Code of conduct

1. Introduction

This document, approved by the Most Senior Officer of Grupo Técnico Calcat, S.L. on 16-11-2023, sets out the set of general rules and principles of professional conduct that apply to all professionals of Grupo Técnico Calcat and that serve to establish the guiding parameters of our company's corporate culture.

Grupo Técnico Calcat's priority objective is to generate trust in the services of “7112 - Engineering technical services and other activities related to technical consultancy”, for the benefit of clients' needs, of competitiveness against the rest of the companies in the sector, and of the expectations of everyone who works in our organisation.

Grupo Técnico Calcat aims to maintain a relationship of trust in the area where it operates, that is, with those companies, institutions or persons whose contribution is necessary to make the mission of Grupo Técnico Calcat a reality.

2. Pillars of the code of conduct

In particular, and among all the corporate principles and values of Grupo Técnico Calcat, this Code is built on the following fundamental pillars:

• The structural ethical principles, which must govern any business behaviour or action of Grupo Técnico Calcat, generally, with respect to all the economic and social agents in which it seeks to generate trust.
• The criteria of behaviour of Grupo Técnico Calcat's professionals, specifically, with respect to each type of economic and social agent with which it interacts in the course of its business, i.e. clients, suppliers, workers, public bodies, competitors, etc.
• The implementation mechanisms, in order to establish control systems for the compliance and corporate development of the Code of Conduct and of all the structural ethical principles and criteria of behaviour it contains.

3. Recipients

This Code of Conduct is addressed to the professionals of Grupo Técnico Calcat.

Grupo Técnico Calcat will encourage all companies controlled by it and the main suppliers and collaborators it deals with to adopt conduct in line with the structural ethical principles of this Code.

The Code of Conduct is valid, always taking into account the cultural, linguistic, social and economic differences of the various companies where Grupo Técnico Calcat operates.

4. Structural ethical principles

4.1 Strict compliance with the law and human rights

All Grupo Técnico Calcat professionals will maintain strict respect for the legal system in force in all the territories where Grupo Técnico Calcat operates.

In accordance with the above, all action by Grupo Técnico Calcat and the people who make it up will scrupulously respect the law, human rights and public freedoms, and will adopt all measures that guarantee respect for fundamental rights, the principles of equal treatment and non-discrimination, protection against child labour exploitation and any other principles set out in the Universal Declaration of Human Rights and the United Nations Global Compact on human rights, labour rights, the environment and the fight against corruption.

In the course of their professional activity, any entity or person who collaborates or deals with Grupo Técnico Calcat must diligently respect the legal system in force, the Code of Conduct and the internal regulations of Grupo Técnico Calcat.

4.2 Quality and excellence as a fundamental pillar

Grupo Técnico Calcat orients its activity towards satisfying and defending its own clients, attending to all requests that may improve the quality of the services provided.

For this reason, Grupo Técnico Calcat directs its engineering technical services and technical consultancy activities towards achieving excellent quality standards in its services and products.

4.3 Reputation and prestige as a calling card

Grupo Técnico Calcat has a solid reputation thanks to its extensive experience and a solvent, loyal team committed to the values and know-how that make up the culture of Grupo Técnico Calcat.

Each and every one of its professionals will take part in strengthening the prestige of Grupo Técnico Calcat and safeguarding its reputation.

4.4 Protection and development of our human resources

The people of Grupo Técnico Calcat are an indispensable factor for its success. Grupo Técnico Calcat promotes the professional development of its people, taking into account the possible balance between the company's objectives and the needs and expectations of employees.

Likewise, Grupo Técnico Calcat encourages the ongoing adaptation and improvement of the skills and capabilities of the whole organisation. In particular, Occupational Risk Prevention is a priority chapter for the company, and therefore Grupo Técnico Calcat undertakes to provide the means necessary to eliminate or reduce the occupational risks of all those who carry out their professional work at Grupo Técnico Calcat.

4.5 Respect for and commitment to the community and the environment

Grupo Técnico Calcat is firmly committed to the protection of and respect for the environment, and therefore carries out its activity under the premise of minimising negative environmental impacts and preventing pollution, promoting research, development and innovation that improves processes, and providing training for its employees and professionals on the proper environmental management and optimal management of natural heritage.

4.6 Confidentiality and transparency in all relationships

Information is one of Grupo Técnico Calcat's main assets for managing its activities.

All Grupo Técnico Calcat professionals will use this resource with the utmost care, preserving its integrity, confidentiality and availability and minimising the risks arising from its disclosure and misuse, both internally and externally.

Grupo Técnico Calcat undertakes to disclose information about the company in a complete and truthful manner, allowing shareholders, analysts and the remaining stakeholders to form an objective judgement about Grupo Técnico Calcat.

5. Criteria of behaviour

The specific criteria of behaviour towards each of the groups and persons with which Grupo Técnico Calcat deals, as set out in this Code of Conduct, must be inspired by and applied in accordance with the strictest compliance with the law, which will in all cases inform their application, and will be mainly oriented towards:

• Quality and excellence in service to earn the loyalty of our clients.
• The reputation and prestige we must convey to our suppliers and business partners.
• The development and protection of our workers.
• Strict compliance with the law before public bodies.
• Respect for and commitment to the community and the environment.
• The transparency of our activities with respect to the organised markets in which we participate.

5.1 Relationships with clients

Honesty and professional responsibility. Any relationship with our clients must meet a high commitment to honesty and professional responsibility, as well as respecting the regulations applicable to the relationship with our clients.

Therefore, the commitments made with clients must be respected, announcing in good time any change, modification, alteration or variation in verbal and written agreements, fostering transparency in our organisation's relationships and being upstanding in all professional dealings with our clients.

Contracts and promotional activity. Contracts and promotional activity with Grupo Técnico Calcat's clients must be:

• Clear and direct.
• Compliant with current regulations, without resorting to evasive or in any way improper practices.
• Complete, so that our clients have all the relevant information for decision-making.

Grupo Técnico Calcat undertakes not to use misleading or false advertising instruments. Marketing activity must be carried out by offering all relevant information to our clients for appropriate decision-making.

Confidentiality and privacy. Sensitive information about our clients must be treated with absolute reserve and confidentiality and may not be provided to anyone other than its legitimate holders or under official requirement, always with the appropriate legal safeguards.

Commercial dealings with clients must be carried out, where appropriate, in an environment that guarantees the privacy and confidentiality of conversations, negotiations and documentation used.

Conflicts of interest. Any economic, family, friendship or any other kind of link between our professionals and clients may alter the independence of decision-making and could pose a potential risk of disloyal action by bringing the personal interests and those of Grupo Técnico Calcat into conflict.

Consequently, when these circumstances arise, they must be brought to the attention of Grupo Técnico Calcat's Compliance Committee.

In particular, a conflict of interest will be deemed to exist when, directly or indirectly, the company's interest and the personal interest of any Grupo Técnico Calcat professional, as defined above, or of any person connected to them, collide. Therefore, behaviours that compromise the independence of Grupo Técnico Calcat or its clients in decision-making must not generally be accepted.

Gifts, presents and favours. Grupo Técnico Calcat will not give or accept any kind of gift or present that could be interpreted as exceeding normal commercial or courtesy practices.

In particular, any form of gifts, presents or favours to clients that could influence the independence of their decision-making, or that could induce the guarantee of any kind of favour to Grupo Técnico Calcat or its employees and managers, is prohibited.

In all cases, care will be taken to avoid this type of behaviour in the international transactions in which Grupo Técnico Calcat is involved, given the difficulty of controlling it in jurisdictions and markets other than Spain and the negative impact such behaviour can have on the company's reputation.

Grupo Técnico Calcat will refrain from practices not permitted by applicable law, by commercial usage or by the ethical or conduct codes, where known, of the companies or entities with which it maintains business relationships.

Any gift from Grupo Técnico Calcat will be characterised by having only a symbolic value and by being intended to promote the brand image of Grupo Técnico Calcat; any gift offered for that purpose must be managed and authorised in accordance with company protocols.

Handling of complaints. Any complaint will be welcomed by our organisation, because it will help us find our way back to excellence and professionalism in our service and products.

Therefore, Grupo Técnico Calcat professionals undertake to attend to, respond to, channel and, where appropriate, resolve any complaint or grievance from our clients.

Business opportunities. No Grupo Técnico Calcat professional may use the name of Grupo Técnico Calcat or invoke their professional status to carry out transactions on their own behalf or that of connected persons.

No Grupo Técnico Calcat professional may carry out, for their own benefit or that of connected persons, investments or any transactions linked to Grupo Técnico Calcat's assets of which they became aware in the course of their professional activity, when the investment or transaction had been offered to Grupo Técnico Calcat, provided that Grupo Técnico Calcat has not rejected that investment or transaction without the influence of the professional concerned.

5.2 Relationships with suppliers and other collaborators

Choosing suppliers and other collaborators. The processes for choosing our collaborators must be characterised by the pursuit of competitiveness and quality, guaranteeing equal opportunities among all our organisation's suppliers and collaborators.

In particular, Grupo Técnico Calcat professionals will not deny anyone who, meeting the required conditions, can compete for the contracting of products and services, adopting objective and transparent criteria in the choice between candidates.

Should the supplier or collaborator, in carrying out their own activity for Grupo Técnico Calcat, adopt behaviours not in line with the general principles of this Code of Conduct, Grupo Técnico Calcat will be entitled to take appropriate measures and may refuse future collaboration with that supplier.

Relationship with suppliers. Relationships with our suppliers are governed by common principles and are subject to rigorous quality, compliance and excellence control by Grupo Técnico Calcat. The formalisation of a contract with a supplier must always be based on clear relationships and avoid forms of dependence.

Independence. The purchase of goods or services will be carried out, at any level, with total independence of decision. Any economic, family or other kind of link must take into account the provisions set out above regarding the possible existence of a conflict of interest.

Gifts, presents and favours. The prohibition on giving or accepting gifts set out above will apply equally to the relationship between Grupo Técnico Calcat and its suppliers and collaborators. This prohibition will apply equally to all Grupo Técnico Calcat professionals and employees. Purchasing departments must, if anything, take extra care to avoid this type of practice.

5.3 Human resources

Staff recruitment and professional advancement. Grupo Técnico Calcat avoids any form of discrimination with respect to its own workers.

In the processes of managing and developing people, as well as in the selection and professional advancement phase, the decisions made are based on the match between the expected profiles and the professionals' profiles and on merit-based considerations.

Access to functions and positions is also established taking into account skills and capabilities; in addition, whenever it is compatible with overall work efficiency, a flexible work organisation that facilitates work-life balance is favoured.

Training. Grupo Técnico Calcat makes information and training tools available to all workers with the aim of valuing their specific skills and developing people's professional worth. Training responds to the organisation's objectively established needs and takes into account people's professional development.

Gender equality. Grupo Técnico Calcat professionals will respect the right to equal treatment and opportunities between women and men. In general, they will actively promote the absence of any discrimination, direct or indirect, on grounds of sex, and the effective defence and application of the principle of equality between men and women in the workplace, advancing in the establishment of measures that favour work-life balance.

The principle of equal treatment and opportunities between women and men will be guaranteed both in access to employment and in vocational training, professional advancement and working conditions. Grupo Técnico Calcat will adopt the appropriate measures and decisions in response to any action that constitutes or causes discrimination on grounds of sex.

Occupational health and safety. Grupo Técnico Calcat declares its firm commitment to maintaining and developing the implemented Risk Prevention system, assuming the protection of workers as its main objective in this area and driving the integration of Prevention at all levels of the Company.

Grupo Técnico Calcat will adopt the measures necessary to eliminate or reduce risks, guaranteeing compliance with applicable legal requirements, promoting the consultation and participation of workers, and raising the awareness of all employees regarding risk prevention.

Moral integrity. Grupo Técnico Calcat undertakes to protect the moral integrity of its professionals, guaranteeing the right to working conditions that respect the dignity of the person. For this reason, it protects workers against acts of psychological violence and combats any discriminatory attitude or behaviour, or any behaviour harmful to the person, their convictions and their preferences.

The necessary measures will be adopted to prevent and, where appropriate, correct sexual harassment, mobbing and any other form of violence or discrimination, avoiding among all Grupo Técnico Calcat professionals any behaviour or speech that could harm personal sensitivities.

5.4 Relationships with public bodies

Legality and integrity. The principle that will guide at all times the relationships between Grupo Técnico Calcat and the public bodies, authorities and officials it interacts with will be the strictest compliance with the applicable law.

In particular, special attention will be paid to strict compliance with the various tax, social security and anti-money-laundering regulations that apply.

Gifts, presents and favours. The prohibitions concerning gifts, presents and favours to clients apply equally to Grupo Técnico Calcat's relationship with public bodies. Grupo Técnico Calcat will not give to, nor accept from, public officials, authorities or public bodies in general any kind of gift or present that could be interpreted as exceeding normal courtesy practices.

In particular, any form of gifts, presents or favours to public officials, auditors, directors, etc. that could influence independence of judgement or induce the guarantee of any kind of favour is prohibited. Grupo Técnico Calcat will refrain from practices not permitted by applicable law, by commercial usage or by the ethical or conduct codes, where known, of the administrations or public bodies with which it maintains business relationships.

Any gift from Grupo Técnico Calcat will be characterised by having only a symbolic value and will be intended to promote the brand image of Grupo Técnico Calcat. Any gift offered for that purpose must be managed and authorised in accordance with company protocols.

Political parties. In compliance with the law, Grupo Técnico Calcat will refrain from carrying out any prohibited activity in relation to the financing of political parties or the sponsorship of events whose sole purpose is political activity. Grupo Técnico Calcat will likewise refrain from exerting any kind of direct or indirect pressure of a political nature.

Competition law and regulatory bodies. Grupo Técnico Calcat complies and undertakes to comply with any local or national competition-law regulations and will cooperate with the authorities that regulate the market.

5.5 Relationships with the community and the environment

Environmental policy. Grupo Técnico Calcat has environmental and sustainable-development policies, in accordance with environmental legislation. This policy is also underpinned by the awareness that respect for the environment can represent a competitive advantage in an increasingly broad and demanding market in the field of quality and conduct.

Operations in organised markets — Transparency. Grupo Técnico Calcat complies at all times with its legal obligations regarding periodic public information, the disclosure of material events and other transparency duties, with full submission to the regulations. In particular, regarding financial information, Grupo Técnico Calcat pays special attention to ensuring that such information is prepared truthfully and is recorded and disseminated to the market appropriately.

Information control. Grupo Técnico Calcat has an internal code of conduct for the management and handling of confidential information, containing the protocols for the external disclosure of documents and information relating to Grupo Técnico Calcat, with particular reference to inside information.

In accordance with the aforementioned internal code of conduct, all Grupo Técnico Calcat professionals who possess inside information are obliged to safeguard it and adopt the appropriate measures to prevent such information from being subject to abusive or disloyal use and, where appropriate, will immediately take the measures necessary to correct any consequences that may have arisen, except for communications with judicial or administrative authorities under the terms provided by law and by the aforementioned internal code.

Grupo Técnico Calcat professionals must avoid behaviours that could give rise to phenomena of abuse of confidential information and market manipulation, including by third parties. In order to guarantee maximum transparency, procedures for the management of confidential information will be adopted that respect the law and comply with international best practice.

6. Implementation

Grupo Técnico Calcat's Compliance Committee will be the delegated body that advises the Most Senior Officer on the adoption of policies that promote the ethical behaviour of Grupo Técnico Calcat and on compliance with this Code of Conduct.

6.1 Functions

The Ethical Compliance Committee will have the following functions:

• To verify the application of the Code of Conduct, through specific activities aimed at monitoring the continuous improvement of conduct within Grupo Técnico Calcat, by assessing the conduct-risk control processes.
• To review the initiatives for spreading knowledge and understanding of the Code of Conduct.
• To receive and analyse reports of violations of the Code of Conduct.
• To take decisions regarding significant violations of the Code of Conduct, proposing where appropriate the imposition of sanctions and the adoption of disciplinary measures.
• To establish controls to prevent the commission of offences that could give rise to legal liability for Grupo Técnico Calcat.
• To propose to the Most Senior Officer the amendments and additions to be made to the Code of Conduct, and to maintain, publish and keep this Code of Conduct up to date.

6.2 Training

The Code of Conduct is made known to internal and external parties through specific communication activities and through its publication on Grupo Técnico Calcat's website.

In order to ensure a correct understanding of the Code of Conduct at all levels, an annual training plan will be established to promote knowledge of the principles and ethical rules set out in this Code of Conduct.

6.3 Whistleblowing channel

Grupo Técnico Calcat undertakes to establish, for each party involved, whistleblowing channels through which to send the relevant communications. These channels will safeguard the confidentiality of the information handled.

In particular, in relation to the process of preparing financial information, Grupo Técnico Calcat will establish, under the supervision of the Audit Committee, a whistleblowing channel that allows the reporting of potentially significant irregularities, especially financial and accounting ones, in addition to any breaches of the code of conduct and irregular activities within the organisation.

Likewise, in matters that may affect Grupo Técnico Calcat's workers, such as situations of discrimination, harassment, mobbing or workplace safety, among others, specific channels will be established for the communication and handling of any improper conduct that may occur in these areas.

6.4 Violation of the Code of Conduct

Grupo Técnico Calcat's Compliance Committee will send reports on violations of the Code of Conduct, detected following indications from those involved or following audit activities, together with any suggestions deemed necessary:

• In the most significant cases, to the Most Senior Officer or the Audit Committee, who must adopt the corresponding measures.
• In the remaining cases, to the General Management of Grupo Técnico Calcat.

No one, regardless of their level or position, is authorised to request that a professional commit an unlawful act or one that contravenes the provisions of this Code of Conduct.