1. GENERAL SUMMARY 

Organisational ethics at LEIALTA SLP. 

In the business world, when we talk about ethics, we refer to the objective mechanisms that will help demonstrate the values promulgated in the organisation and that it upholds socially. Through the Code of Ethics we try to give effect to the values or ethical principles of our organisation. The ethics in LEIALTA S.L.P. appeal to the processes that determine decisions and behaviours of the organizations under respect of the fundamental principles that govern in any civic community.

This document aims to give an overview of the different internal and external initiatives, which we structure based on our BUSINESS VALUES and organisational philosophy, which we try to reflect in all the professional services that LEIALTA, S.L.P. offers to third parties.

Our CODE OF ETHICS is the benchmark for our current conduct and is the result of the consensus reached between the Partners of the firm and the support of all the employees who make up the firm, thereby seeking the fullest involvement of the organisation in a culture based on responsibility towards clients and society.

The most important points addressed by our current CODE OF ETHICS are:

I. Identification of the company’s principles and values, which focus on:

• Transparency: We speak clearly with our clients in our advice, without beating around the bush.
• Meritocracy: We reward our professionals on the basis of their achievements and goals. We do not believe in favouritism or any other form of professional discrimination.
• Motivation: We ensure that our team does what they really want to do, only then will they give their best.

II. Compliance with national and international law:

We work to maintain knowledge of and compliance with the law (acceptance of the legal system applicable to LEIALTA S.L.P.), with varying levels of demand, in terms of knowledge and compliance with current legislation, depending on the level of responsibility in the organisation.

Duty of knowledge and compliance with the “internal legality” (the code of ethics and other possible internal rules), i.e., respect for the commitments assumed and shared by all members and employees of LEIALTA. S.L.P.

It is the duty of LEIALTA S.L.P. to ensure that employees with functional diversity receive adequate training, which projects their value, as well as on the legislation and internal rules that apply specifically to their condition.

III. Human rights compliance:

In general, it should never be overlooked, especially considering the increasingly global scope of companies and the territories where our future activity may be developed, to take into consideration the respect for human rights, which is why from LEIALTA S.L.P. we assume:

• The 1948 Universal Declaration of Human Rights.
• The United Nations (U.N.) Global Compact, proposed by its Secretary-General in 1999 at the World Economic Forum in Davos, Switzerland, between the United Nations and the business world.
• The provisions of the International Labour Organisation (I.L.O.); in particular the I.L.O. Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy of 1977 and the Declaration on Fundamental Principles and Rights at Work of 1998 (especially with the following themes: eradication of child labour, abolition of forced labour, prohibition of discrimination, freedom of association and the right to collective bargaining).
• International Convention on the Rights of Persons with Disabilities 2006.

IV. Respect for the environment and sustainability:

We take on the challenge of eliminating global warming and working to reduce CO2 emissions. We work under actions that improve the environment and are more sustainable, deciding to have suppliers that help us in this task, recycling materials, reducing unnecessary water consumption, and supporting initiatives that promote respect for the environment, so we have a philosophy aimed at not using office paper or limiting it, to replace this medium with the use of technology. We have ecological containers that favour the recycling of paper at all times.

In addition, our on-site maintenance and cleaning providers use environmentally friendly or low environmental impact products.

There is also management of the air conditioning in our workplace, and limits on excessive or improper energy consumption, using energy consumption meters and controllers.

2. ETHICAL OPERATING PROCEDURES. 

There is a set of procedures in our Code of Ethics, which applies the behavioural guidelines and directives to be followed by LEIALTA S.L.P. staff in the performance of their duties and responsibilities, in all the professional fields in which the company may be represented.

LEIALTA S.L.P. addresses the following processes linked to its Code of Ethics:

I. Loyalty and liability procedure.

II. Procedure to ensure decent working conditions.

III. Procedure for establishing relationships with responsible stakeholders.

IV. Procedure for avoiding conflicts of interest.

V. Validity.

I. Loyalty and liability procedure:

Respect for the legal system, national and international rules and regulations that may affect us, and the promotion of integrity, responsibility, and transparency are aspects that cannot be ignored.

At LEIALTA S.L.P. all employees, managers and directors must be committed to:

• Compliance with the legal order

The commitment to comply with national and international legislation in all its areas and to extend it when the work or activities are carried out through third parties, are inexcusable premises and of essential relevance to maintain the best reputation and condition of a company involved, responsible in the defence of the development of society and the people who form it. As proof of this commitment, LEIALTA S.L.P. has a legal compliance control system.

The heads of the organisational units, in this case the area managers, shall provide their employees with the information and clarifications necessary for them to carry out their functions in full compliance with the legal obligations and established regulations, and shall analyse their compliance on an annual basis.

• Integrity, accountability and transparency

The confidential information of LEIALTA S.L.P. employees in the different client companies where they carry out their activities shall be subject to professional secrecy and may not be provided or leaked to third parties.

There shall be no accounting actions that seek to disguise transactions or relevant financial information.

In terms of compliance with the LORTAD, LEIALTA S.L.P. has the corresponding LORTAD Security Document, as well as the legalisation of its files, supporting, in turn, the confidentiality of the information in external suppliers such as Dataprius and annual audits.

II. Procedure to ensure decent working conditions:

Occupational Risk Prevention and Occupational Safety is a basic element for LEIALTA S.L.P., especially given the special adaptations that its employees require, derived from their personal situations or possible disabilities.

• From LEIALTA S.L.P., all members must be committed to:
  • Respect, dignity and non-discrimination.
  • LEIALTA S.L.P. employees shall show due respect and courtesy to their colleagues, stakeholders and third parties with whom, as a result of their activity and functions, they have a relationship.
  • Managers are committed to avoiding any form of iniquity, exercising their authority in a fair and equitable manner and respecting the dignity of individuals.
  • Threats, acts of violence or intimidation, and abusive, harassing, or offensive behaviour, whether verbal or physical, shall be avoided.
  • A free and respectful environment is the right of all LEIALTA S.L.P. employees.
  • The eradication of forced, coerced and child labour will be supported.
• Right to privacy in the workplace

LEIALTA S.L.P. employees who have access to personal data of employees shall have the obligation to guarantee the personal right to privacy, and inform them about the use that will be made of such data, except with the consent of the interested parties or in cases of legal obligation. The payment of salaries, wages and remuneration shall be treated as completely confidential and exclusively addressed to the data subject. Remuneration information shall not be provided to external employees or third parties, except in cases of legal obligation or provision.

• Occupational health and safety

LEIALTA S.L.P. takes occupational health and safety aspects into account when designing its workplaces so that they are fully suitable for its disabled workers.

• Absence of illegal drugs

The possession, distribution or consumption of illegal drugs of any kind is strictly prohibited on company premises or at company workplaces.

Presence at work under the influence of alcohol or illegal drugs shall not be permitted.

• Prohibition of gambling and betting

Participation in any kind of betting using equipment or facilities owned by LEIALTA S.L.P. or its client partners, whether during or outside working hours, is strictly forbidden.

III. Procedure for establishing relationships with responsible stakeholders:

All stakeholders are key elements in achieving the results and reputation of LEIALTA S.L.P.. Relations with them must be transparent, honest, loyal, respectful and ethical.

Of particular importance are LEIALTA S.L.P.’s relations with suppliers and customers.

With clients and users, there will be a commitment to provide them with services of legal and business advice, project development, analysis and evaluations or opinions commissioned or requested, under high-quality standards and based on their business, personal or reputational needs, respecting their possible expectations.

With suppliers, purchasing decisions should be socially responsible and made on the basis of the quality of the products and on the basis of their Corporate Social Responsibility policies, together with any commitments they may have made in relation to the inclusion and integration of people with disabilities.

In this point LEIALTA S.L.P. assumes in a special way to favour the contracting with SOCIALLY RESPONSIBLE SUPPLIERS, linked to the figure of Special Employment Centres, with the aim of favouring the labour integration of people with disabilities. Thus, the company currently has as a social supplier a company qualified as a Special Employment Centre, linked to the provision of auxiliary and maintenance services, called PROLIMPIA INTEGRA -T.

IV. Procedure for avoiding conflicts of interest:

Conflicts of interest arise when a situation arises in which the interests of individuals, family members, or persons close to managers and employees diverge or are antagonistic to the interests of the company.

All actions or decisions in which an employee of LEIALTA S.L.P. participates must be oriented towards the objective of maintaining the continuity of the company and the achievement of an excellent reputation.

• Commitments to be made

There is an explicit limitation in relation to the performance of other duties, work or employment outside LEIALTA S.L.P.

In this sense, company ownership respects that its employees perform external activities or services, as long as they never involve totally unfair competition, a loss of efficiency or productivity in the workplace and that the organisation’s own means or resources, or the company’s or client companies’ time or facilities are not used for these purposes.

• Appropriate treatment of confidential information

If, for work-related reasons, confidential or privileged information is possessed, it must never be used for personal gain. If this situation is reliably demonstrated, it will give rise to the corresponding legal proceedings, as appropriate.

Professionals having access to such information may not carry out transactions based on such confidential information or transmit it to third parties for this or any other reason.

Confidential information shall be protected against inadvertent disclosure to outsiders.

In the event that confidential information is to be transmitted electronically, it must be duly protected under the internal guidelines set out in the security documents developed.

• Limitation on the acceptance of gifts or invitations

Under no circumstances may gifts and/or invitations be accepted from natural or legal third parties related to the company’s activities that could lead to a loss of independence in commercial relations with the different stakeholders, especially with customers or suppliers.

V. Validity:

All these procedures are in force as of 1 January 2016, until a new update is approved or they are repealed.

It will be reviewed periodically with the aim of adjusting its requirements to the reality of the company and its relationship with the environment and its stakeholders.

3. PROFESSIONAL ETHICS

LEIALTA S.L.P. is made up of highly experienced professionals, linked to the sectors of law, economics, taxation, and international taxation, who carry out their activity under the code of ethics that governs their professional activity.

LEIALTA S.L.P. assumes and fully respects the DEONTOLOGICAL CODES of the professionals who provide services in the firm and that in particular refer to the following:

1.Code of Ethics associated with the legal profession:

The lawyer is obliged to respect the ethical and deontological principles of the profession established in the General Statute of the Spanish Bar, approved by Royal Decree 658/2001, of 22 June, in the Code of Ethics approved by the Council of Bar Associations of Europe (CCBE) on 28 November 1998, and in the present Code of Ethics approved by the General Council of the Spanish Bar, in those approved by the Council of Bar Associations of the Autonomous Communities, and those of the specific Bar to which he/she belongs.

2. Code of Ethics associated with the profession of economist:

Established by the Plenary Session of the General Council of Economists’ Associations, CGCEE, held within the framework of the 1st Economists’ Forum (Madrid) on 29 September 2011. Text updated by approval of the Plenary of the CGCEE, in the framework of the II Forum of Economists on 15 November 2012 (Madrid).

The application of the Codes of Ethics will be reviewed periodically to align their requirements with those of our firm.