0. INTRODUCTION
Enigmia Digital S.L., since its inception, has expressed a firm ethical commitment, and understands that the best way to fulfill it is the establishment of effective internal rules and procedures that tend to:
- To develop its activity in accordance with rigorous ethical rules and current legislation.
- Implement action standards and control and communication systems to prevent their activity from being used for purposes contrary to the legal system.
- Ensure that all employees comply with the policies and procedures regarding the prevention of illicit activities.
- Strictly comply with the law.
Adherence to this Code is absolutely essential to ensure that all Enigmia Digital services fully comply with the law. This regulation is mandatory for all Enigmia Digital employees, so they must make it their own and be actively involved in its implementation and development.
Our thanks in advance for supporting this Policy.
1. SCOPE OF APPLICATION
This Code is binding on the following persons and entities:
- To the members of Enigmia Digital's Board of Directors
- To all employees who work for Enigmia Digital
- To the members of the Management Committee and other members of Enigmia Digital's Senior Management
- To all entities and organizations linked to Enigmia Digital by a domain relationship or whose management, by any other title, is the responsibility of Enigmia Digital.
2. ETHICAL VALUES
Employees, both in the actions they carry out as a result of their relationship with Enigmia Digital, as well as in those others in which it could be interpreted that they are attributable to Enigmia Digital or could affect its reputation, must comply with the contents of the Code, which is based on ethical values, among which those that are key to the culture of Enigmia Digital must be highlighted:
- Respect for the dignity of the person and the rights that are inherent to him/her. Enigmia Digital is committed to the application of the contents of the Universal Declaration of Human Rights, the United Nations Global Compact, and other conventions and treaties of international organizations such as the Organization for Economic Cooperation and Development and the International Labor Organization.
- Respect for the equality of people and their diversity, which requires, with respect to all types of personal and professional relationships arising from business and activities, respectful and equitable behavior in which there is no room for discriminatory attitudes based on gender, ethnic origin, creed, religion, age, disability, political affinity, sexual orientation, nationality, citizenship, marital status or socioeconomic status.
- Strict Compliance with the Law, which requires assuming without exception the obligation to observe the legislation applicable to the activities and operations of Enigmia Digital and the actions related to them.
- Professional Objectivity, which requires decisions and actions taken without accepting the influence of conflicts of interest or other circumstances that could question the integrity of Enigmia Digital or its employees.
Ensuring compliance with this commitment to ethical behavior requires Responsible Care, which requires:
- Responsibility in actions, both institutional and individual, strictly in accordance with the principles and criteria of the Code.
- Responsible attitude, which involves employees in the identification, immediate communication and resolution, where appropriate, of ethically questionable actions.
Enigmia Digital believes that the generalization to all types of business practices of the aforementioned ethical values and those implicit in the contents of the Code must contribute effectively to the development of the societies in which they take root.
3. RELATIONSHIP WITH AND AMONG EMPLOYEES
Enigmia Digital's relationship with its employees and their relationship with each other shall be based on compliance with the following commitments:
3.1. Respectful Treatment and Prohibition of Discrimination
Treat employees with dignity, respect and fairness, taking into consideration their different cultural sensitivities.
Not to discriminate against employees on the basis of race, religion, age, nationality, sexual orientation, gender or any other personal or social condition unrelated to their merit and ability.
Do not allow any form of violence, harassment or abuse at work.
Guarantee of labor rights
Recognize the rights of association, unionization and collective bargaining.
Prohibition of child labor
Enigmia Digital does not admit child labor. Enigmia Digital will not use child labor or incorporate into its business activity any product or service derived from child labor and will ensure compliance with the provisions of the International Labor Organization (ILO) in relation to child labor.
3.4. Equal opportunity
All employees shall enjoy equal opportunities for the development of their professional career. Enigmia Digital is committed to establishing an effective policy of equal opportunities for its employees to develop their professional activity based on the principle of merit.
Enigmia Digital employees will respect the equal opportunity policy in their professional environment and will support the personal and professional learning of their colleagues.
3.5. Occupational health and safety
Enigmia Digital will provide its employees with a safe and stable environment and undertakes to permanently update the occupational risk prevention measures as well as to scrupulously respect the applicable regulations in this area in all the places where it carries out its business activities.
4. RELATIONSHIP WITH THIRD PARTIES AND THE MARKET
Enigmia Digital and its employees will base their relationships with customers, suppliers, competitors and partners as well as with their shareholders, investors and other market players on the principles of integrity, professionalism and transparency.
Fair competition
Enigmia Digital prohibits any action that involves the exercise of unfair competition practices and undertakes to ensure compliance with the antitrust laws applicable in the countries where it operates.
4.2. Management probity
Enigmia Digital prohibits bribes to authorities and public officials and prohibits its employees from giving to third parties or receiving from third parties undue payments of any kind, or gifts, gifts or favors that are outside the uses of the market or that, due to their value, characteristics or circumstances, may reasonably alter the development of commercial, administrative or professional relationships in which its companies are involved.
4.3. Quality
Enigmia Digital is committed to the quality of its products and services. They establish as a guideline of its business performance the search for quality in its products and services and will make available to its employees the necessary means for the development of the most appropriate quality management systems at all times. Enigmia Digital will seek the best satisfaction of the expectations of its customers and will develop an effort of anticipation in the knowledge of their needs.
Enigmia Digital places customers at the center of its activity, in order to establish lasting relationships with them based on the reciprocal contribution of value and mutual trust.
Enigmia Digital provides value through professional advice and innovation in the configuration and efficient provision of products and services tailored to the needs of its customers at all times.
Enigmia Digital is committed to the continuous review of its organizational processes to improve the attention and service to its customers.
Enigmia Digital expects its clients to conduct and manage their economic activities in accordance with the law and requests their cooperation in order to effectively comply with the institutional objective and social commitment to prevent money laundering and the financing of terrorist activities.
4.4. Confidentiality regarding third party information
Enigmia Digital guarantee the respect of the confidentiality and privacy of the data of third parties in its possession. Enigmia Digital undertakes to preserve the confidentiality of the data it has regarding third parties, except for legal, administrative or judicial obligations that involve obligations to deliver them to entities or persons or to make them public. Likewise, they guarantee the right of affected third parties to consult and promote the modification or rectification of the data when necessary. The employees of Enigmia Digital, in the performance of their professional activity, will keep the confidentiality of the data in the terms set out above and will refrain from any inappropriate use of this information.
Enigmia Digital considers that one of the main elements on which the trust of its customers is based is the appropriate safeguarding of their information and the effective limitation of its use in accordance with the provisions of the legal provisions that, in each case, are applicable.
The non-public information that Enigmia Digital has about its customers and their operations is confidential. Enigmia Digital has adopted rules and procedures to:
- To guarantee the security of access to its computer systems and to the physical files in which contractual and transactional documentation of its customers is stored.
- To comply with the legal requirements regarding personal data protection.
Employees, who by reason of their position or professional activity, have or have access to customer information, are responsible for its custody and appropriate use.
4.5. Transparency, value creation and corporate governance
Enigmia Digital assumes as a guiding principle of its business behavior towards its shareholders, investors, analysts and the market in general, to transmit true and complete information that expresses a true and fair view of the companies, their business activities and their business strategies.
Enigmia Digital is committed to providing its customers with timely, accurate and understandable information on its operations, as well as on the fundamental characteristics of the products and services it offers or provides.
This commitment requires special diligence in the professional performance of all persons with responsibility for the maintenance of processes and information systems for customers, in the personal attention to their requests for information and in the resolution of their complaints.
4.6. Protection of corporate assets
Enigmia Digital and its employees will always seek the best protection of all assets and rights that constitute the assets of the companies, preserving the confidentiality of the information related to the same, which may only be used in relation to the activities of the company. Employees are responsible for protecting Enigmia Digital's assets entrusted to them and preserving them from any loss, damage, theft or illegal or dishonest use.
4.7. Conflicts of interest
All Enigmia Digital employees must avoid situations that may involve a conflict between their personal interests and those of Enigmia Digital and refrain from representing the company or intervening or influencing the making of decisions in which, directly or indirectly, they or a third party linked to them by any significant economic, family or professional relationship has a personal interest.
Employees who find themselves in a conflict situation are obliged to communicate it to their hierarchical superior. Conflicts between personal interests and business interests will always be resolved in favor of those corresponding to Enigmia Digital companies.
4.8. Use of Digital Enigmia information
Enigmia Digital requires its employees to make a discreet and professional use of the company's information to which they have access in the performance of their activities and to limit its use to the company's own activities and is committed to establish management systems focused on the respect of this principle.
5. RELATIONSHIP WITH SOCIETY
5.1. Environment
Enigmia Digital assumes the commitment to ensure the greatest respect for the environment in the development of its activities, as well as to minimize the negative effects that, eventually, these could cause. Enigmia Digital is committed to strict compliance with applicable environmental legislation.
5.2. Social commitment
Enigmia Digital is committed to acting in a socially responsible manner, in compliance with the laws of the countries in which it operates and, in particular, assumes responsibility for respecting cultural diversity and the customs and principles in force among the people and communities affected by its activities.
6. INTERPRETATION AND COMPLIANCE
This Code establishes the principles and commitments of business ethics that Enigmia Digital and its employees must respect and comply with in the exercise of their activities.
Enigmia Digital will communicate and disseminate among all its employees, and those third parties for whom it is relevant, the content of this Code of Ethics. Employees must formally commit to compliance with the Code at the time they join the organization, in the renewal of their contracts and in those other circumstances in which Enigmia Digital deems it appropriate. In addition, Enigmia Digital will periodically require employees to formally state that they are aware of and comply with the Guidelines for Conduct established in the Code and will conduct training sessions on the different aspects of the Code.
Enigmia Digital expects from all its employees a high level of commitment to comply with its Code of Ethics. Managers and employees may be evaluated based on their compliance with this Code. Non-compliance will be analyzed in accordance with internal procedures, legal regulations and agreements in force, and if applicable, the appropriate sanctions will be applied.
Any doubt that may arise regarding the interpretation or application of this Code of Ethics should be consulted with the hierarchical superior or, if necessary, with the Compliance Officer.
No one, regardless of level or position, is authorized to request an employee to contravene the provisions of this Code of Ethics. No employee may justify improper conduct on the grounds of a superior order or ignorance of this Code.
Any employee who has knowledge or reasonable suspicion of a breach of this Code may bring it to the attention of his or her superior or report it through the mechanisms established by the company for the formulation of suggestions and complaints. Enigmia Digital will take the necessary measures to avoid adverse consequences as a result of communications made in good faith by employees in accordance with the provisions herein.
The violation or non-compliance with this Code that constitutes a labor misconduct shall be sanctioned in accordance with the regulations in force, without prejudice to other responsibilities in which the offender may have incurred.
7. REPORTS AND ETHICAL CHANNEL
All Enigmia Digital managers and employees may consult any doubts about the interpretation of the Guidelines of Conduct that appear in this Code and must report, in good faith and without fear of reprisal, any breach of the Code's guidelines that they observe in their professional performance to the Independent Control Body, via e-mail: canaletico@enigmiacorp.com
Communications made to the Independent Oversight Body shall be handled in a manner that ensures that the confidentiality of the identity of the complainant and any third party named in the complaint is protected, and prevents access by unauthorized personnel.
The information received in the ethical channel will be treated in accordance with the provisions of the regulations on Data Protection.
Enigmia Digital will not permit retaliation against persons who, in good faith, have raised a concern regarding any immoral or illegal conduct. In particular, Enigmia Digital will apply the principles set out in the European regulations on whistleblower protection.
8. VALIDITY
The Code of Ethics comes into force on the date of its publication and dissemination to managers and employees and will remain in force until its annulment is approved.
It will be reviewed and updated periodically by the General Manager, and at the proposal of the Independent Audit Body.
Any changes to the Code of Ethics will be communicated to all persons bound by and interested in complying with it.