An ethics code is a set of guidelines that aims to establish acceptable behaviors and Good practices for members of a particular group, association or profession.

Since its creation, Montero Traducciones, S.L. has been guided by client needs and expectations to offer language services of the highest quality. It strives to maintain this level of quality while respecting the environment, health and safety in the workplace, social responsibility and preventing criminal offences.

Today’s clients, shareholders, suppliers, private and public entities, and society in general, demand higher levels of responsibility and ethical behavior from companies. To meet this demand, Montero Traducciones, S.L. requires all employees and subcontractors to act with integrity, responsibility and respect. The main purpose of this Ethics Code is to highlight the values and principles required by the Company to carry out its daily activities.

This Ethics Code of Montero Traducciones, S.L. must be complied with by all employees, managers and administrators, meaning that it must be read, understood, accepted and shared and is sent to critical providers and collaborators so that they may voluntarily abide by it.

Montero Traducciones, S.L. defines its “Corporate Values” as values that should be understood, adopted and implemented by all persons pertaining to or related to the Company in order to fulfill the following purposes and commitments set forth by the Company:

• Focus on customer satisfaction.
• Defining objectives that are aimed at meeting the needs and expectations of the Company.
• Social Responsibility. Commitment to the needs of the groups that are related to the Company and improving the quality of life of people.
• Commitment to the Environment. Commitment to the sustainable development of the Organization to minimize pollution.
• Fostering professional development. Commitment to analyzing employee training needs.
• Commitment to Health and Safety in the workplace. Commitment to action in order to prevent injuries and the deterioration of health.

With the “Corporate Values” established by Montero Traducciones, S.L., the Company aims to define the aspects in which people should establish the conditions and relationships in their professional activities. Observing these values is the foundation of this Ethics Code established by the Montero Traducciones, S.L.

This Ethics Code aims to present the set of principles and recommended behaviors that will achieve ethical and responsible management in carrying out the company’s daily activities.

Its application will help ensure that the results obtained are consistent with the relevant legislation and with the image that the Company wishes to project both internally and externally.

This Ethics Code must be followed by all employees of Montero Traducciones, S.L., regardless of their position or time in the company.

Employees of Montero Traducciones, S.L. participated in the drafting of this code by providing comments and suggestions prior to its approval.

This code is a regulatory tool that establishes the behavioral guidelines and directives in all areas of activity of Montero Traducciones, S.L. It also serves as a guide for making decisions in specific situations that involve employees.

The principles of the Ethics Code are the principles and guidelines that employees of Montero Traducciones, S.L. should be governed by when performing their duties and responsibilities in all professional areas in which the Organization is represented.

The Company is committed to complying with current legal provisions.

The commitment to comply with relevant legislation in all areas and ensure its compliance when work or activities are carried out by third parties is essential and extremely important in order to maintain the best reputation and status as a committed and responsible company in the defense of the development of both society and its citizens.

Employees, managers and administrators of Montero Traducciones, S.L. are committed to carrying out their roles and responsibilities in accordance with the established procedures.

Disparaging remarks or criticism that may undermine stability shall be avoided. All of this will result in establishing the reputation of the Company as an inclusive business that respects its clients, suppliers and other interested parties with which it maintains a relationship.

People in the Company will commit to acting with integrity and transparency when carrying out their activities.

All employees of Montero Traducciones, S.L. shall show respect and courtesy to their colleagues, clients and interested parties with whom they have or may have a relationship. The basis of a fruitful and satisfactory relationship begins with respect for the dignity of people, equal opportunities, dialogue and the non-existence of discriminatory or derogatory behaviors. All employees of Montero Traducciones, S.L. have the right to work in a free and respectful environment.

Threats and acts of violence or intimidation will not be tolerated. Abusive, degrading or offensive behavior, whether verbal or physical, will not be allowed nor will any type of discrimination based on race, gender, age, nationality, religion or opinion in any other condition or circumstance, be it personal or collective.

In all work-related activities, decision-making or participation in decision-making and interpersonal relationships in the workplace, as well as compliance with legal obligations, conduct should be honest and transparent.

Ethical behavior must be based on three pillars: neutrality, confidentiality and loyalty.

Montero Traducciones, S.L. considers favorable and safe working conditions to be the basic elements of a work environment, referring to health protection, respect and equal opportunities.

The Company is committed to providing a workplace which is tidy and in accordance with the requirements of the applicable legislation for occupational risk prevention.

Employees will collaborate in keeping workstations clean and tidy, since an untidy workplace or area hampers efficient management of duties, responsibilities and resources.

Occupational health and safety of individuals is a critical element when carrying out business activities. That is why employees must follow the instructions of the Occupational Risk Prevention Manager, using the individual protection instruments.

The possession, distribution or consumption of any type of drugs in the Company’s facilities is strictly prohibited. Likewise, smoking within the facilities is prohibited in compliance with current regulations.

No person shall be permitted to work under the influence of alcohol or illegal drugs

Conflicts of interest appear when a circumstance or situation arises where the personal interests of an employee differ from those of the Company.

An employee who detects any type of labor conflict should communicate it to the Department Managers, so that it is resolved as quickly and efficiently as possible.

All actions or decisions in which a person from the Company participates must be oriented towards the aim of maintaining the continuity and prosperity of the Company, as well as maximizing client satisfaction, respect for the environment, health and safety in the workplace, and the sustainable development of society.

Employees shall not carry out any activities or offer any services outside of the work relationship with Montero Traducciones, S.L. that lead to a loss of efficiency or productivity in their work. Similarly, they shall not provide services to another entity related to language services in order to avoid conflicts of interest, nor shall they maintain business relationships with companies where there are personal or family interests, without prior notification to Company management.

If, for work reasons, there is access to confidential information or it can be used for personal gain, under no circumstances may it be used. Improper use may put the Company in a difficult situation in which its financial status could be affected. Confidential information shall be protected to ensure that no third parties read or obtain access to it.

Always try to avoid:

• Legible confidential papers on desks
• Absence from the workstation leaving visible information on the computer screen
• Transporting outside of the office and without adequate permission portable discs, USB drives or confidential information that has not been duly protected or encrypted,
• Including confidential information on servers or repositories with unrestricted access
• Failing to properly protect the confidentiality of personal passwords (sharing them with internal or external staff, writing them in visible places, passwords that are easily to guess)
• Failing to destroy sensitive information after its legitimate use

The commitment to neither supplying nor disclosing any type of private or confidential information about the Company and about participants or organizations related to the Company must be maintained.

The use of e-mail and the Internet must be that which is necessary to carry out the job and its functions. These tools shall not be used in an abusive way for personal benefit nor for activities that may affect the image of the Company.

Nor will they be used to commit illegal acts or infringe the rules established by the Company in this Ethics Code. Only those with prior authorization shall have access to the IT systems, and no software that may affect the security of the systems shall be installed, used or distributed. Actions shall not be carried out that allow the entry of computer viruses. Unauthorized copies of computer programs are also prohibited.

All employees shall safeguard assets and tools owned by Montero Traducciones, S.L. as well as by third parties who may be at the Company’s facilities. This not only includes protection against non-authorized use, but also against the theft and use for illegal or improper purposes.

The removal, disposal or destruction of any object of value owned by the Company, except when carried out by managers in charge of this task, is prohibited.

All information contained in any physical medium (paper, cardboard, etc.) or in electronic medium is part of the knowledge base and value of the Company, and therefore is part of its property. It cannot be sold, transferred or acquired without authorization of the relevant department.

All personal data received by Montero Traducciones, S.L. (clients, CVs, suppliers, etc.) shall be kept completely private, since they pertain to Interested Parties that are essential for the continuity of the Company.

Likewise, the confidentiality of persons who file a complaint or make comments about any non-compliance of what is specified in this code shall be guaranteed. There is a channel established for this purpose called “Queremos saber (We want to know)” on the corporate website in the “Contact” section.

All interested parties (shareholders, clients, suppliers, management, etc.) that have a relationship with Montero Traducciones, S.L. are essential for projecting, maintaining and developing the image of the Company. Therefore, these relationships must be frank, loyal, respectful and ethical.

Relationships with suppliers and clients are of special importance, given their greater implication with the processes of the Company. There must be a commitment to provide clients with services that give them the greatest satisfaction, satisfying their needs and expectations.

When choosing suppliers, it is important to take into account product quality, cost of supplies and how environmentally and socially responsible the supplier is.

Interested parties have the right to receive information that is correct, specific and timely. When dealing with interested parties, no false promises or statements shall be made that are not the personal responsibility of those making them, or that compromise the image of the Company or make commitments knowing that they cannot be carried out, or that there is the intention of not carrying them out.

All employees of the Company shall ensure contractual integrity, ensuring that Suppliers and Clients comply with the established criteria during the duration of the contracts.

The Company shall not partake in unfair client acquisition.

Acts of unfair competition are considered to be those that violate the national and regional laws that protect fair competition, in particular the following:

• All practices related to direct or indirect client acquisition that infringe upon the dignity of individuals,
• The use of third parties as a means to evade ethical obligations,
• The receipt or payment of compensation that does not comply with the legal regulations on competition,
• As well as all actions and behaviors gathered in Articles 5 to 17 of the Law on Unfair Competition, and the subsequent modifications, developments and interpretation of the relevant courts in this regard.
• Price-fixing with the competition
• Market-sharing with the competition
• Creating non-aggression pacts with the competition

All practices of corruption, bribery, favoritism, or illicit situations are prohibited. Persons of Montero Traducciones, S.L. undertake not to request, accept or offer any form of illegal payment or commission.

Gifts, loans or invitations from third parties that could compromise independence or impartiality in business relationships shall not be accepted.

The Company undertakes to maintain and use the facilities.

All employees of Montero Traducciones, S.L. are under the obligation to maintain their working environment tidy, in correct operating condition and safe. Therefore, the manager must be informed when problems have been detected in the facilities or workstations, since an untidy workstation or one that does not function correctly can generate unnecessary costs or represent potential risk of accident or injury. This way the workplace can continue to be dignified, comfortable and safe.

Respect for the environment that minimizes as much as possible any impact we create with our activities creates well-being and is the base for sustainable development.

Reliability and maintenance of resources is essential for the Company’s credibility. The care, order and state of facilities and vehicles are necessary for the proper provision of the service. The misuse or overuse of resources increases environmental impact, such that the correct maintenance of installations, vehicles, assets, knowledge and efficiency when using resources is essential.

Each employee shall be responsible for the use of each resource, ensuring it is used efficiently, without loss and trying to generate the least amount of waste as possible and suitably managing them.

Employees of Montero Traducciones, S.L. shall adopt the principles contained in the Manual of Best Environmental Practices.

Respect and compliance with this manual will ensure that environmental impact is minimized and that there is a rational use of resources.

Montero Traducciones, S.L. is committed to the development of society. Active and committed behaviors will serve to create an ethical and responsible company that is engaged in sustainable development.

A responsible organization that aspires to form part of civil society must take into account the problems in society, as well as the support requested by governmental and non-governmental organizations.

Montero Traducciones, S.L. will carry out actions and projects that reduce social needs and problems in a transparent way, so that the company’s development and economic growth is harmonious with society.

The Company will also support efforts against social inequality, hunger and disaster situations.

Montero Traducciones, S.L. has set forth the following core principles transparently, so that its economic development and growth remains in harmony with the public authorities:

• Cooperation and transparency

Maintain a relationship of transparency, collaboration and compliance with tax obligations with different government entities.

• Non-interference

Refrain from all forms of undue interference in political activity

• Honesty and the fight against corruption: the company shall maintain strictly professional relationships with political figures and civil servants. Management and employees are not permitted to offer payments, gifts, or any other special treatment, whether direct or indirect, which may constitute bribery or lead to the extortion of civil servants, political staff, parties, candidates, etc.

In today’s socioeconomic world, Companies are centers of professional, economic and social development, such that as the value of a Company increases, so does the well-being and prosperity of its employees and its surroundings.

The Company is committed to:

• Continuous improvement

The commitment to management is based on efficient processes and systems, the systematic search for improvements, the identification and application of practical improvements and the internal analysis of the results obtained. The integrated and prioritized management of these activities is the principal channel that will ensure the Company’s survival and growth.

• Taking responsibility for actions carried out

In the event of consequences and claims arising from the actions carried out or the results obtained, they shall be responded to with respect, attention and appropriate responses. This includes the rational and thoughtful analysis of the circumstances that triggered them and the conveyance of an honest, ethical, swift and committed response.

• Fair Competition

Competition with other Companies should be fair and based on the search for differentiation through legal means. Advertisements shall always be truthful, without lying to enhance the Company’s own services or discrediting or criticizing the competition.

Management will hold a regular meeting once a year, and it shall be governed by the provisions of its regulations. To verify the effectiveness of this code, Management will be guided by the document that comprises all of the tools that are used by the organization, being able to request any clarification or additional information about them.

If, when carrying out its responsibilities, Management sees that the ethical values and principles of the Company or the regulations of this Code of Conduct are not followed, it will inform the relevant parties, taking into account the severity or significance of noncompliance in order to implement the appropriate measures.

Any person with questions about the Code of Conduct or who notices possible noncompliance should contact Management through its suggestions box, by sending an email or through the communications channel found on the corporate website, “Queremos saber (We want to know)”.

Management, when appropriate, will communicate this to the person or entity concerned, which will be responsible for responding to the person who had the question or informed of possible non-compliance.

In Brunete on October 04, 2023

Montero Traducciones, S.L.