditions, coordinate bids, assign clients, sales territories or product lines, or join in any other activity that breaks the applicable anti-trust and competition laws.

Breaking anti-trust and competition laws may lead to severe legal penalties for our company and criminal charges against the individuals involved.

Conflict of interest

When carrying out any activity, you should avoid anything that could lead to a conflict between your personal interests (or those of any member of your family) and the interests of the company.

Conflicts of interest can occur when you or one of your family members receive any personal or financial benefit (or have a financial interest) or work for a supplier, client, competitor or company that intends to do business with us.

If at any time during your employment you think you may have an actual or potential conflict of interest, you are obliged to report said conflict to our company immediately.

Remember that having a conflict of interest is not necessarily a violation of the Code, but not disclosing it is.

Company resources

You are obliged to protect TRIDIOM's resources.

TRIDIOM trusts that you will use company resources in an honest and efficient manner.

Resources include physical goods such as facilities, supplies, equipment, machinery, spare parts, raw materials, finished products, vehicles and company funds. They also include intangible assets such as confidential information, intellectual property and information systems.

You should only use company resources for legitimate commercial purposes and protect them from theft, lost, damaged or misused. The obligation to protect company funds is particularly important if you are authorised to spend money or approve expenditure, as well as manage budgets.

Fraud

Committing fraud is to misuse company resources by intentionally hiding, altering, falsifying or omitting information for the benefit of yourself or others.

Fraud may be motivated by the opportunity to obtain something of value (such as meeting a performance target or receiving a payment) or to avoid negative consequences (such as a disciplinary action).

Confidential information

You must protect and not disclose any confidential information concerning TRIDIOM, its clients, suppliers, business partners or a third party that is sensitive in terms of competition and/or proprietary. You must assume that all company information is confidential or sensitive in terms of competition, unless there is clear evidence that TRIDIOM has already published said information in the public domain.

Disciplinary action

If you breach our Unified Code, the company will be able to take the appropriate disciplinary action in accordance with the misconduct and sanction system in force at that time.

The TRIDIOM management team will ensure compliance with this Unified Code and its manner of working must be a model and example for all its employees.

TRIDIOM wishes to establish a specific communication channel with the management and governing bodies which serves as a way to report any possible misconduct, non-compliance, unethical or illegal behaviour or behaviour that breaches the rules stipulated in the Unified Code of Ethics and Professional Conduct.

PROCEDURE

Allegations should be sent by email to ana@tridiom.com, which will be accessible to the Chair of the Audit Committee. The following information should be included as a minimum:

Details of the individual making the allegation

Name and surname(s).

Telephone. Address.

E-mail

Type of allegation:

Misconduct related to suppliers.

Non-compliance with market procedures with regard to choosing suppliers.

Improper appropriation and diversion of resources.

Fraudulent appropriation of company goods for personal use or with the intention of making a profit. Accounting matters.

Recording business and financial transactions in a way that breaches generally accepted accounting practices. Work-related issues and risk prevention.

Conflict of interest.

Falsifying documents.

Modifying contracts, reports or documents for personal benefit or with the aim of having a detrimental effect on TRIDIOM.

Using inside information.

Violating or breaching legal regulations.

Using information without authorisation about the company, its clients or suppliers.

Other

Recording transactions

All financially significant transactions made by the company will be clearly and accurately recorded in proper accounting records which give a true and fair view of the transactions and will be available for internal and external auditors to view.

TRIDIOM employees will record financial information in the company's systems completely, clearly and accurately, so as to reflect its rights and obligations on the corresponding date in accordance with the applicable regulations. TRIDIOM undertakes to implement and maintain a suitable internal control system over financial reporting and to regularly monitor its effectiveness.

Ethics in financial reporting.

TRIDIOM and its employees are committed to providing complete, fair, accurate, timely and understandable information in public company reports and other communications and we voluntarily adhere to the provisions of the Transparency Act.

Records and other documents shall be maintained in accordance with existing legal, regulatory or contractual requirements. TRIDIOM prohibits any employee from altering or destroying records, unless authorised by its policy or guidelines. TRIDIOM also prohibits any employee from helping or encouraging independent auditors to destroy the company's audit records.

Financial records shall be made available for inspection by management and auditors.

TRIDIOM must try to address and solve any internal control weaknesses identified by employees, external auditors or third parties.

Inside information

Employees shall not use inside information for their own financial benefit or disclose, for use by third parties, inside information obtained as a result of working for TRIDIOM.

Current legislation sets forth financial penalties and prison sentences for anyone committing the abovementioned activities. Such activities could be grounds for dismissal for just cause.

These restrictions apply to all directors, managers and employees at all levels, including senior management and administrators, internal and external

Compliance committee

In order to ensure compliance with this Code, there is a Compliance Committee made up of Management

The Compliance Committee may act on its own initiative or at the request of any TRIDIOM employee, supplier or third party with a direct relationship and legitimate business or professional interest, through a complaint made in good faith. To this end, communications made under this Code, whether they contain reports of non-compliance or queries relating to its interpretation or application, may be sent to the company through the designated ethics channel.

The Compliance Committee reports directly to the Board of Directors and has the following basic responsibilities:

• Supervise compliance with and the internal distribution of the Code to all members of the TRIDIOM team.
• Receive all kinds of written queries about the application of the Code and refer them, where appropriate, to the department responsible for processing and responding to said queries.
• Oversee and monitor the processing of files and their resolution.
• Answer any doubts that arise from applying the Code.
• Propose to the Board of Directors any clarifications and rules for implementation needed to apply the Code.
• Monitor the Ethics channel and compliance with its procedure.

In carrying out its duties, the Compliance Committee shall ensure:

• The confidentiality of the identity of those making allegations, unless disclosure of the information is required by law or court order.
• The conduct of proceedings appropriate to the circumstances of the case, which shall always be carried out independently and with full respect for the right to be heard and the presumption of innocence of any person concerned.
• Protection of any whistleblower from retaliation as a result of submitting good-faith requests or complaints. The Compliance Committee shall have the necessary means to ensure the implementation of this Code.

Equality and Sexual Harassment Prevention Plan

At TRIDIOM, we reaffirm our commitment to promoting equal opportunities and respect for everyone who forms part of our organisation. This commitment is put into practice through the implementation of an Equality Plan and a clear and effective protocol for the prevention of, and response to, sexual and gender-based harassment.

Equality Plan

TRIDIOM’s Equality Plan aims to ensure a fair, inclusive and respectful working environment, eliminating any form of discrimination on the grounds of gender, origin, sexual orientation, disability or any other personal or social circumstance.

Prevention of Sexual and Gender-Based Harassment

TRIDIOM condemns and prohibits any form of sexual harassment, gender-based harassment or other discriminatory behaviour in the workplace. To this end, the following measures have been implemented:

• Clear definition of harassment: We provide clear definitions of what constitutes sexual harassment and gender-based harassment, in accordance with current legislation.
• Zero-tolerance policy: We are firmly committed to taking immediate action in response to any instance of harassment, without exception.
• Action protocol: We have an accessible and confidential procedure in place for receiving, investigating and resolving complaints relating to harassment.
• Preventative training: We organise workshops and training sessions to identify, prevent and tackle harassment in all its forms.
• Support for victims: We provide psychological, legal and personal support to those affected, ensuring the protection of their integrity and dignity.

Commitment Across the Organisation

The implementation of the Equality Plan and the protocol for the prevention of sexual harassment requires the active participation and commitment of everyone at TRIDIOM. Every member of the organisation has a responsibility to act with respect, promote inclusion and report any behaviour that contravenes these principles.

Through these actions, TRIDIOM reinforces its commitment to creating an ethical, safe and respectful working environment for everyone.