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Ethics

Index

• Code of Conduct
• Introduction, Mission, and Vision
• Corporate Values
• What is the Code of Conduct?
• What is not the Code of Conduct?
• To Whom is it Addressed?
• What Effects are Expected?
• What Effects are Not Expected?
• Principles and Values
• Compliance with Legality
• Integrity and Objectivity
• Respect for People and Diversity
• Health and Physical Integrity
• Environmental Protection
• Stakeholder Behaviour
• Use and Protection of Information
• Intellectual and Industrial Property
• Ethical Standards
• Anti-Corruption
• Warning Signs
• Record Keeping
• Money Laundering
• Public Resources and Taxation
• Dissemination and Application
• Reporting Channels
• Independence and Confidentiality
• Prohibition of Retaliation
• Investigation of Retaliation
• Non-compliance with the Code

Code of conduct

The Evidenze Group code of conduct (hereinafter, the “Code of Conduct” or the “Code”), is a guide in which honest behavioral guidelines are compiled , respectful and integrity addressed both to the team of people who are part of the Evidenze Group and to third parties with whom it interacts, or its interest groups.

It is important to keep in mind that the Code of Conduct does not contemplate all the situations or circumstances in which the people who make up the Group may find themselves, but rather it is a standard of conduct that establishes the action criteria that must be observed by the Group's suppliers and be observed by the people who make up the Evidenze Group in the performance of their responsibilities.

Likewise, it involves the articulation of a set of principles and values in the behavior of the people who make up the Evidenze Group. The Code of Conduct is also a reflection of the Evidenze Group's public commitment to these principles and values.

Its objective is to ensure ethical and responsible professional behavior of the Group and all its employees and suppliers, in the development of its activities as a basic element of its business culture, on which training and the personal and professional development of its employees.

 

Introduction, mission, and vision of Evidenze Group and its subsidiaries

The companies of EVIDENZE GROUP EUROPE, S.L. (parent company) and its subsidiaries form the Evidenze Group (hereinafter, the 'EVIDENZE GROUP' or the 'GROUP')

The EVIDENZE GROUP is a collection of companies providing services and solutions in health knowledge management, specializing in clinical research (CRO), medical training, consulting, communication, organization of scientific events, and patient support and care programs.

The EVIDENZE GROUP was established in 2020, integrating leading companies in the health knowledge sector in Europe.

The companies that make up the EVIDENZE GROUP have a combined experience of over 100 years in the health sector, spanning research, training, and patient support programs.

In an atomized and vertical market, the EVIDENZE GROUP provides its clients with a 360° service, focused on the knowledge and scientific evidence. This enables us to support them from the generation of evidence to its transformation into knowledge and application in the healthcare system.

The EVIDENZE GROUP aspires to be recognized as a benchmark in knowledge management in the health sector, for its understanding of industry needs and for the integration of services, with the goal of enhancing the quality of life for individuals.

The mission of the EVIDENZE GROUP is to add value to the healthcare sector by enhancing clinical practice through evidence.

The mission of the EVIDENZE GROUP is to add value to the healthcare sector by enhancing clinical practice through evidence.The EVIDENZE GROUP advocates for a legal, regulatory, and supervisory environment that is transparent and predictable, always promoting regulatory compliance and the highest standards of business and scientific ethics.

To achieve our mission, we believe that the behaviour of personnel working in the EVIDENZE GROUP should be guided by principles of personal ethics, professional excellence, and corporate and social responsibility.

 

CORPORATE VALUES

Similarly, the values of the EVIDENZE GROUP should govern behaviour with clients and suppliers, with members of the GROUP, as well as with third parties with whom collaboration or interaction occurs.

Integrity

The EVIDENZE GROUP always operates within the international and local regulations of the sector. Specifically, it acts by applying these ethical principles in its relationships with employees, clients, and suppliers. At EVIDENZE, we advocate for engaging with openness and honesty, acting with responsibility and transparency in fulfilling the commitments we undertake.

Team

All members of the EVIDENZE GROUP share common goals and are interdependent, recognizing that success depends not only on the fulfilment of individual responsibilities but also on supporting the rest of the team in achieving the objectives of the GROUP.

Trust

The EVIDENZE GROUP respects all its members, clients, and suppliers, treating them in the same way we would like to be treated. The GROUP places trust in the capabilities and intentions of others while being aware that everyone performs better in a trusting environment. Different working styles can bring value, be complementary, and enhance the results of the GROUP.

Innovation

The goal of the EVIDENZE GROUP is to contribute to its clients and society by providing new ideas and technological value to simplify and enhance research processes, healthcare professional training, and patient support programs. The GROUP focuses on a thorough understanding of its clients and the regulatory and technological framework that applies to them, innovating and seeking innovative solutions that add value in an ever-evolving environment.

 

Scientific rigor

The EVIDENZE GROUP operates with high standards of quality and safety in all areas of its activity. The GROUP is aware that its credibility and the trust of its clients depend on the quality and scientific rigor of its services.

 

What is the Code of Conduct of the EVIDENZE GROUP?

The code of conduct of the EVIDENZE GROUP (hereinafter, the 'Code of Conduct' or the 'Code') is a guide that compiles guidelines for honest, respectful, and integral behaviour aimed at both the team of individuals forming part of the EVIDENZE GROUP and third parties with whom it interacts, or its stakeholders.

It is important to note that the Code of Conduct does not cover all situations or circumstances that individuals within the GROUP may encounter; rather it is a standard of conduct that establishes the criteria of behaviour to be observed by the providers of the GROUP and followed by individuals within the EVIDENZE GROUP in the performance of their responsibilities.

Moreover, it represents the articulation of a set of principles and values in the behaviour of the individuals within the EVIDENZE GROUP. The Code of Conduct also reflects the public commitment of the EVIDENZE GROUP to these principles and values.

Its objective is to promote ethical and responsible professional behaviour from all employees of the GROUP, as a fundamental element of its corporate culture, which underpins the training and personal and professional development of its employees.

Therefore, the Code of Conduct:

• Facilitates the understanding and application of the corporate culture of the EVIDENZE GROUP, firmly grounded in the respect for human and social rights and the effective integration of the entire employee community into the GROUP, with respect for its diversity.
• Establishes the principle of due diligence for the prevention, detection, and eradication of irregular behaviours, of any nature, including, among others, risk analysis, definition of responsibilities, employee training, and, where applicable, third parties directly related to the GROUP, and the formalization of procedures, especially those for reporting and the immediate elimination of irregular behaviours of which individuals within the EVIDENZE GROUP become aware.
• Considers the principle of criminal liability of legal entities, as established in the legal system, and prevents and prohibits the existence of behaviours that may determine the responsibility of the GROUP among its legal representatives, administrators, employees, or any other person subject to its authority.

 

What is not the Code of Conduct of the EVIDENZE GROUP?

The Code of Conduct is not a substitute for any legal norms that are applicable in each case and territory, nor for the obligations validly assumed in each specific case through contract or collective bargaining.

It is also not an exhaustive manual of procedures or processes to be followed in resolving incidents that may occur in the daily activities of individuals within the EVIDENZE GROUP.

 

To whom is it addressed?

This Code of Conduct is mandatory and must be adhered to by all individuals within the EVIDENZE GROUP, including administrators, executives, employees, suppliers, and collaborators of the GROUP, as well as individuals obligated or recipients of the Code of Conduct.

The Code of Conduct is also directed at individuals, entities, and stakeholders who are direct recipients and obliged to respect its content, and therefore, they must be aware of it.

Likewise, representatives, agents, and/or intermediaries acting in the interest or on behalf and representation of the EVIDENZE GROUP are recipients of this Code of Conduct. These individuals or entities must align their conduct with the standards of the Code whenever they represent or manage the interests of the GROUP.

The primary recipients of the Code of Conduct are employees, clients, suppliers, advisors, and other individuals or entities that interact with the EVIDENZE GROUP for professional, commercial, or business reasons. In addition to being informed to understand the Code, all these individuals must accept that, in their dealings with the EVIDENZE GROUP, the conduct of both the GROUP and the recipients of this Code of Conduct is governed by its provisions.

Individuals obligated by the Code of Conduct must meet three requirements, specifically:

• Understand and comply with the conduct rules established in this Code and the ethical principles on which it is based,
• Report, through the channels provided, any situations of non-compliance of which they become aware, and
• Cooperate in any internal or external investigation initiated in this matter.

 

What effects are expected?

The main effect expected from this Code is to provide all its recipients with knowledge of the conduct standards they should observe and/or respect in their dealings or relationships with the EVIDENZE GROUP, as applicable.

Recipients or those obligated are also expected to collaborate in its dissemination and effective implementation. In the case of executives, it is expected that they set an example for the rest of the organization in their awareness, dissemination, and compliance with the Code of Conduct.

It is also expected that this Code allows and encourages all obligated parties to make use of the various means provided to aid in its compliance.

Finally, it is expected that both the recipients and those knowledgeable about the Code of Conduct collaborate and act consistently to prevent its violation.

 

What effects are not expected?

The Code of Conduct cannot have the effect of exempting its obligated parties from the duty to be aware of and comply with legal standards, internal standards of the EVIDENZE GROUP, or their own standards based on everyone’s professional status.

Nor is it expected that the existence or content of the Code can be used by its recipients to create confusion and/or disagreements regarding its interpretation, with the intent of somehow hindering its compliance.

Another effect that cannot be expected from the Code of Conduct is that it will solve all cases and doubts that may arise on its own to comply with the principles and values of conduct of the EVIDENZE GROUP.

Finally, the Code of Conduct cannot have the effect of eliminating the need for all its recipients to act responsibly and use common sense when facing problems that may arise.

 

Principles and values of corporate conduct

The principles and values of corporative conduct to which the EVIDENZE GROUP is committed at the highest level and that inspire this Code are:

• Compliance with legality.
• Maintenance of optimal working conditions both within the EVIDENZE GROUP and for collaborators.
• Promotion of equal opportunities among all individuals within the EVIDENZE GROUP.
• Establishment of an increasingly diverse structure within the board of directors.
• Integrity and objectivity in business/corporate conduct.
• Respect for individuals and their diversity.
• Protection of health and physical integrity.
• Environmental protection.
• Proper conduct in relationships with stakeholders in the healthcare industry.
• Use and protection of information.
• Protection of intellectual and industrial property.
• Maintenance of high ethical standards.

 

Compliance with legality

In the EVIDENZE GROUP, we are committed to compliance with applicable laws, with a particular emphasis on collaborating with justice in the case of potential violations that may constitute criminal acts in general, and particularly those that may result in direct criminal liability for the EVIDENZE GROUP, in accordance with the provisions of current legislation of each country where the GROUP operates or any other provision that may replace and/or complement in the future.

In all relationships with authorities and publics representatives of each country, we will always act respectfully and in accordance with the provisions of applicable laws to promote and defend our legitimate interests.

Recipients of the Code of Conduct will always collaborate with authorities and public representatives when exercising the functions legally assigned to them.

 

Integrity and objectivity in corporate conduct

Our goal is solely and exclusively to always achieve the most convenient alternative for our interests among all possible options, if these are allowed by applicable law and by this Code of Conduct.

The conduct of all recipients of the Code of Conduct must always pursue a single objective within certain limits:

a) Rejection of arbitrariness

Arbitrary actions cannot be taken, and one's own or third-party interests cannot be prioritized in any case, either to favour or harm them, by deciding different from what objectively is most convenient for the interests of the EVIDENZE GROUP.

b) Conflict of interests

A conflict of interest arises when personal interests interfere with a person's ability to exercise their judgment objectively or perform their work with honesty and transparency.

Examples of conflict of interest:

• Deciding or recommending the award of a contract from the EVIDENZE GROUP to a company where a family member of the person in charge of making the decision works.
• Making a business decision that may benefit a friend or family member of the person in charge of making the decision, either by directly benefiting from it or because the company they work for will benefit. This includes the hiring of immediate family members (first- and second-degree relatives) of key clients, to avoid conflicts of interest and ensure ethical business practices.
• Working for clients, suppliers, or subcontractors of the EVIDENZE GROUP, without prejudice to the responsibilities that may be incurred in terms of incompatibility while serving in the public sector.

When a recipient of this Code finds themselves in a conflict-of-interest situation, they must inform the Compliance Officer (see section 5.5.1) and refrain from making any decision on the matter in which there is a conflict. If the Compliance Officer indicates how to act after studying the potential conflict of interest, the recipient can then make the decision that objectively is the most convenient for the interests of the EVIDENZE GROUP.

When allowing a recipient of this Code in a conflict-of-interest situation to make the decision in which there is a conflict, the Compliance Officer will consider not only the integrity and objectivity of the person making the decision but also whether the objectivity image of the EVIDENZE GROUP may be affected in the eyes of third parties.

When the recipient of the Code of Conduct in a conflict-of-interest situation is part of a group of people collectively responsible for making the decision (such as committees or working groups), they will inform the rest of the individuals responsible for making the decision when it is collective and will abstain from participating in any vote.

c) Favouritism

Within its corporate values of integrity and teamwork, the EVIDENZE GROUP is committed to avoid favouritism or nepotism in decisions related to hiring, internal promotion, or training. In other words, aspects unrelated to the candidate's knowledge, experience, and personal merit, such as kinship or friendship with a GROUP employee, will not be considered in the decision-making process regarding these activities.

d) Respect for free competition

The EVIDENZE GROUP is committed to free competition. Therefore, whenever the GROUP competes with one or more competitors to carry out a commercial, business, or business operation, recipients of this Code will refrain from engaging in any practice contrary to free competition to favour the interests of the EVIDENZE GROUP.

Practices contrary to free competition include:

• Illegally obtaining information about the competitor's product or offer.
• The collusion, with one or more competitors, fix prices and other determining elements of the offer are being competed for.
• Disseminating false or distorted information that is detrimental to one or more competitors.

e) Honest negotiation

In EVIDENZE GROUP, we reject any type of corrupt practice, especially bribery. All recipients of our Code of Conduct will refrain from promoting, facilitating, participating in, or covering up any type of corrupt practice, including facilitation payments, and will report to the Compliance Officer any corrupt practice of which they become aware.

In the development of international business, the EVIDENZE GROUP will be guided by the recommendations and guidelines issued by business associations, the Compliance Officer, and the Organisation for Economic Co-operation and Development.

 

Respect for people and their diversity

Respect for people is a fundamental principle in all actions of the EVIDENZE GROUP.

a) Respectful treatment

Recipients of this Code of Conduct will always treat all individuals they interact with, whether they are recipients or familiar with this Code, with due respect. Disrespectful verbal or written actions or expressions against any person or group of people, whether present or not, will not be allowed.

b) Violence and aggressive behaviours

All recipients of this Code are strictly prohibited from engaging in any type of violent conduct and aggressive behaviour, including physical assault or the threat of physical assault, as well as verbal violence.

c) Equality and non-discrimination

In the EVIDENZE GROUP, we ensure equal and non-discriminatory treatment for all our employees regardless of their race, skin colour, religion, sex and sexual or gender orientation, nationality, age, political position, pregnancy status, degree of disability, and other legally protected circumstances.

The EVIDENZE GROUP is firmly committed to equality policies, and all recipients of this Code of Conduct must act accordingly, respecting such policies.

d) Harassment

The EVIDENZE GROUP prohibits and pursues acts of harassment in the workplace, including sexual harassment. Individuals who may consider themselves victims of harassment, or those who are aware of such situations occurring among their colleagues, have the reporting channel to communicate or report these situations.

e) Respect for Human Rights

The EVIDENZE GROUP has a general commitment to respecting the Human Rights of all individuals. Additionally, in the EVIDENZE GROUP, we maintain a special interest in monitoring and ensuring compliance with Human Rights in our relationship with EVIDENZE GROUP personnel, with special attention to those linked to business activities, such as the right to association (freedom of association and the right to collective bargaining), the rights of children and youth (elimination of child labor and forced labor), or the right to fair and satisfactory employment conditions.

 

Health and physical integrity protection

The safety, health, and well-being of the individuals who are part of the EVIDENZE GROUP constitute a fundamental asset for competitiveness, improving productivity and sustainability, as well as an essential value for full individual development.

This is why the practices determined by the regulations in the development of this matter will be respected and implemented.

a) Occupational Risk Prevention

At EVIDENZE GROUP, we attach the utmost importance to protecting the physical integrity and health of individuals and preventing any type of risk for them in the workplace.

At EVIDENZE GROUP, we maintain a clear commitment to informing all recipients of this Code of Conduct about the current regulations regarding occupational risk prevention, always considering that our fundamental principles in this matter are as follows:

• Maintain a real and effective integration of occupational safety and health in all our decisions and activities.
• Ensure a system of continuous improvement of working conditions to increase safety standards, measure service quality, and promote worker participation.
• Establish the necessary controls and guarantees so that the necessary compliance with the legal framework on occupational risk prevention is present in all decisions of the EVIDENZE GROUP.
• Promote the health and well-being of individuals by fostering healthy work environments and increasing individual capacity to maintain and improve physical and emotional health, as well as quality of life.

EVIDENZE GROUP strongly advocates for the safety, health, and well-being of individuals as the cornerstone of its business strategy and from its responsibility as a social agent.

 

Environmental protection

Environmental protection is one of our guiding principles, always proceeding in accordance with the laws and other regulations on environmental protection and developing our activities sustainably.

Our commitment is to ensure environmental protection by working respectfully, preventing pollution, and minimizing the environmental effects resulting from the activities we carry out.

To fulfil this commitment, we have established three fundamental pillars:

• Precaution: avoiding actions that may entail an environmental risk, regardless of the severity they may have if materialized.
• Prevention: avoiding the environmental consequences associated with a specific action.
• Correction: foreseeing how to counteract the environmental consequences of a risk in case it materializes.

All of us in the EVIDENZE GROUP embrace these pillars, and it is our responsibility to put them into practice.

To achieve this, the EVIDENZE GROUP ensures compliance with applicable environmental legal requirements in the territories where we operate.

 

Correct behaviour regarding stakeholders in the health industry

a) Import and export licenses and permits

In all import and export operations of any kind, EVIDENZE GROUP will always operate within the framework established by the applicable legislation of the countries involved.

b) Competition

When operating in international markets, EVIDENZE GROUP undertakes the commitment to always respect the legislation of different states regarding antimonopoly and competition practices. The recipients of this Code of Conduct involved in these operations must be aware of and comply with the requirements of the relevant state legislation on competition matters.

 

Use and protection of information

a) Protection of confidential information

The EVIDENZE GROUP has access to information from its clients and suppliers, which is provided under the commitment and obligation of confidentiality. In the EVIDENZE GROUP, we assume the commitment not to disclose and to protect this confidential information. This commitment must be assumed and fulfilled by all recipients of this Code of Conduct.

Like all companies, during its operations, the EVIDENZE GROUP generates information that is valuable to it or whose disclosure could harm its interests or operations in the market. In the EVIDENZE GROUP, we assume the commitment to regulate in a clear and reasonable manner the identification, handling, and protection of its confidential information. Recipients of the Code of Conduct must be aware of and comply with these regulations.

The EVIDENZE GROUP is a group of companies to which its clients and users can entrust information protected by the laws of different countries as confidential. This information must be treated with special care to ensure its protection, which the EVIDENZE GROUP takes as a priority in its dealings with clients.

Recipients of this Code of Conduct must be aware of and comply with the legal standards applicable to the handling, filing, and conservation of confidential information.

b) Protection of personal data

The laws of many countries protect the most sensitive information for individuals, especially for natural persons, preventing it from being disclosed or handled through computer systems without guarantees.

In the EVIDENZE GROUP, we take special care to protect personal data to which we have access during our activity, always complying with the applicable laws and regulations. Recipients of this Code of Conduct, responsible for handling or filing legally protected personal data, are obligated to be aware of the applicable legislation and ensure its proper application and compliance.

c) Transparency commitment

Whenever it does not affect confidential information, the EVIDENZE GROUP is committed to transparency in its actions, disclosing to the general public and our clients the information established by laws as well as that which is reasonable to disclose, regarding the activities and business of the EVIDENZE GROUP.

 

Protection of intellectual and industrial property

The intellectual and industrial property of the EVIDENZE GROUP includes methods, databases, materials, knowledge (know-how), programs, procedures, trademarks, domain names, patents, discoveries, designs, copyrights, strategic plans, and trade secrets, among others, regardless of whether they are registered in the corresponding records or even if they are not registrable as such.

In this regard, and as basic principles in this matter, those obligated by this Code of Conduct must be aware of their obligation to protect the intellectual and industrial property of the EVIDENZE GROUP, as well as their duty to respect that of others. Therefore, they will exercise special care and commitment to protecting intellectual and industrial property rights, both their own and those of others.

Employees must refrain from using information and intellectual or industrial property rights to which they have had access in their previous jobs or through personal or professional relationships with third parties outside the EVIDENZE GROUP.

Furthermore, as indicated by applicable regulations in this matter, any invention or discovery made by an employee in the course of their work is the property of the EVIDENZE GROUP, which will protect it in the manner it deems appropriate.

Finally, intellectual, and industrial property will be considered confidential information, and the provisions of this Code of Conduct regarding confidentiality will apply to it.

 

Maintenance of high ethical standards

The EVIDENZE GROUP and its employees must adhere to the highest ethical standards of behaviour in all the business activities and act in a way that enhances the reputation of the EVIDENZE GROUP within the industry.

We must remember that integrity is the foundation of all our corporate relationships.

Therefore, before deciding, we should ask ourselves:

• Is it legal?
• Does it align with the values of this Code?
• Am I acting ethically and responsibly?
• If others subject to this Code knew about the decision, how would they react?
• Would I agree that everyone should do the same as I am doing?

No code of conduct can cover absolutely every situation that may arise in our daily work and require an ethical or legal decision.

Employees facing situations not expressly covered in this Code should apply the philosophy and general concepts established in it, in addition to their own judgment and the highest ethical standards, as well as the assessment of supervisors, managers, and professionals at the EVIDENZE GROUP when applicable.

In case employees have any doubts or questions, they should consult the Compliance Officer before taking any action.

 

Criteria for the prevention of corruption

The individuals obligated by this Code commit to comply with current anti-corruption legislation and, especially, to maintaining scrupulous regarding activities that could be framed in corruption cases, whether involving private individuals or public officials, whether national or foreign.

EVIDENZE GROUP prohibits requesting or accepting, directly or indirectly, advantages or favours, whatever their nature, for personal benefit, with the aim of influencing the decision to establish, maintain, or terminate a relationship or business with a third party, derived or related to operations carried out by or on behalf of the EVIDENZE GROUP.

Likewise, it is strictly prohibited to promise or offer to a third party, whether a public official or private employee, directly or indirectly, gifts, bribes, or favours not authorized by the EVIDENZE GROUP, whatever their nature, with the aim of obtaining, securing, or retaining business or advantages in operations carried out by or on behalf of the same.

Within this prohibition, invitations to lunches and work dinners, general meals, are not included, as long as they are reasonable and moderate. In any case, a maximum amount per diner of 70 euros is set. Exceptionally, gifts with a symbolic economic value, understood as those not exceeding 50 euros, or promotional or courtesy gifts, are considered acceptable. In these cases, they must always be disinterested and should not seek to obtain specific behaviour or favouritism. Invitations considered within social, ordinary, and customary uses, and within reasonable and modest limits, may also be accepted.

In cases where the gift, attention, or invitation exceeds the amount of 50 euros, it must be reported to the Compliance Officer to act in accordance with internal rules.

However, notwithstanding all the above, in relationships with healthcare professionals, the direct offering or delivery of any gift or token is prohibited, except for the direct or indirect offering or delivery of professional-use utensils in medical or pharmaceutical practice, which must meet the following two conditions: (i) not be related to a prescription medicine and (ii) their market price does not exceed 10 euros.

For these purposes, any member of the medical, dental, pharmaceutical, nursing, or podiatry profession will be considered a healthcare professional, as well as any other person legally considered as such, or any other person who, in the exercise of their profession, could directly or indirectly influence or condition activities related to prescribing, purchasing, supplying, dispensing, or administering medicines for human use.

EVIDENZE GROUP expressly prohibits facilitation payments, meaning it is absolutely forbidden to make small payments to officials or other individuals to expedite or ensure the completion of routine administrative actions, such as obtaining official documents, processing documentation, or providing postal or public services.

Notwithstanding the above, those bound by the Code of Conduct who interact with healthcare professionals, healthcare organizations, or patient organizations must act in accordance with the ethical standards of the pharmaceutical industry.

 

Warning signs

In the development of business activities of the EVIDENZE GROUP, attention must be paid to certain factors that could indicate the possibility of corruption or bribery risks, including, among others, the following:

• Requests for cash payments to third parties or to an account that is not domiciled in the beneficiary's country or where the transaction takes place.
• Request for excessive remuneration or compensation above the market rate.
• Consulting agreements with vaguely described services.
• Suggestions for favorable treatment in exchange for the use of a particular local provider or intermediary; and
• Previous violations or breaches of applicable laws.

 

Record keeping

All payments made by the EVIDENZE GROUP must be adequately justified, for example, through receipts and invoices, which must be retained with a reasonable level of detail to accurately reflect the transactions.

Likewise, the accounting entries for all transactions must be made in accordance with accounting regulations.

The EVIDENZE GROUP expressly prohibits false accounting or the omission of maintaining accounting books.

 

Money laundering

The recipients of the Code of Conduct, especially those involved in the economic management of business units and order processing, shall refrain from promoting, facilitating, participating in, or concealing any type of money laundering operation, and shall proceed, in any case, to immediately report to the Compliance Officer any event that leads them to suspect the possible existence of behaviours typical of or related to money laundering.

 

Use of Public Resources and Taxation

The EVIDENZE GROUP will ensure that, when applicable, public funds and assistance requested or received from public administrations are used for the intended purpose for which they were granted, and that the application process is transparent, rigorous, and truthful.

The EVIDENZE GROUP will always comply with tax regulations, avoiding practices that involve the unlawful evasion of tax payments to the detriment of public funds.

 

Dissemination and application of the code of conduct

The Code of Conduct is available to all stakeholders through the various corporate websites of the EVIDENZE GROUP, and it will be also distributed by email to those stakeholders deemed appropriate.

Likewise, the EVIDENZE GROUP will carry out the necessary training, information, and awareness actions to ensure that all its employees have sufficient knowledge of this Code of Conduct and its contents.

In addition to general training and information, the EVIDENZE GROUP provides specialized training to those groups of its executives or employees who, due to the nature of their duties, need a more precise and detailed understanding of the conduct rules applicable to their area.

All recipients of this Code of Conduct will have the support and guidance of their superiors and the Compliance Officer to address any doubts regarding it.

 

Reporting channels

The EVIDENZE GROUP has a policy that outlines the general principles of the internal system for information and protection of whistleblower, meaning anyone who wishes to report a possible violation of the Code of Conduct, or provide information about misconduct in a professional or work-related context, as summarized in this section.

Whenever a recipient or someone knowledgeable about the Code of Conduct of EVIDENZE GROUP wants to report a potential violation to the Compliance Officer, or provide information about misconduct in a professional or work-related context, they can do so verbally or in writing through any of the following channels:

• The reporting channel is available on the websites of each of the EVIDENZE GROUP companies, by completing the requested information. The reporting channel allows for the option to submit an audio or voice file to communicate verbally.
• Email address: compliance@evidenze.com
• Regular mail, marking the envelope as "confidential", addressed to: Compliance Officer – Passatge Ferrer i Vidal, number 8 (08005), Barcelona.

The EVIDENZE GROUP has a procedure for managing the information or communications received, creating a record of both verbal and written reports using a form. If it is decided to open a case, the process described in this Code of Conduct is applied. The form is available at the following URL: https://channel.globalsuitesolutions.com/evidenze

 

Independence and confidentiality

The EVIDENZE GROUP, with the aim of protecting whistleblowers within the GROUP, ensures that anyone submitting a complaint or report through any of the established channels will have the confidentiality of their identity preserved, except when identification is required by authorities in accordance with applicable law.

The EVIDENZE GROUP also guarantees that the Compliance Officer will investigate the reported or communicated facts with complete independence from the management bodies of the GROUP.

In addition to ensuring the confidentiality of the whistleblower's identity, the EVIDENZE GROUP also safeguards the identity of any third party mentioned in the communication, as well as the actions taken in the management and processing of the report, and data protection, preventing access by unauthorized personnel.

 

Prohibition of retaliation

The EVIDENZE GROUP ensures that no reprisals will ever be taken, no threats of reprisals will be made, and no attempts at reprisals will be carried out against anyone who, in good faith, reports a possible violation of its Code of Conduct to the EVIDENZE GROUP.

This guarantee does not extend to those who act in bad faith or with the intention of spreading false information or harming individuals within the GROUP. Against such illicit conduct, the EVIDENZE GROUP will take appropriate legal or disciplinary measures.

 

Investigation of possible retaliation

The Compliance Officer will analyse the reported or communicated facts and may request information from other bodies within the EVIDENZE GROUP, which are always obliged to provide it, provided there is no legal prohibition to do so.

Unless current legislation dictates otherwise, as the investigation progresses, and if deemed appropriate by the Compliance Officer, the affected individuals may be informed of the events that occurred. This is to allow them to provide additional information and, if necessary, present arguments or justifications for their actions.

 

Non-compliance with the Code of Conduct

Anyone with knowledge of a potential violation of the Code must report it through the designated reporting channel or any other means provided for this purpose.

All professionals at EVIDENZE GROUP have a duty to cooperate in investigations into potential Code violations.

When the existence of a violation of the Code of Conduct that is pursued by the law is verified, the GROUP will proceed to inform the relevant authorities.

If the violation of the Code of Conduct authorizes the GROUP in taking disciplinary measures in accordance with the provisions of applicable labour regulations against its executives, employees, or collaborators, the EVIDENZE GROUP will initiate the necessary procedures, through the Human Resources Department, to implement them.

Finally, if the violation has been committed by representatives, agents, or intermediaries of EVIDENZE GROUP, actions will be taken in accordance with the terms of their respective contracts, which may include terminating the relationship.

The Chief Executive Officer of the GROUP will be competent for the imposition of disciplinary sanctions for violations of the Code of Conduct, and where applicable, the Board of Directors, for the most serious cases where there may be evidence of the commission of a crime.

The disciplinary proceedings will be conducted according to the following procedure:

• Opening and documentation of the file as soon as the facts are known through any channel. This file will be prepared by the Compliance Officer, with possible support from other departments, such as Legal or Human Resources.
• Hearing of the interested party within a period of 7 days. When there are indications of the commission of a crime, the Compliance Officer, together with legal advisors, may suspend the hearing of the interested party.
• Proposal for sanctions by the Compliance Officer, which will be submitted to the Chief Executive Officer for ratification or, if necessary, for submission to the Board of Directors.
• Finally, the interested party will be informed of the conclusion of the file and its disciplinary consequences, if any.

The application of the disciplinary regime will proceed according to applicable labour regulations and the procedure.

Disciplinary measures may be imposed on the person(s) who commit the violation, as well as on those who have approved the commission of the violation or have not taken appropriate measures to correct deficiencies or have not reported it despite knowing of the existence of a violation.

- Evidenze Group