Code of Conduct and Ethics (December 2019)

INTRODUCTION

The words that appear in this Code of Conduct define us. INMÍNER INGENIERÍA S.L., hereinafter INMÍNER ING., is a company united by common principles and a shared commitment to the highest standards of conduc

Although we perform our engineering work within the framework of applicable laws and regulations, compliance with the law alone is not enough for us. We strive for much more.

Through our Code of Conduct, we envision a work environment that we can all be proud of, a company that others respect and admire, and a better world because of our actions.

Together, we are laying the foundation for a values-based culture that will lead us to great levels of success. That is why this Code of Conduct applies to the daily activities of INMÍNER ING employees. Each of us is personally responsible for the Code, understanding what it means and applying it consistently.

People who occupy leadership positions in our company have a special share of responsibility since they must set an example of what it means to “live by the code.”

In Ciudad Real on December 12, 2019

Engineering Manager: Pedro Mesas Riballo

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Información de derechos y responsabilidades

If you become aware of a circumstance or action that violates or appears to violate the Code of Conduct, a company policy or applicable law, please contact management as soon as possible.

You have the right and personal responsibility to report any circumstance or action that violates or appears to violate the Code of Conduct, a company policy or applicable law. You should use these rights responsibly and report only matters where you reasonably believe there has been a violation.

Non-retaliation policy

INMÍNER ING. will not take any action against you as a result of presenting any ethical conflict in good faith. Likewise, INMÍNER ING. does not tolerate any retaliation by any person against any employee for filing or making a report in good faith.

Our values

INTEGRITY IS THE FOUNDATION OF EVERYTHING WE DO

This is a constant. The people we work, live and serve with can trust us. We align our actions with our words and deliver what we promise. We develop and strengthen our reputation through trust. We do not inappropriately influence others, nor do we allow them to inappropriately influence us. We are respectful and behave in an open and honest manner.

En pocas palabras, la reputación de la empresa refleja el desempeño ético de quienes trabajamos aquí.

WE ARE HONEST AND ACT WITH INTEGRITY

We aspire to the highest level of integrity and ethical behavior. We tell the truth. We only promise what we believe we can deliver. We fight to fulfill our commitments. Our company's shareholders, customers, distributors, dealers and suppliers, as well as the people we do business with and our co-workers, must be able to trust what we say and believe that we will always keep our word.

WE AVOID AND MANAGE PROBLEMS AND POTENTIAL CONFLICTS OF INTEREST

We must not engage in activities that create, or appear to create, conflicts between our personal interests and the interests of the company. These situations arise when a personal or family interest or other relationship makes it difficult for an individual to represent the company fully and fairly.

Conflicts of interest may arise in any part of INMÍNER ING's operations. The most serious conflicts of interest typically arise when an employee has the authority to spend company money, has the authority to hire or involve a person outside the company, or has information that may be valuable to people outside the company. company.

A conflict of interest, or the appearance of a conflict of interest, often arises when a gift, favor, or entertainment is offered to an employee. Although some of these activities are part of a normal business relationship, we do not accept gifts, gifts or entertainment that may have a value greater than we can provide, or that would force us or appear to force us to act contrary to the law, the interests commercials of INMÍNER ING. or the ethical business practices of INMÍNER ING.

WE COMPETE FAIRLY

INMÍNER ING. believes that fair competition is fundamental to free enterprise. We comply with competition laws in all work areas in which we have a presence. In relationships with competitors, suppliers and customers, we avoid agreements that restrict our ability to compete with others.

We are not involved in agreements, understandings or contracts with competitors that affect the prices or conditions under which our work is sold.

WE ENSURE THE ACCURACY AND INTEGRITY OF OUR FINANCIAL STATEMENTS AND RECORDS

The integrity of the financial and accounting reports of INMÍNER ING. It is based on the validity, accuracy, comprehensiveness, timeliness and clarity of the entries that support the basic information in the company's accounting books.

We ensure that every accounting or financial entry accurately reflects what the supporting information describes. We expect employees involved in creating, processing or recording such information to be personally responsible for its integrity. The same standards of integrity that apply to external financial reporting apply to financial statements that are used as internal management tools.

WE ARE FAIR, HONEST AND OPEN IN OUR COMMUNICATIONS

We communicate with others in a respectful, fair, honest and open manner. We keep employees informed in a timely manner through communications about the company's relevant and understandable financial information, as well as any other type of information. When communicating information about INMÍNER ING., we make every effort to disclose it in its entirety and to everyone, without preferences or favoritism towards any individual or group.

WE HANDLE “INVILEGED INFORMATION” IN AN APPROPRIATE AND LEGAL MANNER

Inside information can be defined as information about the company that is not public knowledge. Such information, such as certain financial data, technical materials and future plans, for example, may be of great value to others and should therefore be kept strictly confidential.

Any person who has “substantial” privileged information of INMÍNER ING. You should avoid using it for personal gain or to provide it to others. We hope that all employees, their families, and others whose relationship with INMÍNER ING. provide them with access to said information, comply with these principles.

WE REFUSE TO MAKE INAPPROPRIATE PAYMENTS

When dealing with public officials, other companies and private citizens, we adhere firmly to ethical business practices. We will not seek to influence others, directly or indirectly, by paying bribes, or by any other means that is unethical, or that tarnishes our reputation for honesty and integrity.

Even the appearance of such behavior should be avoided.

WE SET AND ACHIEVE AMBITIOUS GOALS

The quality of our work and services reflects the power of INMÍNER ING.: our pride in what we do and what we make possible. We are passionate about people, production processes and excellence in design. In a word: WE LOVE engineering.

We are determined to serve our customers through innovation, continuous improvement, intense focus on customer needs and dedication to meeting those needs immediately.

For us, excellence is not just a value, it is a discipline and it means making the world a better place.

WE ACCEPT ONLY THE BEST QUALITY IN OUR WORK AND SERVICES

We are dedicated to quality and take personal pride in all the work and services we offer. Our keen focus on customer needs continually drives us to improve quality through an implemented ISO-9000 quality system.

Our continued success depends on us exceeding our customers' expectations and standing behind everything we do.

WE FOCUS ON PROVIDING THE HIGHEST VALUE TO OUR CUSTOMERS, ALWAYS WITH A SENSE OF URGENCY

We feel the urge to satisfy the needs of our clients. Additionally, we have developed a reputation for excellence by listening to customers, understanding their needs and challenges, and offering products and services that help them achieve success. Our clients expect the best from INMÍNER ING., and each of us must ensure that our individual decisions and actions contribute to a positive perception of the company, improve satisfaction and promote loyalty of our clients.

We feel the urge to satisfy the needs of our clients. Additionally, we have developed a reputation for excellence by listening to customers, understanding their needs and challenges, and offering products and services that help them achieve success. Our clients expect the best from INMÍNER ING., and each of us must ensure that our individual decisions and actions contribute to a positive perception of the company, improve satisfaction and promote loyalty of our clients.

WE ESTABLISH A WORK ENVIRONMENT THAT SUPPORTS EXCELLENCE

The employees of INMÍNER ING. They expect the work environment to promote personal improvement, continuous learning and a feeling of self-worth. Employees have the right to express their opinions in good faith about how we can improve our performance and that of the company. We listen, respond, motivate teamwork and actively make decisions based on facts and data.

WE SELECT, PLACE AND EVALUATE EMPLOYEES BASED ON THEIR QUALIFICATIONS AND PERFORMANCE

INMÍNER ING. selects, places, evaluates and rewards employees based on their personal qualifications, job skills, demonstrated performance and the contributions they make to our company.

WE GIVE EMPLOYEES OPPORTUNITIES TO DEVELOP THEM

We ask employees to be their best, to learn from their successes and failures, and to seek opportunities to improve their performance on their own initiative, as well as through continuous learning programs offered by the company.

We motivate employees to self-development, and we will help them master the current job and improve their skills for the position. We are committed to ensuring that all employees have opportunities to develop their skills and contribute to the success of INMÍNER ING.

WE SEE RISK AS SOMETHING TO BE MANAGED AND AS A POTENTIAL OPPORTUNITY

Because we realize that business and risks cannot be separated, we proactively identify, assess and manage the risks that have the most potential to impact the business. For us, managing risk also means looking for opportunities for potential competitive advantage.

WE TAKE A “BUSINESS PERSPECTIVE”

Taking a “business perspective” means promoting the best interests of our company as a whole. Business thinking in our work areas is fundamental to the success of our business. We strive to ensure that company decisions do not put our work areas at a competitive disadvantage.

WE HELP EACH OTHER TO ACHIEVE SUCCESS

We are a team and we share our unique talents to help those with whom we work, live and serve. The diversity of thoughts and decision-making of our people strengthens our team.

We respect and value people with different opinions, experiences and backgrounds. We struggle to understand the big picture and then, we do our part. We know that by working together we can produce better results than we could achieve alone.

WE TREAT OTHERS WITH RESPECT AND DO NOT TOLERATE BULLYING OR HARASSMENT

The full value of each individual's contribution can only be achieved when we treat each other with the respect, trust and dignity we expect for ourselves. INMÍNER ING. insists on a work environment free of intimidation and harassment. As individual employees, we have the right to expect a positive work environment, as well as the responsibility to speak up and ask for change if we observe any behavior contrary to this principle.

WE TREAT PEOPLE FAIRLY AND AVOID DISCRIMINATION

We develop and maintain a productive and motivated workforce by treating employees fairly and equitably. We respect and recognize the contributions of employees and other stakeholders. We select and place employees based on their aptitude for the job to be performed, making appropriate and necessary adjustments, without regard to race, religion, national origin, color, gender, sexual orientation, age, or physical or mental disability.

We support and obey laws prohibiting discrimination everywhere we work. We hope to grow our business so that employees do not feel the need to be represented by unions or third parties. When employees have opted for such representation, or when it has been required by law, we seek an honest and professional approach to working with representatives.

WE TREAT OTHERS WITH RESPECT AND DO NOT TOLERATE BULLYING OR HARASSMENT

The full value of each individual's contribution can only be achieved when we treat each other with the respect, trust and dignity we expect for ourselves. INMÍNER ING. insists on a work environment free of intimidation and harassment. As individual employees, we have the right to expect a positive work environment, as well as the responsibility to speak up and ask for change if we observe any behavior contrary to this principle.

WE PROMOTE AN INCLUSIVE ENVIRONMENT

We understand and accept the uniqueness of people and do not pass judgment on differences. We value the diversity of talents, skills, abilities, cultures and unique experiences that enable INMÍNER ING employees. achieve superior business and personal results.

We know that when we seek diverse points of view and are receptive to them, the benefit is for INMÍNER ING.: innovative solutions and criteria for decision making that can strengthen the company and make us more successful.

WE COLLABORATE WITH KEY ENTITIES AND ORGANIZATIONS OUTSIDE OUR COMPANY

The strength of the company is the result of our ability to maintain long-lasting and mutually satisfactory relationships with clients, suppliers, official organizations and other entities that are part of the circle of our business. We listen, learn, innovate and continually work to strengthen these relationships through conscious and trustworthy behavior.

WE ASSUME OUR RESPONSIBILITIES

Both individually and collectively, we make meaningful commitments, first to each other and then to those with whom we work, live, and serve.

We understand the needs of our clients and focus on them. We are citizens of the world and responsible members of our community, dedicated to safely caring for our environment as well as managing our business ethically. We know that it is a duty and an honor to continue the savoir faire of INMÍNER ING.

WE PROTECT THE HEALTH AND SAFETY OF OTHERS AND OUR OWN

As a company, we strive to contribute to an environment where all people can work safely and lead healthy, productive lives, now and in the future. We actively promote the health and safety of all people in our facilities with our own Occupational Risk Prevention System.

As employees, we put safety first by creating a work environment that protects the health and safety of others and ourselves. We actively promote safe practices throughout the value chain, from suppliers to customers. We are committed to providing our clients with projects, designs or product developments that are safe and reliable in the market.

WE SUPPORT ENVIRONMENTAL RESPONSIBILITY THROUGH SUSTAINABLE DEVELOPMENT

We strive to create value for INMÍNER ING. by providing clients with solutions that improve the sustainability of their operations. We take advantage of technology and innovation to increase our efficiency and productivity, while reducing environmental impact, thanks to our designs.

We develop new business opportunities that help our clients do the same. Our projects comply with, or exceed, the provisions and standards applicable in all the places for which they are developed.

We lead industry and community initiatives that share our commitment to enabling sustainable progress.

WE ASSUME OUR PERSONAL RESPONSIBILITY

We are committed to the success of INMÍNER ING.. Each of us is personally responsible for achieving both individual and shared goals. We demonstrate leadership by holding ourselves individually accountable for improving value focused on shareholder expectations.

WE PROTECT OUR TANGIBLE ASSETS, OUR BRANDS AND OTHER INTELLECTUAL PROPERTY

We will go to any lengths necessary to preserve, protect and responsibly use all of our assets. This includes tangible and intangible assets, such as our brands, technology, business information and intellectual capital.

We will not unauthorizedly disclose our trade secrets or other confidential information belonging to the company, our customers, or our suppliers, whether during the course of our work for our company or thereafter.

To protect our interests, we ensure that appropriate controls are in place when company information is shared with others. Although we hire individuals with knowledge and experience in various technical areas, we do not employ them to obtain access to trade secrets and confidential information of others.

We have a personal responsibility to use all appropriate means to safeguard company assets against loss, theft, damage or misuse.

WE SAFEGUARD OUR CONFIDENTIAL INFORMATION

We consider all the information we have as an asset. Some of this we share with others through advertising or press releases. We protect everything else, including trade secrets, confidential financial information, plans for new projects or service development, and other sensitive business and personal information, through careful attention to the Information Protection Guidelines and interpersonal communication, the proper administration of corporate records, the secure use of all means of communication and, when necessary, legally binding contracts.

WE USE ELECTRONIC COMMUNICATION TECHNOLOGY IN A RESPONSIBLE AND PROFESSIONAL MANNER

Access to the Internet and the use of INMÍNER ING.'s intranet systems, email, telephones and faxes are increasingly important.

As employees, we are expected to use such technology in a responsible and professional manner, consistent with the Code and other company policies.

WE RECOGNIZE AND RESPECT PERSONAL PRIVACY

We recognize and respect the privacy interest of individuals' personal information. We collect and process only relevant and accurate information, necessary or appropriate for business purposes, and we do so only by legal and fair means.

We appropriately safeguard the security and confidentiality of company records that include personal information, whether INMÍNER ING. retain those records or do so any business partner of INMÍNER ING., and we limit access to such information only to those who have a legitimate business need to obtain it when permitted by law.

WE ARE PROACTIVE MEMBERS OF OUR COMMUNITIES

As individuals and as a company, we contribute significant time and resources to promote the health, well-being and economic stability of our communities around the world. We encourage all employees to participate in community activities that promote common well-being.

We believe that our success must contribute to the quality of life of the communities in which we work and live, as well as their prosperity and sustainability.

WE MAKE RESPONSIBLE PROPERTY AND INVESTMENT DECISIONS

The investments of INMÍNER ING. They must be compatible with the social and economic priorities, local laws, customs and traditions of the countries in which we do business.

In any case, our conduct must promote acceptance and respect of our company.

We also expect our host country to recognize our need for stability, growth and commercial success and to honor its contracts, including those relating to the rights and property of citizens of other nations.

WE PARTICIPATE IN PUBLIC AFFAIRS APPROPRIATELY

Our employees must feel free to participate in public affairs and political processes, in accordance with their individual beliefs and citizen rights.

Where we participate as individuals in public affairs or in the political process, we must keep in mind that said activity is carried out in our capacity as individuals as private citizens, and not on behalf of INMÍNER ING. and we must make this clear to everyone involved.

COMPANY POLICIES AND ADDITIONAL INFORMATION

Company policies and other more detailed company policies, as well as additional information and guidance in this Code of Conduct, are available to employees on the INMÍNER ING server.

The company policies in force at the time of publishing this Code of Conduct are:

  • Business entertainment, favors and gifts
  • Company attitudes about politics.
  • Public affairs
  • Conflicts of interest
  • Data privacy
  • The company's installations
  • Free trade
  • Improper payments
  • Intellectual Property Rights
  • Asset Protection
  • Public communications

EXEMPTION

People who hold leadership positions in our company have a special share of responsibility as they must set the example of what it means to “live by the code.”

Consequently, only the Board of Directors may exempt an Executive or Director from complying with a provision of the Code of Conduct.