Ethical code

INTRODUCTION.

The purpose of the Ethical Standard or Code of Ethics is to establish the general guidelines that must govern the conduct of LAMAIGNERE and its employees in the performance of their duties and in their commercial and professional relations, acting in accordance with laws and regulations established in Spain and in third countries.

This Standard, together with other regulations and information such as the Instructions and Guidelines emanating from its Board of Directors and Management Committee, Annual Report and Annual Statement, Labor Policy, Manuals, etc., are the set of rules by which LAMAIGNERE governs all its actions according with a correct, transparent and socially responsible Corporate Policy.

This Code aims to serve as a guide for the corporate culture of LAMAIGNERE with the objective that all its employees will always act in accordance with the ethical norms and values of the company and could be aware of whether their behavior or that of the rest of the team is in accordance with the principles of the company.

Establishing a complete Code of Ethics allows all members of the LAMAIGNERE team to know, in every moment, the behavior expected of them, taking responsibility for their actions. In this way, it prevents the occurrence of defaults and speeds up the process of eradication of these behaviors.

Compliance program function related with this aspect is key, due to Compliance’s ability to avoid major evils begins long before they begin to occur, when the first evidence of behavior deviations is detected.

It will be in these types of situations when the Compliance Officer will receive the task of interpreting the concepts in an appropriate way. Occasionally, when necessary, it will be resort to the highest management levels of LAMAIGNERE.

THE BRAND.

LAMAIGNERE is a business group that offers logistics and transportation services of all kinds with the sole objective of facilitating and contributing to the success of its clients’ operations. To this end, it adapts its services to the specific needs of its clients and constantly innovates to carry out the implementation of new services that adapts to them.

GENERAL PRINCIPLES

LAMAIGNERE activities are governed by the principles of honesty, dignity, coherence and respect, guaranteeing the physical and moral integrity of the people who are related to the company. They also guarantee respect for applicable laws and internal policies, guidelines, procedures and instructions.

The user is the fundamental axis of the company, and therefore, LAMAIGNERE always works hard to offer its users advantages over the competition with products and services of high quality and absolute confidence. For this, it bets on innovation not only in the implementation of new services, but also in the improvement of the processes that make up its own activity and that of its customers.

The corporate culture of the company is based on participation and collaboration in the achievement of objectives, generating enthusiasm, shared knowledge and satisfaction with social relationships. The delivery of personnel and the contribution to teamwork are valued, encouraging the implication of achieving the best results for the company, above particular interests.

LAMAIGNERE works to generate value, encourage the initiative and perseverance, anticipates problems by seeking ethical solutions that are applicable, and achieves long-term results thanks to its discipline in planning-organization and implementation.

Care of the environment and the reasonable use of natural resources are a priority for LAMAIGNERE, so respectful behaviors have always been promoted among the staff. Likewise, the company is committed to its socio-economic environment, contributing permanently to the generation of wealth and employment in its different fields of activity.

AREA OF APLICATION.

This Code of Ethics is addressed to all people who work for the LAMAIGNERE Group, regardless of where they perform their work and their placed within hierarchy.

Besides, LAMAIGNERE intends to extend the respect to the given behavior guidelines, to all suppliers and partners that collaborate with the entity, through certain agreements by which they commit themselves to respect it.

STANDARS OF CONDUCT.

General principles which govern this code are the base for the establishment of the rules of conduct that all those who have any relationship with the Company are affected by. They are the following ones:

1. Respect for the dignity of people and their fundamental rights.

2. Respect for workers’ rights, equal opportunities and non-discrimination.

3. Occupational safety and health.

4. Respect for the brand image.

5. Money laundering, bribes and gifts.

6. Use of assets.

7. Protection of intellectual property.

8. Information management.

9. Conflict of interests.

10. Customer relations.

11. Relations with suppliers and collaborators.

12. Relations with authorities and officials.

13. Commitment to society and environment.

14. Reporting channel.

15. Disciplinary measures.

16. Implementation, communication and monitoring.

17. Validity.

1. Respect for the dignity of people and their fundamental rights.

LAMAIGNERE is committed to creating, maintaining and protecting, with all the means at its disposal, a work environment where the dignity and freedom of all the people who work for the company be respected.

Additionally, LAMAIGNERE is aware of the problem of sexual harassment and harassment due to sex in the work environment, not tolerating, under any circumstances, such behaviors.

Any type of harassment undermines the professional environment and influences the health, well-being and performance of the people who suffer from it. Therefore, any action or conduct of this nature is prohibited, being considered as improper behavior and labor infraction that gives rise to the sanctions established by the regulations in this regard.

The LAMAIGNERE government must promote a work environment without incurring discriminatory treatment, where its personnel receive fair and respectful treatment.

Consequently, LAMAIGNERE staff must work as a team, in a spirit of collaboration, respecting the dignity of others, and foster this corporate ethic, which includes actions such as:

• • Help other people in professional development.
  • Review the work of other people in an objective, sincere and conveniently documented manner.

• Treat fairly the opinions, concerns and complaints of other people.
• Assist in the complete knowledge of work standards, including policies and procedures to protect confidential information, as well as establish security measures in general

2. Respect for workers’ rights, equal opportunities and non discrimi nation.

In LAMAIGNERE, no form of illegal work is tolerated, being all workers protected by the rights set in the Workers’ Statute and other Agreements, as well as the rest of the regulations that apply to them according to their position in the organization.

In order that all workers are aware of the rights that protect them, and can carry out their work with all the required guarantees, at the beginning of the employment relationship, each person will receive the following information:

• Characteristics of his position and the tasks to be performed.
• Information regarding regulatory and remunerative elements regulated according to the applicable regulations, as well as those improvements that LAMAIGNERE makes available to employees for greater and better reconciliation of work, family life and personal life.
• Training in the field of Occupational Risk Prevention, as well as rules and procedures on risks, preventive measures and action in case of emergencies.
• Training in the field of information security.
• Training in relation to this Code of Ethics and crime prevention.

Recruitment and personnel selection processes, as well as the management of internal promotion and the development of professional careers, are carried out through procedures that guarantee equality, merit and capacity, without any exception for reasons of gender, ethnicity, sexual orientation or political or religious ideas. In the same way, the transparency, impartiality, professionalism, independence and discretion of the people who carry out the selection are ensured.

The job offers that are published are adjusted to the objective characteristics, requirements and conditions of the position, avoiding the use of words referring to the sex of the person, as well as the exclusion of issues that are not related with professional skills.

Selection processes are characterized by their adaptation to the functions or tasks to be carried out, as well as the tests, exams and the battery of questions that are used regularly in personal interviews.

LAMAIGNERE is conscious that training is a competitive advantage and an opportunity for professional and personal development of its employees, allowing to offer a high quality and innovative service to its customers and users.

Moreover, it is committed to the implementation of staff performance evaluation processes, understands it as an opportunity to establish a way of dialogue between the responsible persons and their personnel. In this way, the relationship is strengthened and serves as an instrument of motivation.

3. Occupational safety and health.

LAMAIGNERE is mindful of accidents at work and occupational diseases minimization, for which it assumes in the management of the organization and its workers the permanent dedication to achieve a high level of safety and health at work and working conditions, promoting continuously different initiatives aimed at its improvement.

In this line, tending to reduce risks for workers, LAMAIGNERE, has a culture of zero tolerance with the consumption of alcohol and drugs during the workday in any of its centers and equal for all employees, whatever their placed within the organization. All of that, with the aim of avoiding the endangerment of both the worker himself, as well as the rest of the users that relate to him and the company’s assets.

The company is especially concerned with dealing – with the intention of eliminating them – the risks arising from the storage and transfer of all types of merchandise, the risks of fire, toxicity, soil and water pollution, waste generation, and all those that may endanger the environment and human health and, consequently, entail the commission of crimes against the environment or public health.

These processes are perfectly structured and detailed by the organization, through the articulation of preventive and action rules, in strict compliance with current regulations, and implemented by the company itself, in order to eliminate risks.

4. Respect for the brand image.

LAMAIGNERE is a company which over its more than 100 years of experience has gained a position of relevance and strength in society and among companies in the sector.

Workers are responsible for preserving the prestige of LAMAIGNERE as a value that belongs to everyone, a distinction that is shared during the duration of the contractual relationship.

Consequently, workers are obliged to maintain maximum respect for the image of LAMAIGNERE, during working hours and also outside it. So, they should not get involved in any activity that could negatively affect the image of the company.

5. Money laundering, bribes and gifts.

LAMAIGNERE does not accept that, within its organization, irregular payments or money laundering are carried out, so it has procedures and measures to avoid it and by means of which it can detect the possible responsible parties.

Through this control, LAMAIGNERE carefully analyzes economic transactions that, due to their nature or amount, may be suspicious. Employees must collaborate in these tasks, informing immediately of any irregularity or unusual behavior that they could detect.

LAMAIGNERE workers will not participate in bribes, concessions of benefits or advantages of any nature that can be understood to be improperly affecting the normal development relationships in which LAMAIGNERE participates.

LAMAIGNERE staff will not request, accept or receive from any person or entity, payments, gifts, attentions, or favors that are outside the lawful uses of the market, and are – or could be understood to be – aimed at influencing the normal development of commercial, administrative or professional relations in which LAMAIGNERE is involved. And in any case, they have the obligation to inform about the behaviors of this type that they are aware of.

6. Use of assets.

LAMAIGNERE is a company that makes available to its staff the appropriate material and resources to carry out the assigned work. It is essential for the correct running of the company that all employees make responsible use of them.

The computer and communications resources will be used for tasks related to their purposes and according to the position of each employee. Its use must be limited and in accordance with the other policies described in this Code. The behavior on the internet and in the use of email services must be based on the principles of ethics, respect for people and current legislation. It is prohibited any illegal or irresponsible activity or that harms the image of LAMAIGNERE.

The same will happen with logistic and transport resources, which in no case can be used for tasks different than those assigned by LAMAIGNERE and in a reckless or careless manner.

People employed in LAMAIGNERE are required to read and comply with the policies contained in the procedures developed for this purpose.

7. Protection of intellectual and industrial property and trade secret.

LAMAIGNERE respects the protection of intellectual property, industrial and their own commercial secrecy and that of other companies.

Employees must verify, before making use of the mentioned rights, that LAMAIGNERE has a license or authorization that allows it.

8. Information management.

LAMAIGNERE is committed to respecting the privacy of all confidential information to which it has access, as well as the identity of the subjects involved.

To achieve this goal, it is essential that LAMAIGNERE staff know and comply with the company’s privacy policies to adequately protect all types of confidential information that may have been accessed.

In addition, LAMAIGNERE is obliged to respect the legislation on the Protection of Personal Data. In accordance with said legislation, any person can exercise their rights of modification, cancellation and opposition, in the way established by regulation.

LAMAIGNERE uses information from companies in the sector in order to compete successfully in the market. The information obtained on these companies must be carried out through market research, evaluation of products and services and study of public documents, never attempt to obtain information by inappropriate or illegal means.

In this sense, if a worker receives information from any competing company that thinks it could be classified as confidential, he must contact the corresponding LAMAIGNERE Management to determine the appropriate process.

As for the external communications of information, they will always be consistent and precise, both to comply with legal and regulatory obligations, and for the reputational image of the brand. In this line of action, for LAMAIGNERE it is essential to make its communications with total transparency and provide, in any case, complete, honest and accurate information.

The statements made by LAMAIGNERE staff related to products and services, including, but not limited to, press releases, in meetings with customers and users and in the various presentations that may be made of the company, will be current, precise and not misleading or false, as well as maintaining high levels of credibility of LAMAIGNERE in the market and preventing unintended contractual obligations from occurring.

The records and documents owned by LAMAIGNERE are kept and destroyed in accordance with the record keeping policies.

9. Conflict of interests.

A conflict of interest arises in any situation where there is a potential division of loyalties between personal interests and obligations towards LAMAIGNERE.

Consequently, all LAMAIGNERE collaborators have responsibility to safeguard the integrity of business decisions and ensure that they are taken on the basis of what is best for the entity, without their personal interests influencing them.

Due to an activity that constitutes a real conflict of interest is never acceptable, activities that may even appear to conflict should be avoided, as well as using other people to indirectly carry out an inappropriate activity.

Although it is difficult to describe the different ways in which a conflict may arise, one or more of the following situations are often included:

• Participation in other companies’ activities.
• External commercial interests.
• External employment.
• External investments
• Business relationships with family or friends.
• Do not use the representation of LAMAIGNERE in organizations whose objective is not related to the company.

Before initiating an activity that may constitute a potential conflict of interest, the situation must be communicated in writing to the corresponding LAMAIGNERE Director and await for approval.

10. CustomerCustomer relations.relations.

The satisfaction of its customers and users is a priority aspect in the activities of LAMAIGNERE, so the company works diary to make available a wide infrastructure and organization, led by a team of professionals.

The guarantee of more than one hundred years offering services cosign the activity of the company, but especially the trust of its customers is what allows it to continue growing.

Different certifications support the quality of the comprehensive range of international logistics and freight services by land, air and sea that have been offered by LAMAIGNERE since 1908.

LAMAIGNERE is committed to providing quality services, in time and price rather than competitive, in order to increase the degree of satisfaction of its customers and users. LAMAIGNERE Management assumes responsibility for maintaining and improving the Quality System that guarantees the supplied services and products.

LAMAIGNERE employees equally assume the quality promise of the products and services provided, in accordance with the stablished guidelines in the different quality standards that the company has endowed, from which the following general ideas are extracted:

• It is the responsibility of each and every person in the organization, the task of improving the quality of service and customer satisfaction.
• Consider the improvement of quality as a continuous process.
• Know and promulgate, in an understandable way, the Quality Standards.
• Participate in improvement programs, which are managed by the respective quality managers.
• Maintain continuous contact with customers and users, so that this allows to know their needs and expectations, and, therefore, they can be satisfied.

11. Relations with suppliers and collaborators.

LAMAIGNERE is faithful with stable suppliers and collaborators, based on trust, transparency, the highest quality mutual requirement, and above all the continuous dedication to innovation and the improvement of services.

Therefore, collaboration with suppliers and partners has to be conceived throughout the organization as a common business, in which everyone participates to provide the best possible service to the customer and from which everyone benefits.

Likewise, LAMAIGNERE is obligated to choice suppliers and collaborators who make commitments regarding compliance with the essential aspects of this Code and, in no case, will opt for those who are disrespectful of Human Rights and the Protection of the Environment and that do not adjust their activity to certain ethical standards. 12. Relations with authorities and officials.12. Relations with authorities and officials.

12. Relations with authorities and officials.

Transport and logistics activities performed by LAMAIGNERE imply constant relations with the authorities and public institutions of the countries in which the company carries them out.

LAMAIGNERE employees, who, in the performance of their work, must relate to these authorities and public institutions will always do so in a lawful and respectful manner, avoiding any corrupt activity.

It is expressly forbidden to offer, request or accept gifts, favors, or any kind of benefit from those authorities.

It will be the worker who, by the circumstances of each case, assess whether isolated gifts or attentions of little value can be consider as a normal event in local practice, always taking into account the good reputation of the company. In case of doubt, you will always consult with a superior before accepting it.

In no case, employees can accept any type of tax advantage for the company. Employees who because of their role in the entity assume any functions related with these activities, will pay special attention to the accuracy and veracity of the tax information that is declared.

13. Commitment to society and the environment.

For LAMAIGNERE, the care of the environment and the reasonable use of natural resources based on international ISO standards are a priority, so respectful behaviors have always been promoted between the staff. Among all the actions aimed in this regard, the following stand out:

• LAMAIGNERE is committed to using a good environmental practices system by creating energy saving systems in computer equipment, intelligent lighting systems, monitoring and analysis of air conditioning tools, electricity, water and gas supply, integrity of the different systems and supply networks (data center, incidents, alarms, etc.), automatic shutdown of computers, shutdown of lights and air conditioners when they are not necessary and optimization and use of natural light.
• LAMAIGNERE encourages paper saving and responsible consumption of it, reuse as much as possible, use of appropriate bins, segregation and recycling, use of email to attach documents, use double-sided printing / two pages per sheet , use of screen display modes, treatment of documentation in digital format and review the status of photocopiers.
• LAMAIGNERE encourages the use of electronic services in communications: web elements (chats, forums, wikis) and emails, avoiding unnecessary displacements.
• In its usual transport and logistics activities, LAMAIGNERE, strives to reduce the environmental impact through efficient use of its facilities, equipment and means of transport. It is the company’s priority to provide the existing equipment in the market that generates less environmental impact.

Moreover, LAMAIGNERE intends to create this environmental awareness among its workers beyond the respect of these guidelines in the workplace, encouraging them and actively participating in activities that pretend to do so.

Besides, LAMAIGNERE is devoted to its socio-economic environment and tries to permanently contribute to the generation of wealth and employment in its different fields of activity. Its business policy includes objectives for the creation of quality employment and the reasonable use of the economic resources used in its activity.

LAMAIGNERE support the fostering of collaboration and community protection, promoting social actions, such as sponsorship and volunteering in organizations of social interest.

This objective is materialized in LAMAIGNERE Foundation that was born in 2017 as a result of the firm desire that the logistic group has always had, to contribute to the progress of people, integrate society into a better world that aid the most disadvantaged and pool all available means and resources to achieve those goals that are full of maximum ambition and enthusiasm.

14. Reporting channel.

With regard to the communication of defaults, LAMAIGNERE has established a reporting channel accessible from the company’s website (https://www.lamaignere.com/es/es/canal-de-denuncias) which aims to establish a mean of communication so that any person (whether employee, client, business partner, supplier) can report those behaviors contrary to the legislation, to this Code of Ethics or to the internal procedures of LAMAIGNERE, guaranteeing confidentiality and anonymity.

15. Disciplinary measures.

The violation or breach of the provisions contemplated in this Code or in the internal policies, protocols, procedures or standards of LAMAIGNERE, and the realization of any criminal act in the exercise of work activities, suppose the commission of an infraction of the labor relationship that will involve the adoption of appropriate disciplinary measures.

Disciplinary sanctions will be imposed in accordance with the principles of proportionality and guilt, through a procedure in which the offender can exercise his or her rights of defense effectively.

16. Implementation, communication and monitoring.

This Code of Ethics will be implemented in such a way that all employees can know and understand its content, making available to all of them the required means to do so, including, if necessary, training tasks and enquiry channels.

Regulatory and this Code compliance is extremely important for the proper functioning of the company, so it is essential to establish internal control measures to ensure it.

The control tasks will be carried out by various mechanisms, so LAMAIGNERE is obliged to establish material resources that allow the reporting of real or imminent breaches in a confidential manner.

Compliance with the Code of Ethics is subject to the corresponding disciplinary regime applicable in accordance with labor regulations, without prejudice to the applicability of criminal regulations.

17. Validity.

The Code of Ethics will enter into force on the day of its publication to all employees and will be in effect as long as its repeal is not approved. It will be reviewed and updated periodically and, where appropriate, the necessary policies, processes and controls will be reviewed, updated or implemented. In order to this aim, the suggestions and proposals made by the employees and the commitments taken by LAMAIGNERE regarding ethics and compliance will be kept in mind.