Ethical Code

Index:

1. Definition and Purpose of the Code of Conduct and Responsible Practices
2. Scope of Application
3. General Principles
4. Commitments
4.1. Compliance with Applicable Legislation and Internal Regulations
4.2. Compliance with Agreements and Conventions
4.3. Relations with Employees
4.4. Relations with Clients
4.5. Market Practices
4.6. Relations with Suppliers
4.7. Political Neutrality
4.8. Conflicts of Interest and Loyalty to the Company
4.9. Engagement in Other Activities
4.10. Use of Company Assets and Services
4.11. Confidentiality of Information and Personal Data Protection
4.12. Protection of Intellectual and Industrial Property
4.13. Corruption and Bribery
4.14. Recording of Operations
4.15. Money Laundering and Irregular Payments
4.16. Social and Environmental Commitment
5. Compliance with the Code and the Ethics Committee
6. Publicity of the Code

Annex I

Definition and Purpose of the Code of Conduct and Responsible Practices

DERCOSA’s Ethical Code establishes the action criteria, principles, and attitudes the company must have in the performance of its professional responsibilities.

The Ethical Code (hereinafter referred to as the Code) aims to ensure professional and ethical behavior, consolidating a culture and standards of conduct that are shared, accepted, and respected by all its employees. It will be the foundational element of its corporate culture. To this end, the principles and values that should govern relations with employees, clients, shareholders, partners, suppliers, etc., are defined.

The Ethical Code is mandatory. All DERCOSA employees are required to comply with the Ethical Code and to report, using the channel provided by the company, any practices contrary to it and the rules on which it is based that they may observe. To this end, the company has established a procedure, led by the Ethics Committee, that allows its employees to confidentially report any irregularities or misconduct observed.

Thus, the Code:

Facilitates the knowledge and application of DERCOSA’s corporate culture, based on the respect for human and social rights, and the effective integration of all employees into the company, respecting their diversity.

Applies the principle of due diligence for the prevention, detection, and resolution of irregular conduct related to criminal offenses or any other nature. In this regard, the company understands that the aforementioned principle commits it to regularly analyze risks in this area, ensure that employees know what is expected of them, define responsibilities regarding compliance with the Code, and establish a channel for the notification and prompt resolution of irregularities. The company has procedures in place to address these elements.

Scope of Application

This Ethical Code is directed at all administrators, executives, and employees (hereinafter generically defined as «persons» or «employees») of the DERCOSA company, regardless of the contractual modality that determines their employment relationship and the position they hold.

Additionally, the application of the Ethical Code may be extended to any person or organization linked to DERCOSA when circumstances warrant and the nature of the relationship allows.

When discrepancies arise between local norms, laws, and regulations and this Ethical Code, employees will preferably apply the stricter norm.

All employees are responsible for knowing and complying with laws relevant to their function, responsibility, and workplace. In any case, DERCOSA will provide the necessary means for them to know and understand the local legislation relevant to their professional functions.

In case of doubt, DERCOSA employees can seek help through their immediate superior and other means established for the dissemination, knowledge, and compliance of this Ethical Code detailed below.

DERCOSA will provide employees with the necessary means to comply with and contribute to the principles of action contained in this Ethical Code.

General Principles

The Ethical Code is a commitment that includes principles and basic standards for the proper development of relationships between DERCOSA and its main stakeholders wherever it conducts its business activities.

The Code is based on the following principles:

All DERCOSA operations will be conducted under an ethical and responsible framework.
Compliance with current legislation will be applicable in this Code.
The behavior of DERCOSA employees will adhere to this Code of Conduct and Responsible Practices.
All individuals, both physical and legal, maintaining a direct or indirect employment, economic, social, and/or industrial relationship with DERCOSA, will be treated fairly and with dignity.
All DERCOSA activities will be carried out in the most environmentally respectful manner, promoting biodiversity conservation and sustainable management of natural resources.

Employees

DERCOSA does not employ anyone under the age of 16.
No employee at DERCOSA will be discriminated against based on race, physical disability, illness, religion, sexual orientation, political opinion, age, nationality, or gender.
DERCOSA prohibits all forms of physical, sexual, psychological, or verbal harassment or abuse of its employees, as well as any other conduct that could create an intimidating, offensive, or hostile work environment.
DERCOSA employees have the right to unionize, freedom of association, and collective bargaining.
Weekly working hours and overtime will not exceed the legal limit established by law. Overtime will always be voluntary and compensated in accordance with the law.
The salary received by DERCOSA employees is in line with the function performed, always respecting agreements.
All DERCOSA employees perform their work in safe and healthy environments.

Clients

DERCOSA is committed to offering all its clients a high standard of excellence, quality, health, and safety in its products, and to communicating with them clearly and transparently. These products will be ethically and responsibly produced.

Shareholders

DERCOSA conducts its activities in accordance with social interest, understood as the viability and maximization of the company’s long-term value in the common interest of all shareholders.

Business Partners

DERCOSA extends the obligation to comply with this Code to its business partners.

Suppliers

The suppliers of the products used by DERCOSA are required to comply with this Code as applicable. They must also allow any review by DERCOSA or authorized third parties to verify compliance.

Society

DERCOSA is committed to collaborating with the local, national, or international communities where it conducts its business.

Commitments

4.1. Compliance with Applicable Legislation and Internal Regulations

Regulatory compliance is a necessary prerequisite for this Code. All DERCOSA employees must comply with current legislation. The application of the Code shall in no case imply a breach of the legal provisions in the countries where DERCOSA operates.
All DERCOSA employees must comply with the company’s rules and procedures, as well as any instructions that may be approved in their development.
Any other local Codes of Conduct that may exist must align and adapt to the criteria established in this Code, which will prevail over any other internal regulations unless they are stricter. To facilitate proper internal control, DERCOSA employee decisions will be traceable from a compliance perspective, so that the adequacy of decisions to internal and external norms is justifiable, verifiable, and reviewable by competent third parties or the company itself.
DERCOSA is committed to providing the necessary means for its employees to know and understand the internal and external regulations necessary for the exercise of their responsibilities.
In the event of non-compliance with the Code, the company has a consultation and notification procedure that allows any person related to it to confidentially report any irregularity that, in their opinion, constitutes a violation of the Code.

4.2. Compliance with Agreements and Conventions

DERCOSA assumes, as part of its internal regulations, the content of the agreements and conventions, national or international, to which it has adhered, committing to their promotion and compliance.
The current agreement is attached to this Code in Annex I, which will be permanently updated.

4.3. Relations with Employees

Respect Among Individuals
At DERCOSA, human resource management and employee relationships are always based on respect for individual dignity and are founded on principles of mutual trust and respect.
The company expressly prohibits abuse of authority and any form of harassment, whether physical, psychological, or moral, as well as any other conduct that could create an intimidating, offensive, or hostile work environment for individuals.
All DERCOSA employees must treat each other with respect, professionalism, and kindness, fostering a pleasant, rewarding, and safe work environment that encourages individuals to give their best. Similarly, relationships between DERCOSA employees and those of collaborating companies will be based on the aforementioned criteria, professional respect, and mutual collaboration.
The company expressly prohibits its employees from consuming alcohol and illegal substances that may hinder the fulfillment of their assigned professional responsibilities. Smoking is prohibited throughout the company.
DERCOSA employees will exercise due diligence and control to avoid cases where irregular workers are collaborating with the company and to prevent the illegal employment of foreign workers. Likewise, as the Ethical Code extends to them, suppliers, contractors, and other collaborating companies will also be obligated to avoid the aforementioned bad practices.

Professional Development, Equal Opportunities, and Non-Discrimination
DERCOSA guarantees equal opportunities and is committed to providing the means to help its employees develop both professionally and personally.
The company does not tolerate any form of discrimination based on gender, race, sexual orientation, religious beliefs, political opinions, nationality, social origin, disability, or any other circumstance that could be a source of discrimination.
DERCOSA supports and is committed to implementing and developing public policies aimed at promoting greater equal opportunities and fostering a culture of merit-based reward.
Selection and promotion decisions at DERCOSA will always be based on merit and circumstances and evaluations of an objective and transparent nature. The company’s employees will be aware of the methodologies and procedures used for professional development and advancement in the company.
DERCOSA is also committed to providing the means to contribute to the learning and training of its employees and to updating their knowledge and skills to foster their professional progress and add more value to customers, shareholders, and society in general.
Likewise, DERCOSA understands the importance of the balance between personal and professional life for the integral development of the person, and therefore will promote measures and develop actions that help its employees achieve this balance.

Teamwork, Collaboration, and Dedication
DERCOSA considers collaboration, teamwork, and the search for synergies as prerequisites for achieving its goals and maximizing its capabilities, resources, and the diversity of knowledge, skills, and experiences integrated into the company.
Therefore, DERCOSA promotes, facilitates, and encourages collaboration and teamwork among individuals within the company and between different units and sections of the company.
All employees must act with a spirit of collaboration, making their knowledge, skills, and talents available to those who need them to contribute to the achievement of DERCOSA’s overall goals and interests.
DERCOSA employees work efficiently, making the most of the time and resources the company provides.
To stimulate loyalty, satisfaction, and pride of belonging, the company is committed to dedicating resources and developing initiatives and actions that promote cultural cohesion within the organization.

Health and Safety of Individuals
DERCOSA provides the necessary means to ensure, starting from strict compliance with applicable regulations, a healthy and safe work environment for its employees. The company is also committed to continuously improving occupational risk prevention and health promotion measures in each section.
Likewise, DERCOSA also promotes and encourages the adoption of advanced safety and health practices among its suppliers, contractors, and generally collaborating companies.
All employees are responsible for strictly observing health and safety regulations at work, ensuring their own safety and, in general, that of all individuals who may be affected by their activities.
Similarly, employees must responsibly use the equipment assigned to them when performing risk activities and will share knowledge and practices on safety, health, and risk prevention with their colleagues and subordinates. For its part, DERCOSA is committed to providing its employees with the necessary resources and knowledge to perform their duties safely and in a healthy environment.

4.4. Relations with Clients

All employees are required to act, in their relations with clients, according to criteria of consideration, respect, and dignity, taking into account the different cultural sensitivities of each person and not allowing discrimination in treatment based on race, religion, age, nationality, gender, or any other personal or social condition prohibited by law, with special consideration for the attention of people with disabilities.
DERCOSA acts with the aim of offering the highest levels of quality and with the aspiration of achieving excellence in the production of its products.
For this reason, it provides its employees with the necessary means to carry out their activities in such a way as to meet the expectations of the company’s clients.
DERCOSA will make a special effort to anticipate the needs of its clients to bring better and more tailored products to the market.
Employees will also avoid any form of misleading, fraudulent, or malicious conduct that leads to obtaining inappropriate advantages over clients.
In their commercial activities, employees will promote the organization’s products based on their quality, according to objective standards and without providing false information about the competition.

4.5. Market Practices

DERCOSA competes in the market fairly and does not tolerate any form of misleading, fraudulent, or malicious conduct.
All DERCOSA employees are committed to free competition and compliance with established laws in the various countries where they operate, avoiding any actions that constitute abuse or illicit restriction of competition.
Likewise, they will refrain from engaging in misleading advertising about the company’s activities.
Thus, DERCOSA employees will compete in the market fairly, and will not accept misleading, fraudulent, or malicious practices or conduct that lead to obtaining inappropriate advantages in the market.
Employees will exercise due internal control to ensure that, within their areas of influence, the commitments made regarding the characteristics of the products delivered are met.
In their commercial activities, DERCOSA employees will promote the company based on objective standards, without distorting the characteristics or conditions of the products they deliver. All promotional information from the company will be presented clearly to avoid providing information that could mislead. DERCOSA employees will not distort the characteristics of the products offered by the company or mislead about their characteristics.
The search for commercial or market information by DERCOSA employees will always be conducted without violating the rules that may protect it. Employees will reject information about competitors obtained improperly or violating the confidentiality under which it is maintained by its legitimate owners. In particular, special care will be taken not to violate trade secrets in cases of professionals joining DERCOSA from other companies in the sector.
The company’s employees will also avoid spreading malicious or false information about the company’s competitors.

4.6. Relations with Suppliers

DERCOSA considers its contractors, suppliers, and generally collaborating companies indispensable for achieving its growth and development objectives.
DERCOSA employees will engage with their suppliers of goods and services in a lawful, ethical, and respectful manner.
The company is committed to practicing its principles in its relationships with collaborating companies and actively working to convey its principles of action to them. The company will also promote and encourage collaboration with suppliers and contractors that demonstrate advanced social, environmental, and ethical standards.
All DERCOSA employees involved in selecting contractors, suppliers, and external collaborators are required to act impartially and objectively, applying transparent criteria and strictly and without exception complying with DERCOSA’s internal regulations.
DERCOSA will promote and disseminate the content and principles of this Ethical Code among its suppliers and contractors. In particular, those contents that explicitly refer to the company’s relationship with its collaborating companies.
No DERCOSA employee may offer, grant, request, or accept, directly or indirectly, gifts or gratuities, favors or compensations, in cash or in kind, of any nature, that could influence the decision-making process related to the performance of their duties.
Any gift or gratuity received contrary to this Code must be immediately returned and this circumstance communicated to the Ethics Committee. If it is not reasonably possible to return the gift or gratuity, it will be delivered to the Corporate Social Responsibility department, which, after issuing the corresponding receipt, will allocate it to social interest purposes.

4.7. Political Neutrality

DERCOSA conducts its business model without interfering or participating in the political processes of the countries and communities where it operates.
Any relationship DERCOSA has with governments, authorities, institutions, and political parties will be based on principles of legality and political neutrality.
DERCOSA recognizes its employees’ right to exercise their freedom of expression, political thought, and, in general, participation in public life, as long as it does not interfere with the performance of their duties in the company, is conducted outside working hours and any DERCOSA facilities, and always in a way that an external observer could not associate DERCOSA with any particular political option.

4.8. Conflicts of Interest and Loyalty to the Company

Conflicts of interest arise in circumstances where DERCOSA employees have other interests that conflict with those of the company, potentially interfering with their duties or leading them to act for motivations other than the proper fulfillment of their responsibilities in the company.
The relationship between DERCOSA and its employees must be based on the loyalty that comes from common interests. In this sense, the company respects its employees’ participation in other financial or business activities, provided that internal regulations do not prohibit it, such activities are legal, and they do not conflict with or create potential conflicts of interest with their responsibilities as DERCOSA employees.
All DERCOSA employees must avoid situations that could constitute a conflict between their personal interests and those of the company. Therefore, they should refrain from representing it, intervening, or influencing management and decision-making processes in which, directly or indirectly, they themselves or a third party close to them have a personal interest.
Any employee who believes there is a potential conflict of interest must inform their immediate superior and the Ethics Committee. The superior must inform the Ethics Committee of the measures taken or to be taken to avoid the conflict.
The Ethics Committee will assess the effectiveness of the proposed measures and, in case of disagreement, will inform the superior of the measures that must be adopted.

4.9. Engagement in Other Activities

DERCOSA employees may only engage in labor and professional activities outside DERCOSA when they do not compromise the expected efficiency in the performance of their duties. Any external labor or professional activity that may affect the company’s workday must be previously authorized by the Ethics Committee.

4.10. Use of Company Assets and Services

DERCOSA employees will efficiently use the company’s assets and services and will not use them for personal gain.
In this regard, DERCOSA employees will not use the equipment provided by DERCOSA to install or download programs, applications, or content whose use is illegal, contravenes company rules, or could harm its reputation. They will also not use company funds or cards to pay for activities unrelated to their professional activity.
Employees must be aware that documents and data contained in DERCOSA’s IT systems and equipment may be subject to review by competent company units or designated third parties when deemed necessary and permitted by current regulations.

4.11. Confidentiality of Information and Personal Data Protection

DERCOSA personnel are obliged to protect the information and knowledge generated within the organization, owned by or under the custody of the company.
Employees will refrain from using any data, information, or documents obtained during their professional activities for personal gain. They will also not communicate information to third parties, except in compliance with applicable regulations, company rules, or when expressly authorized. They will not use confidential data, information, or documents from a third company without written authorization.
DERCOSA personnel commit to maintaining confidentiality and using any data, information, or documents obtained during their responsibilities in the company according to internal regulations. Generally, and unless otherwise indicated, the information they have access to should be considered confidential and may only be used for the purpose for which it was obtained.
Employees will not make duplicates, reproduce, or use the information more than necessary for their tasks and will not store it in information systems not owned by DERCOSA, except in expressly authorized cases.
The obligation of confidentiality will remain even after leaving DERCOSA and will include the obligation to return any material related to the company that the employee possesses at the time of termination of their relationship with the company.
DERCOSA personnel must respect the personal and family privacy of all individuals, whether employees or others, whose data they have access to. Authorizations for the use of data must respond to specific and justified requests. DERCOSA employees must strictly comply with internal and external regulations established to ensure the proper treatment of information and data provided to the company by third parties.
In collecting personal data from clients, employees, contractors, or any person or entity with whom a contractual or other relationship is maintained, all DERCOSA personnel obtain the necessary consents and commit to using the data according to the purpose authorized by the consent giver. They must also know and respect all internal procedures regarding the storage, custody, and access to data intended to ensure the different levels of security required by their nature.
Employees will report any incidents related to information confidentiality or personal data protection to the relevant department or area.

4.12. Protection of Intellectual and Industrial Property

DERCOSA employees are committed to protecting both their own and third-party intellectual property, including, among others, patent rights, trademarks, domain names, reproduction rights (including software reproduction rights), design rights, database extraction rights, or technical expertise.
In their dealings with third parties, DERCOSA employees will scrupulously follow the rules and procedures regarding the protection of intellectual and industrial property to avoid infringing third-party rights.

4.13. Corruption and Bribery

DERCOSA understands corruption as the use of unethical practices to obtain some benefit. Corruption constitutes one of the categories of fraud.
DERCOSA employees will never resort to unethical practices to influence the will of individuals outside the company to obtain some benefit for the company or themselves. They will also remain vigilant to prevent cases where other individuals or organizations use these practices in their relationship with the company.
In their dealings with public authorities and institutions, DERCOSA employees will act lawfully and in line with international provisions for the prevention of corruption and bribery.
DERCOSA employees who maintain relationships with public administrations must document the decisions made and ensure they comply with the company’s established regulations. This is to facilitate, if necessary, the review of their decisions by third parties.
DERCOSA expressly prohibits non-contractual or illicit payments to any person or entity, public or private, to obtain or maintain business or other benefits or advantages.
The company also prohibits taking advantage of personal relationships with public officials to obtain undue benefits.
DERCOSA employees may not make, offer, or receive, directly or indirectly, any payment in kind or other benefit that, due to its value, characteristics, or circumstances, may reasonably alter the development of commercial, administrative, or professional relationships in which they are involved. Cash gifts or equivalents are expressly prohibited.
Thus, gifts and courtesies must be reasonable, transparent, and legitimate, and received or given exclusively for legitimate organizational interests. They must also be sporadic to avoid regularity that could generate suspicion about their ultimate purpose.
No DERCOSA employee may offer, grant, request, or accept, directly or indirectly, gifts or gratuities, favors or compensations, in cash or in kind, of any nature, that could influence the decision-making process related to the performance of their duties.
Any gift or gratuity received contrary to this Code must be immediately returned and this circumstance communicated to the Ethics Committee. If it is not reasonably possible to return the gift or gratuity, it will be delivered to the Corporate Social Responsibility department, which, after issuing the corresponding receipt, will allocate it to social interest purposes.
Additionally, gifts and courtesies should be socially acceptable so that their public knowledge does not cause discomfort to the recipient or the giver. The company understands that the maximum value of gifts or courtesies given should not exceed 100 euros, an amount that may be periodically reviewed by the Ethics Committee.
Furthermore, invitations to foreign clients to visit Spain must be authorized by the Manager.
In cases where DERCOSA hires third parties to develop the company’s business in third countries, these third parties must formally assume the commitments of conduct outlined in DERCOSA’s Ethical Code, especially regarding relationships with clients and suppliers.
If there is any doubt about the acceptability of practices in this area, employees should consult with the Ethics Committee.

4.14. Recording of Operations

All economically significant operations carried out by the company will be clearly and accurately recorded in appropriate accounting records that faithfully represent the transactions made and will be available to internal and external auditors.
DERCOSA employees will enter financial information into the company’s systems in a complete, clear, and precise manner, so that it reflects, at the corresponding date, its rights and obligations in accordance with applicable regulations. Additionally, they will ensure the accuracy and integrity of the financial information that, according to current regulations, must be communicated to the market.
DERCOSA is committed to implementing and maintaining an adequate internal control system over the preparation of financial information, ensuring the periodic supervision of its effectiveness. Accounting records will be available at all times to internal and external auditors. To this end, DERCOSA is committed to providing its employees with the necessary training to ensure they understand, comprehend, and comply with the company’s commitments regarding internal control of financial information.

4.15. Money Laundering and Irregular Payments

DERCOSA employees must pay special attention to cases where there may be indications of a lack of integrity of individuals or entities with whom the company maintains relationships.
In particular, DERCOSA employees will pay special attention to unusual cash payments considering the nature of the transaction, those made by bearer checks, or those made in currencies other than the one previously agreed upon, reporting through the channels and procedures established in this Ethical Code any payments they consider irregular. They should also remain alert to payments made to or by third parties not mentioned in the corresponding contracts, as well as those made to accounts that are not the usual ones in relationships with a particular entity, company, or person.
They will also pay attention to payments made to individuals, companies, entities, or accounts opened in tax havens and payments made to entities where it is impossible to identify the partner, owner, or ultimate beneficiary.
Finally, DERCOSA employees will carefully review extraordinary payments not foreseen in the corresponding agreements or contracts.

4.16. Social and Environmental Commitment

Respect for the Environment
DERCOSA is committed to sustainable development. DERCOSA addresses its environmental commitment by strictly complying with applicable legislation in all its areas of operation.
The company is committed to developing its activities with the utmost respect for the environment and minimizing the negative effects that they may eventually cause.
Similarly, the company will contribute to the conservation of natural resources and those areas of ecological, landscape, scientific, or cultural interest. To this end, it will establish best practices and promote the necessary training among its employees to preserve the environment.
In its relationships with contractors, suppliers, or external collaborating companies, it will convey these principles and require compliance with applicable environmental procedures and requirements in each case.

Social Commitment
DERCOSA is committed to responsible conduct, based on regulatory compliance, in all countries where it may operate. In particular, it assumes the responsibility to respect the cultural diversity and customs and principles prevailing among the individuals and communities affected by its activities.
In line with its social commitment, DERCOSA will evaluate the non-financial aspects of business projects that may involve its participation and material investments. The company understands that this analysis adds coherence to its commitment to society and sustainable development.
DERCOSA’s commitment to society is reflected in the development of sponsorships, patronages, and collaborations, which are channeled through agreements and resource allocation to social organizations, in a manner consistent with the company’s strategy.
In line with this commitment and its values of transparency and integrity, any donation made by DERCOSA must have the necessary internal and, where appropriate, external authorizations.
Under no circumstances may donations be made to any political party or its representatives, except in cases expressly provided for by applicable legislation.
Donations should only be granted to organizations with the appropriate organizational structure to ensure the proper administration of resources and must be faithfully recorded in the company’s records.
DERCOSA will, as far as possible, monitor the donations made to ensure their proper use.
Additionally, DERCOSA will encourage and promote employee collaboration with social organizations in the areas where it operates through, among other things, corporate volunteer programs.

Compliance with the Code and the Ethics Committee

To ensure compliance with the CSR Policy and the Code, DERCOSA has an Ethics Committee responsible for guaranteeing the principles and standards of conduct outlined in the Ethical Code.
The Ethics Committee comprises the General Director, the head of human resources, the head of safety and hygiene, and the head of the environment.
This committee is also responsible for monitoring the strategy and practices of Corporate Social Responsibility, as well as their degree of achievement and evaluation.
Employees and third parties will confidentially and in good faith report any conduct contrary to the Ethical Code they may observe.
They will use the communication channel established by the company, which allows employees and third parties to confidentially consult doubts and report irregular conduct related to criminal or other matters concerning the Ethical Code. Communications should preferably be nominative. Employees can also use the procedure to consult doubts or propose improvements to existing systems in the company regarding the matters covered by the Code.
The supervision of the communication procedure in matters related to criminal offenses and, in general, the DERCOSA Ethical Code falls to the Ethics Committee, chaired by the General Manager of DERCOSA.
Thus, concerning DERCOSA’s Ethical Code, the Ethics Committee has the following functions:
– Ensure the proper functioning of the communication channel established with the company’s employees.
– Convey to the head of the Ethics Committee any potential improvements in the controls and systems established by the company in the preparation of financial information processes.
– Process received communications for resolution by the relevant DERCOSA units.
– Promote knowledge of the Ethical Code among DERCOSA employees and third parties outside the company.
– Regularly prepare reports on the level of compliance with the DERCOSA Ethical Code, making necessary recommendations to improve its content, facilitate its understanding, or ensure its safeguarding.
Employees and third parties will send their communications related to the Ethical Code, confidentially, in good faith, and without fear of reprisals, to the «Ethics Committee» through:
– The website www.dercosa.com
– Postal mail addressed to Polígono Industrial Castilla, Vial 2, Apartado 13, 46380 Cheste, Valencia, managed confidentially by the Ethics Committee
– An email, jps@dercosa.com, managed by the Ethics Committee.
– Anonymous suggestion box.
The Ethics Committee, when it deems it appropriate to conduct an investigation, will designate the person responsible for responding to communications.
The handling of communications related to harassment will be conducted in a manner that ensures a prompt response and the establishment of precautionary measures when necessary. These matters will, in any case, be handled according to the specific protocol the company has in this area.
Communications received will be treated confidentially.
The data of those involved may only be disclosed if the reported event leads to actions by administrative or judicial authorities and to the extent required by such authorities, as well as in compliance with the Organic Law 15/1999 on Data Protection, and, if applicable, to the persons involved in any subsequent investigation or legal proceedings initiated as a result of the investigation.
The company will appropriately disseminate the existence of this channel.

Publicity of the Code

The Code will be provided in its own language to all employees, published on DERCOSA’s website (www.dercosa.com), and will be subject to appropriate communication, training, and awareness-raising actions for its proper understanding and implementation throughout the organization.

Annex I

State Collective Agreement for the Leather, Leather Goods, Industrial Belts, and Fur Tanning Industries 2019-2021.
International Labour Organization Conventions: https://www.ilo.org/global/standards/introduction-to-international-labour-standards/conventions-and-recommendations/lang–es/index.htm
Guiding Principles on Business and Human Rights: https://www.ohchr.org/documents/publications/guidingprinciplesbusinesshr_sp.pdf