CODE OF CONDUCT

The code of ethical conduct is our guide to proper conduct, together with the established work rules and procedures, to ensure that the right thing is done and that in its logical consequence no wrongdoing occurs in the company. The Code is a guide for all employees of BLUECELL COMUNICACIÓN, S.L. in their professional performance in relation to their daily work, the resources used and the business environment in which it is developed. It provides guidelines that clarify the basic principles of all management and interpersonal relationships with colleagues, employees, managers, suppliers, customers, shareholders and in general any person with a direct or indirect interest in the activity carried out by the company. Our actions are based on respect for our corporate values, and employees will accommodate the performance to principles of behavior respectful of business ethics and professionalism, in order to be a benchmark in these terms and thus be recognized. Scope of application This Code is addressed to all employees of BLUECELL COMUNICACIÓN, S.L. regardless of the type of contract that determines their employment relationship, position they occupy or the place where they perform their work. There is an obligation of those related to the company to inform their main suppliers of the existence of this Code, which will be available for consultation on the company’s website www.bluecell.es

Values

Our values represent our identity as a collective. We are different because the people who work in BLUECELL COMUNICACIÓN, S.L. make this company a unique and differentiating project.

• We are fast, we know how to listen, we seek innovation, we are helpful, and we work as a team rigorously and transparently.
• We make quick decisions and act with speed and dynamism.
• We efficiently focus on solving problems by proposing realistic, high-quality, and feasible alternatives.
• We quickly adapt to changes and the demands of the professional environment.
• We carefully listen to our internal and external clients to accurately understand their needs and propose appropriate solutions.
• We keep our eyes and ears on the client in every operation we carry out, constantly questioning their satisfaction.
• We actively listen with an open attitude and respect for the opinions of all parties involved in a situation.
• We actively seek opportunities to improve products and services and create new business opportunities.
• We take advantage of opportunities and problems to provide innovative solutions.
• We constantly update our technological knowledge to stay at the forefront of innovation.
• We understand our clients’ needs and expectations to develop and implement solutions that enhance their satisfaction.
• We serve our clients efficiently, always maintaining an agile and solution-oriented approach that strengthens the credibility and reputation of the company and its professionals.
• We assist clients with the utmost interest and strive to interpret their demands, making this the top priority of all our professionals’ attitudes.
• We excel in working in multidisciplinary teams across different units, companies, and countries, fostering an environment of trust and mutual respect.
• We collaborate with the rest of the organization, committing to achieving common goals.
• We direct our efforts toward a shared result, recognizing the contributions of every member, no matter how small they may seem.
• We respect differences, opinions, and diversity.
• We are respectful of the environment and sustainability policies.

Principles of ethical behavior

The ethical behavior that governs this company is based mainly on: Good faith. We adjust our actions at all times to the principles of loyalty and good faith with the company, with superiors, colleagues and collaborators with whom we interact. We emphasize the desire to achieve and the spirit of self-improvement. The concern for achieving the objectives set must be constant and continuous. We promote optimistic versus pessimistic attitudes. We subordinate personal objectives to the general objectives of the Company. We ensure that there is no conflict between the two, and we act giving priority to the interests of the company over personal interests or those of third parties.

Honesty

All employees of BLUECELL COMUNICACIÓN, S.L. undertake to declare any personal or professional relationship that could condition our behavior as employees of the Company. In addition, as employees of BLUECELL COMUNICACIÓN, S.L., we do not accept any compensation or undue advantages. We instill honesty and professional ethics in the usual commercial and professional relationships in the performance of our work, both in the private sector and in our relations with the Public Administrations. We do not promise undue favor undue favor to third parties, whether public or private, in order to obtain an advantage. We promote trust to declare any gifts or advantages we may obtain from third parties and make them available to the company. Any personal or professional relationship that affects the Company’s interests is reported to the immediate supervisor. We avoid conduct contrary to free competition, or that involves an act of unfair competition. In advertising campaigns, we provide clear and truthful information. Respect Each and every one of us are responsible for generating an atmosphere of cordiality and friendliness in our environment. We promote respect and trust among people. We appreciate diversity in opinions, training and culture as a source of knowledge and competitive advantage. We are careful with the language we use when talking about third parties and we encourage the non-existence of defamatory guidelines and comments inside and outside the organization. We promote respect for real equality of opportunity between men and women, avoiding any scenario of direct or indirect discrimination. No person employed in BLUECELL COMUNICACIÓN, S.L. is discriminated in the professional field because of race, physical disability, religion, age, nationality, sexual orientation, sex, political opinion or social origin. We maintain a work environment free of any discrimination and any conduct involving harassment. We do not tolerate any form of physical, sexual, psychological or verbal harassment or abuse. We respect the environment and collaborate with the sustainable development of society.

Confidentiality

We refrain from providing, internally or externally, confidential data about people and/or activities developed in the Company. We provide, however, the data that are necessary for other employees of BLUECELL COMUNICACIÓN, S.L. to properly perform their duties, with strict respect to this duty of confidentiality. We avoid conduct contrary to free competition, or that involve an act of unfair competition. In advertising campaigns we offer clear and truthful information. Principles of ethical behavior, respect, confidentiality and use of information. We comply with personal data protection regulations in relation to those we have access to due to our job. The employees of BLUECELL COMUNICACIÓN, S.L. are characterized by a marked proactive attitude in the treatment of confidential information. The information is property of the Company and should be shared whenever it is beneficial and necessary for the Company. In our conduct: We provide those in charge with truthful, necessary, complete and timely information about the progress of activities in our area; and to our colleagues, that which is necessary for the proper performance of their duties. We maintain the professional secrecy of the data, reports, accounts, balance sheets, strategic plans and other activities of BLUECELL COMUNICACIÓN, S.L. and its people, which are not of a public nature, and whose publicity may affect the interests of the company. We will not provide information about them, except when we are expressly authorized to do so. We obtain information from third parties in an ethical and legitimate manner, rejecting all information obtained in an inappropriate manner or that involves a violation of company secrecy or confidentiality. In the event of having doubts about the appropriate treatment of the information, we request the assessment of our manager about the correct cataloguing of this information. We will not be able to use for our own purposes, of third parties, or to obtain benefit or profit, the programs, computer systems, manuals, videos, courses, studies, reports, etc., created, developed or improved in BLUECELL COMUNICACIÓN, S.L., since the company keeps at all times the intellectual property of these. In general, we maintain the strictest confidentiality in the use of internal knowledge outside the company, preserving our know-how. We will only use the computer systems, software, material, reports, etc. of which BLUECELL COMUNICACIÓN, S.L. has acquired the corresponding license, respecting at all times the intellectual and industrial property of these. The use of computer equipment is subject to BLUECELL COMUNICACIÓN, S.L. information security policy in order to avoid damages to third parties and / or the company itself. We will not use the access to the systems to act fraudulently or for our own benefit.

Principles of professional behavior

Passion for the customer

All employees aspire to offer our customers a product of the highest quality and to have an excellent level of service. Excellence and quality of service are constant guides for our actions, promoting a healthy concern for continuous improvement. The resources provided by the company seek to promote innovation and the development of customer services, with profitability criteria. All of us, regardless of the functional area in which we work, are committed to customer satisfaction. We promote honest attitudes towards the customer. Efficient management The employees of BLUECELL COMUNICACIÓN, S.L. work efficiently during the working day, making profitable the time and resources that the company puts at our disposal in a rigorous and rational way. We all give the dedication required to perform our duties, aiming to achieve results in the most optimal and productive way possible. The Company provides us with all the necessary resources to perform our work and improve our performance by optimizing our time and access to the information we need to fulfill our responsibilities. Therefore, we shall make appropriate and reasonable use of them according to our professional needs. We do not engage in personal activities during working hours that interfere with or prevent us from fulfilling our work responsibilities. We use e-mail, Internet access and, in general, the Company’s computer systems for work-related purposes only, and their use for personal use is expressly prohibited. We expressly authorize the Company to monitor the use of these. Unacceptable use of company communications systems includes processing, sending, retrieving, accessing, viewing, storing, printing or otherwise disseminating materials and information that is fraudulent, harassing, threatening, unlawful, racial, sexist, obscene, intimidating, defamatory or otherwise incompatible with professional conduct. In terms of occupational safety and occupational health, we will comply with the preventive measures, using the individual and collective means of protection that the company has at its disposal. In the case of having a team in charge, those responsible will ensure that the members of said team carry out their activity in safe conditions.

Team attitude

As employees of the company, we encourage teamwork and recognize the contribution of others in achieving common results. As members of a team we contribute with equal commitment both inside and outside our area. The attitude of teamwork predominates and stands out over any performance at the individual level. An outstanding individual is also outstanding because of his or her ability to work as part of a team, and therefore there is no conflict between this behavior and that of being excellent individually. Individual interest does not take precedence over team interest. We avoid passive attitudes: we do not get carried away and we do not stay on the sidelines. We encourage enthusiasm and commitment to the group and therefore to the organization. We act in a spirit of cooperation, making available to the other areas and departments of the organization the knowledge and resources that facilitate the achievement of the company’s objectives.

Caring for your reputation

We consider the company’s image and reputation as one of its most valuable assets to maintain the trust of its customers. We monitor the respect and correct use of the corporate image and reputation by everyone in the company’s environment. The brand image is visually embodied in our company logo, for which there are rules of use that protect its use and that we must respect. We are especially careful in any public intervention, having to have the necessary authorization to speak to the media, participate in conferences or professional seminars and in any public media, whenever they appear as employees of BLUECELL COMUNICACIÓN, S.L. We are all part of the corporate image and therefore we assume an ethical and responsible conduct that preserves the image and reputation of the company. At no time we will act showing behaviors that may damage the image. Our way of communicating, conducting ourselves and our own personal image will be in line with the professional context in which we operate.

Professional development

Our professional growth and that of our teams is our key to be competitive. As employees, we are responsible for our professional growth, and therefore it is our duty to be permanently updated with the knowledge and techniques required for the efficient performance of our work. People in charge of teams must pay attention to the motivation and professional development of their collaborators, committing themselves to provide them with development opportunities based on merit and their professional contribution. To this end, they will encourage their continuous learning, recognize their efforts in a specific way and objectively assess their achievements, drawing up the action plans and support necessary for their development.

Entry into force of the code of conduct, interpretation and follow-up

The Code of Ethical Conduct came into force after its approval on October 15, 2020. The present Code of Ethics has been implemented and approved, being ratified and approved by Ángel Sopeña Blanco, sole administrator of the Company, on October 15, 2020. It will remain in force until its modification or cancellation is approved, which will be duly communicated. Each of us assumes the task of reviewing and following this Code, and we comply with all applicable laws, policies and guidelines. This Code attempts to address many of the situations we face on a day-to-day basis, but it cannot address all circumstances. Seek help from: – Your manager. – The administration department. – Your service coordinator if you are an external collaborator. All professionals must report to our manager any conduct that we believe, in good faith, to be a violation of the Code of Ethical Conduct. If any of the above three is involved in the situation we wish to report or cannot or has not adequately resolved our concerns, we will inform a more senior manager, and we inform that all personnel have at their disposal the address compliance@bluecell.es through which it is possible to report, in complete confidentiality, behaviors or facts contrary to ethics, to the law in force, to this Code of Ethical Conduct or to the good corporate governance practices that govern our Company, with special emphasis on those that could have criminal implications. We do not discriminate or retaliate against employees for having reported, in good faith, real and proven violations. Bluecell Comunicación S.L. will ensure compliance with this Code, resolve any incidents or doubts about its interpretation and adopt the appropriate measures for its best compliance. Failure to comply with this code may result in disciplinary action, including the possibility of dismissal and, where appropriate, legal action.