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Code of Ethics

This text is a translation of the original in Spanish. Any conflict, discrepancy or inconsistency that arises will be resolved according to the Spanish version of this text.

Actuation Values and Code of Ethics

GENERAL ACTUATION VALUES OF ADQUIRA ESPAÑA, S.A.

Good faith and trust

Respect for the commitments acquired, both in these principles of action and in contracting, is the basis of Adquira España's performance in the market. Demonstrating this principle with integrity in our business performance also favours a business model that requires trust.

Adquira España is committed to protecting the confidentiality of the information it accesses, whether of the Company, customers, shareholders, employees, or suppliers. We provide our stakeholders (customers, employees, suppliers, shareholders, etc.) with relevant information on how we use and store your personal data. We also inform them about how to access and correct them. Adquira maintains personal data with adequate security measures. If at any time this security is compromised, act quickly and responsibly.

Law compliance

Adquira España ensures compliance with all laws, regulations, and regulatory obligations, both national and international, also considering internal policies and regulations among them. We provide truthful, complete, timely, and clear information in the reports that we register with the pertinent Supervisory Bodies, as well as in other public communications of the Company.

Commitment against corruption

In Adquira España, any conduct interpretable as bribery is prohibited, in the sense of offering or giving any benefit or advantage to people, in order to influence decisions of any kind or to cause a breach of the obligations and duties of the Company's employees. . Neither Adquira nor its employees accept gifts, invitations or incentives that may reward or influence a business decision. Adquira must avoid and in any case declare any conflict of interest that could put personal priorities before collective ones. Adquira acts with rectitude and neutrality without seeking its own benefit or that of third parties through the improper use of its position in the market. Adquira does not make donations in cash or in kind, of any kind, to political parties, organizations, factions, movements, entities, whether public or private, whose activity is clearly linked to political activity.

Human rights

Adquira respects the principles of the United Nations Universal Declaration of Human Rights, as well as the declarations of the International Labour Organization. Is committed to promoting equal opportunities and treats all people fairly and impartially, without prejudice associated with race, colour, nationality, ethnic origin, religion, gender, sexual orientation, marital status, age, disability or family responsibilities.

Adquira España does not tolerate any practice that involves child employment, forced labour, threats, coercion, abuse, violence or intimidation in the work environment. Furthermore, Adquira España guarantees the right to organize in trade unions and does not tolerate any hostile action towards those employees who participate in trade union activities

Professional development

Adquira España involves employees in professional improvement policies to motivate the workforce to achieve their business plan. It promotes the personal and professional evolution of our employees, encouraging the improvement of their own abilities and skills. Bases personnel policies on clear criteria of ability, competence and professional merits. Employees are encouraged to participate actively in management processes to improve their work, initiative and dedication.

Compensation

Adquira España adopts as remuneration criteria compensation appropriate to the labour market in which it operates.

Security and health

Adquira España offers its employees a safe work environment. It also undertakes to implement all possible mechanisms to avoid accidents, injuries and occupational diseases associated with business activity through strict compliance with all regulations, training, and preventive administration of occupational risks.

Products and services

Adquira España offers clients innovative, reliable, and good quality services. We control and ensure that our services meet all safety and quality standards.

Transparency in corporate communication.

Adquira España always provides truthful, clear, useful, and accurate information when marketing its services. Also, check that they meet all the required and offered specifications.

Corporate governance

Adquira España uses the highest criteria and best existing practices in corporate governance.

Value and transparency

Adquira España directs its actions to create value for its partners immediately and without discriminating the relevant information for their investment decisions.

Internal control and risk management

Adquira España carries out controls to manage the risks of the business, its personnel, and its reputation. It also records financial and accounting activity accurately and reliably. Collaborates and facilitates the work of internal control units, as well as external auditors and competent authorities.

Business assets

Adquira España maintains and conserves its physical, financial, or intellectual assets, making efficient and adequate use of them. It does not tolerate the use of computer equipment that deteriorates the company's assets or its productivity, or to commit illicit, fraudulent, illegal activities or that endanger the reputation of the Company.

Commitment to society

Adquira España contributes within its possibilities with public and private initiatives aimed at promoting progress and sustainability of the society in which it works, contributing its capabilities and technology. Consequently, it is committed to sustainable development, environmental protection, and the reduction of any negative impact of our operations on the environment.

Conflicts of interest

Adquira España establishes controls so that no person with a significant economic interest (whether through employment, investment, contract or similar) in a successful or potential supplier is involved, directly or indirectly, in a purchasing process or in a decision associated with the said supplier.

Equality and transparency

The business model of Adquira España, S.A. is based on promoting competition whenever possible, guaranteeing transparency and equal opportunities for all suppliers that send offers. We use corporate purchasing systems to objectively award contracts, which guarantee the availability of products and services in the best existing conditions.

Responsibility with the supply chain

Adquira España extends the above commitments to its suppliers, demanding that they apply principles similar to ours, in addition to requiring them to comply with the law and regulations existing in each country. Adquira España has the criterion of always complying with the payment commitments agreed with the Suppliers.

ETHICAL CODE

Observing the above general principles should serve to inspire security and confidence in those who interact with ADQUIRA: staff, clients, shareholders, suppliers of goods and services. ADQUIRA's standards of professional ethical conduct provide an overview of the company's commitment to act with integrity and solvency in all its practices.

The global environment in which the work takes place presents continuous dilemmas to resolve. An understanding of ADQUIRA's rules and policies, as well as common sense, are the tools to deal with these decisions. During daily activities, it is important to understand the effects that professional decisions can have on ADQUIRA in order to act accordingly.

1. General rules The staff of Adquira España S.A. has general obligations derived from this code, such as:

• Know and comply with the rules of professional ethical conduct.

• Carry out their duties with honesty and integrity.

• Comply with laws and regulations in force in the performance of their obligations on behalf of ADQUIRA.

• Act in accordance with the content and spirit of ADQUIRA's interest policy, and always carry out our professional activity in a way that avoids conflicts of interest.

• Avoid situations that may lead to inappropriate behaviour and avoid them. Inform the Management of any perceived unacceptable behaviour, as well as any illegal behaviour

• Seek appropriate advice from the Ethics Committee of ADQUIRA when problems related to professional ethical conduct arise.

• Act with decorum in everything related to the image of ADQUIRA.

2. Special rules

a. Corporate governance. Corporate Governance in ADQUIRA, in addition to guaranteeing effective Administration and control of activities in the business environment, seeks to:

• Provide sustainable value to partners

• Provide quality in the service provided to customers

• Control business risks

• Provide transparency

b. Control processes. ADQUIRA entrusts external auditing companies with the task of verifying the balance sheets and annual profit and loss accounts. All of this, including the company's annual report, forms part of ADQUIRA's annual accounts, which are deposited in the Mercantile Registry together with the Management report and the independent audit report. Likewise and with the pertinent periodicity, it provides truthful, precise and punctual information to the shareholders and manages their businesses in order to provide sustainable value to the partner, in accordance with the applicable legal and accounting requirements.

c. Protection of human dignity and integrity Being treated with dignity is a right of every person. By virtue of this right, ADQUIRA is committed to creating, maintaining and protecting with all the means at its disposal a work environment where dignity and freedom of all the people who work in the scope of this organization are respected. Likewise, ADQUIRA is committed to the problem of sexual harassment and harassment based on sex in the workplace, establishing a method applied to the prevention and prompt resolution of claims related to cases of sexual harassment and harassment based on sex. Any type of harassment undermines the professional environment and has an influence on the health, well-being, and performance of the people who suffer it, for all this, any action or conduct of this nature is prohibited, being considered as improper behaviour and a lack of work that gives rise to the sanctions established by the regulations in this regard.

d. Fair and respectful treatment. ADQUIRA strives to maintain a workplace without discrimination, where its personnel receives fair and respectful treatment. All ADQUIRA employees must work together in a spirit of collaboration and respecting the dignity of others, which includes:

• Cooperate with others in professional development.

• Review the work of other people in an objective, honest, and properly documented way.

• Deal fairly with other people's opinions, concerns, or complaints.

e. Employment relationship The personnel hired by ADQUIRA do so through a legal employment contract, not accepting any form of illegal work. With the establishment of the employment relationship, each person will receive the following information:

• Characteristics of the position and the tasks to be carried out.

• Information regarding normative and remuneration elements regulated according to applicable legal regulations, as well as those improvements that ADQUIRA makes available to employees for a 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 from ADQUIRA.

• Training in the field of information security.

• Training in relation to this Code of Ethics and in crime prevention

f. Personnel selection Recruitment and selection processes of personnel in ADQUIRA are carried out through procedures that guarantee equality, merit, and capacity, ensuring, in the same way, the transparency, impartiality, professionalism, independence, and discretion of the people who carry out the selection. The job offers that are published are adjusted to objective characteristics, requirements, and conditions of the position, avoiding the use of words referring to the sex of the person, as well as excluding issues that go beyond the curricular ones. The 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.

g. Human Resources administration. The development of professional careers at ADQUIRA promotes merit, professionalism, experience, and capacities without any exception due to gender, race, sexual orientation, or political or religious ideas. The performance evaluation allows to transmit the values of the company and seeks the motivation of the employee. ADQUIRA understands training as a competitive advantage and an opportunity for the professional and personal development of its employees, allowing it to improve the services it offers.

h. Health and security. ADQUIRA assumes a permanent commitment to achieve the appropriate level of safety and health at work, promoting its improvement, with full respect for current regulations. ADQUIRA has a prevention service in charge of monitoring the health and safety of its personnel in charge of providing health and safety programs and procedures integrated into ADQUIRA's working methods. Specifically, the following are commitments of the company:

• Implement a prevention model aimed at the continuous improvement of working conditions, integrating said system into the company's management.

• Develop, apply and keep the workplace risk prevention plans updated.

• Guarantee the participation and training of personnel in said plans.

• Provide ADQUIRA with the human and material resources necessary to develop these plans, as well as circulates them among all the company's employees. The respective Occupational Health and Safety Administration policies will be available to the labour authorities, and accessible to all ADQUIRA personnel, as well as on the company's intranet.

i. Quality of services. At ADQUIRA, it is committed to providing quality services, on time and at a competitive price. All the people employed in ADQUIRA assume this commitment in terms of the quality of services provided.

• It is the responsibility of each and every one of the people in the organization, task of improving quality. We must participate in the improvement programs that are established.

• You must maintain contact with customers, which allows knowing their needs and expectations.

j. Declarations related to services. Statements made by ADQUIRA personnel related to their services will be current, accurate, and not misleading, avoiding unintentional contractual obligations, a criterion that extends to external communications to ADQUIRA, marketing materials, meetings with clients, and presentations.

k. Customer Satisfaction The satisfaction of our customers is a priority aspect of ADQUIRA's activities.

l. Competitor information At ADQUIRA we use information from companies in the sector in order to compete successfully in the market. No attempt will be made to obtain information by inappropriate or illegal means. You should not obtain, or attempt to obtain, confidential information about:

• Competitors

• Current or former employees of competing firms.

• Entities associated with ADQUIRA, clients, or supplier companies that do business with competing companies. If information is received from any competing company that may be considered confidential, such knowledge must be raised to ADQUIRA's Management to determine the appropriate process.

m. External communications. External communication is important to ADQUIRA, both for compliance and image reasons. The information provided is complete, complete, and truthful. Adquira implements its records retention policies according to these criteria.

n. Information privacy.Personal data protection compliance policies must be implemented and known by staff. Anyone can exercise their rights by writing to Adquira España.

o. Conflict of interests. Decisions of people acting on behalf of Adquira must be made based on the best interest of the company. A conflict of interest arises in any situation where there is a difference between personal interests and obligations to ADQUIRA. Activities that directly or through others may appear to be such a conflict will be avoided, such as participation in activities of other companies, in external commercial interests, or commercial relationships with friends or family.

Before starting an activity that may constitute a potential conflict of interest, the situation must be communicated in writing to the corresponding ADQUIRA Management and await their approval.

p. Company assets. The computing and communications resources made available to the staff will be used for tasks related to the purposes of the company and according to the position of the employee. Its use must be in accordance with the other policies described in this Code of Ethics. The use of the internet, intranet, and email services must be based on the principles of ethics, respect for people, and current legislation. Communications made by employees, in use of company resources, will be considered the property of the company.

q. Use of employee-owned resources. It is considered inappropriate behaviour to use social networks with their own resources for non-professional purposes during working hours.

r. Copyright and illegal downloads. Downloading files protected by copyright without permission is illegal, violates our company policy, and may result in administrative sanctions, civil and criminal liability. Therefore, before making such copies, it is recommended to verify that ADQUIRA has a license that allows them to be made.

s. Respect for the corporate image. The workers are responsible for preserving the prestige of ADQUIRA as a value that belongs to all, a value that is shared by the mere fact of belonging to it for the duration of the contractual relationship with ADQUIRA. Consequently, staff must not engage in any activity that could negatively affect their good image.

t. Bribes.ADQUIRA employees will not participate in the granting of benefits or advantages of any nature that could influence the normal development of the relationships in which ADQUIRA participates. Likewise, ADQUIRA personnel will not request, accept or receive from persons or entities outside of ADQUIRA, gifts, hospitality, or favorable treatment outside the lawful uses of the market, and shall be directed to influence the company's performance.

3. Enviromental Commitment.

Medio ambiente Environment ADQUIRA is committed to sustainability and responsible use of resources, focusing its efforts on:

• Use of systems that improve efficiency and minimize environmental impact (electronic communications service, digitization of information, remote control, etc.)

• Use of energy-saving systems.

• I promote the saving of paper, the use of e-mail to attach documents, the use of screen display modes, treatment of documentation in digital format, and review of the status of photocopiers.

• Recycling and Waste Management: ADQUIRA has recycling places or systems for products that have already been consumed or are in disuse, facilitating their environmental management. Likewise, waste of special impact derived from the activity of ADQUIRA (batteries, obsolete cellular phones, etc.) is processed properly.

4. Penalties for non-compliance

It will be the function of the ethics committee to propose sanctions to the personnel responsible for the breaches that reach the ethics committee, sanctions that must agree, in any case, with the provisions of the applicable agreement at the time of committing them.