CORPORATE RESPONSIBILITY POLICY

The corporate responsibility policy of MENAES S.L. It has been prepared by the Company's Management in order to establish the principles and framework foundations that will allow employees and managers to have a clear reference in the issues that shape it. In particular, the corporate responsibility policy of MENAES S.L. It is structured around three sections: the employee code of conduct, the anti-bribery policy and the policy of ethical escalation (reporting of irregularities).

I. CODE OF CONDUCT OF THE EMPLOYEES OF MENAES, S.L.

The present Code of Ethics and Professional Conduct seeks to establish expectations regarding the fundamental principles of behavior that we place in the team of professionals that make up our company. It therefore states the ideals of behavior to which we aspire, as well as the practices that are considered obligatory in our performance as professionals.

The taking of our decisions, which in turn motivate our actions, is based on a set of principles and values; among them, those that we consider to be the most important will be those that will structure this code: responsibility, competence, respect and equity. This Code is articulated around these four values.

1. Responsibility

The workers of MENAES S.L. We are responsible with

- the performance of our functions and the interests of our business,

- the expectations of our customers and the quality of our products,

- compliance with internal guidelines, legal obligations and the principles of the United - - - - -   - Nations Global Compact.

And we will act with maximum commitment in the exercise of those competencies that have been attributed to us for the reason of the position, putting into practice criteria that lead to greater efficiency, satisfaction of our clients and always following the guidelines, guidelines and regulations that are, in each case, the pertinent ones.

2. Competition and desire for improvement

All workers of MENAES S.L. We are competent and strive to develop the functions for which we are responsible, however difficult they may be, whatever our position in the organization chart of the company. We could all be better, even so all workers recognize the competence and importance of the work of our colleagues and, since we live in a changing reality, we assume the need to adapt our skills and continuous improvement. We believe and we all commit ourselves, therefore, in a way to do better, individually and collectively, which must undoubtedly lead to the virtuous spiral of continuous improvement.

3. Respect and solidarity

We are aware of the importance of working as a team, it is one of the keys to the success of any project. All workers of MENAES S.L. We base our professional relationships on a deep mutual respect, individual and collective, moral and physical. We defend the right to integrity and honor of the people, and we are respectful of the will and the right of personal privacy. We do not tolerate harassment or any other form of less price in our work environments.

The comments and affirmations, as well as the way of thinking of the workers of MENAES S.L. they are coherent and always reasonable, given the level of information that we each have. There will always be, therefore, a reasonable explanation in the decisions of our colleagues, although sometimes we do not understand it.

We care about each other's feelings and we are jointly and severally concerned with the personal and professional well-being of our colleagues.

4. Equity

Equity refers to our duty to make decisions and act impartially, objectively and transparently. It has to do with receiving and dispensing fair treatment, with equal opportunities; it has to do with the right of everyone to receive and give according to equal criteria, with no place for personal considerations or favoritism. In MENAES S.L. we believe in a well-understood equity culture, where the reasonable is imposed on the capricious.

Fairness and justice, in a broad sense, has to do with respect for what is right, with the duty of compliance with the given word, compliance with the rules. It is also respect for the dignity of people, their privacy, non-discrimination because of gender, sexual identity, disability or place of origin. We detest all forms of corruption and abuse of a dominant position as well as preserve confidential information from all sources (personnel, professionals, customers and suppliers).

II. ANTI-BRIBERY POLICY

All workers of MENAES S.L. We will base our professional / business decisions for the sole benefit of MENAES, S.L., without any room for personal interests of our own. To avoid conflicts of interest or loyalty, the following rules must be followed:

1. Duty of information. The employee must communicate to his immediate superior any personal interest (including that of relatives or personal friends) that in relation to the fulfillment of his business functions may exist. The attempts of other companies, with which we can maintain commercial relations, to influence the workers of MENAES S.L. or to your family or friends through gifts or benefits must be communicated without delay.

2. Gifts, favors or other forms of benefit. The workers of MENAES S.L. they can not accept or offer any type of present that can be considered as an excess in the usual business and courtesy relationships. Gifts with a market value clearly above € 100 or cash are expressly forbidden. In any case, it is required for all employees the duty of information to direct superiors.

3. Transparency in the award of works, orders or contracts. No employee of MENAES S.L. may award works, orders or contracts to companies related to himself, family or friends (in which there is ostentation of ownership or representation) without prior authorization of the manager of its functional area, or promote a work, order or contract is awarded .

4. Prohibition of competition. No worker of MENAES S.L. You can run a company, participate or work in any way in a company that is totally or partially in competition with MENAES, S.L.

5. Jobs and other forms of participation in other companies. The workers of MENAES S.L. they may freely work or maintain control / representation of other companies as long as there is no possible conflict of interest with the interests of MENAES, S.L. In any case, any additional professional or commercial relationship that may have workers MENAES S.L. must be communicated as soon as possible to the HR department of the company.

III. ETHICAL SCALING POLICY

1. Compliance with the Code of Conduct and Anti-bribery Policy

The provisions included in the code of conduct and anti-bribery policy apply to all workers of MENAES, S.L. without exception, and must be considered as a contractual obligation on the part of all workers. All workers must read this document with the aim of being able to align their behavior according to the principles and values ​​that are exposed.

The management of the company will be responsible for ensuring the distribution of this document to all workers of MENAES S.L. as well as ensuring that all doubts that may arise from any worker are clarified.

2. Scheduling and reporting

Any complaint regarding the breach of the Code of Conduct and / or Anti-bribery Policy must be carried out in writing through the person in charge immediately or through the person in charge of HR.

Any complaint filed will be associated with an objective investigation by the company through ordinary internal procedures.

In accordance with legal requirements, the information will be treated confidentially. The complainants may not suffer any unjustified disadvantage as a result of their complaints.

 

Miguel Almendro Pineda

Dirección General

Granollers, Febrero 2019