Written policies and procedures are at the heart of every organization, and ADELTE Group policies define our values and reflect the organization’s commitment to operating according to the highest ethical standards. Our policies also reflect requirements of various laws and regulations with which all managers, employees and profesionals of ADELTE Group are expected to comply. You can read our Corporate Compliance Policies here or download it by clicking the following button:


This code of ethics (“Code of Ethics”) has been prepared by the Compliance Unit and approved by the Board of Directors of the company ADELTE Group S.L. The latter shall bring it to the attention of the Board of Partners, and it shall be disclosed to all managers, employees and professionals of ADELTE Group, S.L. and all its subsidiaries (“ADELTE Group”), as well as to interest groups deemed appropriate (clients, suppliers, collaborators, and advisors).

The establishment of this regulatory framework originates in the interest of the Board of Directors of ADELTE Group S.L. to provide ADELTE Group with the necessary procedures and training to ensure compliance with ethical and socially responsible principles of general acceptance, given the organic growth of the group, and the new relationships that derive from it.
For the purposes of this Code of Ethics, all directors and employees, as well as those persons whose activity is expressly subject to the Code of Ethics, are considered professionals of ADELTE Group (“Professional” or “Professionals”).

The ethical action must be understood in the same way within ADELTE Group, and be applied evenly in the actions of the Professionals with any person or group of interest with whom they deal with or have any relationship. If it considers it appropriate, ADELTE Group may request such persons or interest groups to voluntarily subscribe to this Code of Ethics, or include the necessary clauses in the framework of commercial agreements. This Code of Ethics aims to ensure that the rights and interests of all those affected are guaranteed. Ethics also implies strict compliance with applicable law and regulations, as well as the articles of association of group companies, and their internal regulations.

The principles and guidelines of conduct contained in the Code of Ethics apply to all Professionals of ADELTE Group, regardless of their hierarchical level and their geographical or functional location. Professionals, shareholders, administrative body and all those who are part of ADELTE Group, undertake to act ethically and in a correct way in the performance of their duties, both making sure that they comply themselves and ensuring compliance with the rules of this Code of Ethics throughout the organisation.

This Code of Ethics develops the principles established in the Mission, Vision and Values of ADELTE Group. It serves as a guide for the actions of its Professionals within the global and intercultural competitive framework in which the group operates.

The Code of Ethics has been developed taking into account the recommendations of good governance and the principles of social responsibility accepted by ADELTE Group, in addition to taking on the obligations of crime prevention in the area of criminal liability of legal persons. This Code of Ethics is the framework of commitment of ADELTE Group with the principles of business ethics and transparency in all areas of action, establishing a set of principles and conduct guidelines aimed at ensuring the ethical and responsible behaviour of all Professionals of the group in the development of its activity.

The Code of Ethics shall be sent to all partners, administrators and Professionals. It shall also be accessible through the group’s website and displayed on the intranet, alongside the rest of the group’s regulations. Those Professionals of ADELTE Group who, in the performance of their functions, manage or direct teams of people, must ensure that Professionals directly responsible to them know and comply with the Code of Ethics, and lead by example, becoming referents of conduct.


The compliance unit (“Compliance Unit”) is responsible for the interpretation and general integration of the Code of Ethics, since due to its nature, it does not cover all possible situations. Instead, it establishes the criteria for the guiding of the conduct of Professionals of ADELTE Group and, if necessary, resolve any doubts that may arise in the course of their professional activity.

Its interpretive criteria are binding for all Professionals of ADELTE Group. The Compliance Unit is a collegial body of an internal and permanent nature. It is linked to the Board of Directors of ADELTE Group, and it has autonomous powers of initiative and control, with competencies in the field of regulatory compliance and good governance processes. Whenever the applicable legislation allows, through the secretary of ADELTE Group’s Board of Directors it has access to the information (company documents, administrators, ADELTE Group Professionals, including minutes of the Board of Directors) necessary for the proper exercise of its functions. In this respect, all Professionals of ADELTE Group must provide the necessary collaboration they require for the proper exercise of their functions.
The Compliance Unit shall have the necessary material and human resources to perform its functions. It shall inform the Board of Directors of ADELTE Group, at least annually and whenever it deems appropriate or is required to do so, of the measures taken to ensure compliance with the Code of Ethics.

The Compliance Unit shall have the following competencies regarding the Code of Ethics:

a) Encourage the dissemination, knowledge and compliance with the Code of Ethics, promoting the training and communication actions it deems appropriate.

b) Ensure and coordinate the application of the Code of Ethics in ADELTE Group.

c) Interpret, in a binding way, the Code of Ethics, and resolve any queries or doubts that arise in relation to its content, application or compliance. And in particular, regarding the complaints channel and the application of disciplinary measures.

d) Drive the procedures to verify and investigate the complaints received and issue the appropriate resolutions on the processed cases.

e) Annually assess the degree of compliance with the Code of Ethics.

f) Inform the competent governing bodies about compliance with the Code of Ethics.

g) Promote the approval of the rules required to develop the Code of Ethics and to prevent its breaches.

h) Approve procedures and protocols of action to ensure compliance with the Code of Ethics.

The composition and functioning of the Compliance Unit shall be regulated in the regulation of the unit itself. These must be approved by agreement of the Board of Directors.

The competencies of the Compliance Unit, in accordance with the Code of Ethics, shall be understood without prejudice to the management and supervisory responsibilities that correspond to the administration of ADELTE Group and its management bodies.


ADELTE Group shall respect and comply with any judicial or administrative decisions that may be issued, but reserves the right to appeal, whenever appropriate, such decisions or resolutions when it understands that they are not in accordance with law and contravene its interests.

ADELTE Group operates in several countries with very different legislation and regulations, and shall always apply and respect this Code of Ethics provided that the applicable local regulations are not stricter, in which case the latter shall apply.

3.1.1. The compliance framework for the partners of ADELTE Group is the following:

– They shall always consider as compatible the creation of wealth inherent to the activity and the attainment of benefits, with the principles broken down in this Code of Ethics, respect of compliance with the applicable regulations, the rights of employees, the environment and the promotion of sustainable social development.

– When making decisions, they shall adopt a vision of the company in the medium and long term, adapting to the needs of each moment.

– They shall exercise their right vote in a responsible way, informing themselves properly, and taking into consideration the interests of the company as a whole when they make decisions.

– They shall respect the right of participation and argumentation of partners in minority or disagreement with majority decisions.

3.1.2. The compliance framework for administrators and managers of ADELTE Group includes:

– They shall act ethically and responsibly in the exercise of their functions.

– They shall comply with the Code of Ethics, collaborating with the Compliance Unit to make it known, and establishing the appropriate means to ensure its implementation.

– Administrators shall provide sufficient information to the partners so that
they can make the appropriate decisions at the meetings of the Board.

– They shall ensure compliance with the legislation and regulations in force in all procedures and departments of the company. They shall also have special prudence in the knowledge and compliance with international legislation and regulations that may be applicable.

– The managers of ADELTE Group must ensure that the Professionals who depend on them receive the suitable information and training that allows them to understand and fulfil the legal and regulatory obligations applicable to their job, in accordance with this Code of Ethics and the internal regulations of the group.

– They shall guarantee that the accounts accurately reflect the true and fair image of ADELTE Group, confirming the application of generally accepted accounting principles and standards in the preparation of the accounts, introducing, if necessary, further internal or external control mechanisms.

– They shall provide external professionals, consultants, auditors, etc. with truthful, complete and detailed information, as required by their duties.

– They shall act with ethics, transparency and good repute, prioritising the interests of ADELTE Group and avoiding situations of conflict of interest.

– They shall abide by the processing of information under this Code of Ethics in Section 3.8., with special emphasis on the confidential nature of the information that may be considered strategic, even when they no longer provide their services to the company.

– They shall ensure compliance with payment obligations by diligently fulfilling contractual obligations, as well as paying taxes. Likewise, they shall defend the interests of the company demanding the timely collection of credits and demanding compliance with the contractual obligations acquired by third parties.

– They shall choose their collaborators and subordinates according to the principles of merit and capability, seeking only the interest of ADELTE Group.

– They shall ensure the quality and safety of their products, in order to avoid possible incidents or accidents that may cause damage to property or individuals.

3.1.3. Current Legislation

The Professionals of ADELTE Group shall strictly observe the legislation in force in the place where they carry out their activity, taking into account the spirit and purpose of the rules. They shall also abide by the provisions of the Code of Ethics and the basic procedures that regulate the activity of ADELTE Group and the companies in which they render their services. They shall also fully respect the obligations and commitments taken on by ADELTE Group in its contractual relations with third parties, as well as the uses and good practices of the countries in which the group operates.

The guiding criteria that the conduct of the Professionals of ADELTE Group must follow, shall be professionalism, integrity and self-control in their actions and decisions:

a) Professionalism is a diligent, responsible, efficient action, focused on excellence, quality and innovation.

b) Integrity is a fair, honest, in good faith, objective action, in line with the interests of ADELTE Group and its principles and values stated in Section 1.3 of the Code of Ethics “Mission, vision and values of the ADELTE Group”.

c) Self-control in actions and decision-making, which implies that in any action carried out, the following must be assessed:

  1. that the action is ethically acceptable;
  2. that it is legally valid;
  3. that it is desirable for the company and ADELTE Group; and
  4. that the person is willing to take on responsibility for it.

The internal regulations of ADELTE Group include the following points:

a) Policy of non-discrimination based on race, colour, nationality, social origin, age, sex, marital status, sexual orientation, ideology, political opinions, religion or any other personal, physical or social condition of its Professionals, and equal opportunities.

b) Principles of respect for people. ADELTE Group rejects any manifestation of violence, physical, sexual, psychological, moral or other harassment, abuse of authority at work, and any other conduct that creates an intimidating or offensive environment for the personal rights of its Professionals.

c) Reconciliation of family life with work activity, to the greatest extent permitted by the labour policy of ADELTE Group.

d) Right to privacy. Respect for this right also refers to personal data, which shall not be disclosed except with the consent of the interested parties, and in cases of legal obligation or compliance with judicial or administrative decisions, and to medical and economic data; also to the respect of personal communications of its Professionals through Internet and other means of communication.

e) Responsible use of the media, computer systems and, in general, any other means that ADELTE Group makes available to the Professionals, in accordance with the policies and criteria established for such purpose.

f) Access by the Professionals to the resources and means necessary and suitable for the development of their activity. Professionals commit to making a responsible use of them, and to not use them for personal matters.

g) Commitment of the Professionals not to generate wasteful expenditure that diminishes the creation of value for the shareholders.

h) Occupational health and safety. ADELTE Group has legal preventive measures regarding the occupational health and safety programme. They promote the abidance of rules related to occupational health and safety, both internally and by suppliers and collaborators.

ADELTE Group shall promote the training of its Professionals. Training programmes shall promote equal opportunities and career development, and contribute to the achievement of the group’s objectives. The Professionals of ADELTE Group are committed to constantly updating their technical and management know-how, and to take advantage of the internal training programmes.

ADELTE Group shall have a strict and objective selection programme, exclusively considering the academic, personal and professional merits of the candidates and the needs of the group, which shall assess its Professionals in a strict and objective way, taking into account their individual and collective professional performance.

The Professionals of ADELTE Group shall not be able to give or accept gifts or gifts in the performance of their professional activity.

As an exception, the delivery and acceptance of gifts or presents shall be allowed if all of the following simultaneously occur:

a) they are of insignificant or symbolic financial value, which for the purposes of this Code of Ethics, are those that do not exceed the amount of 200 euros per unit, and that do not consist of units for smaller amounts that, added up, imply a higher financial value.

b) they correspond to signs of courtesy or to customary business gifts; and

c) are not forbidden by law or by generally accepted business practices.

Except for the aforementioned exceptions, the Professionals of ADELTE Group may not, directly or through an intermediary, promise, offer, grant, give, solicit, receive or accept unjustified advantages or benefits that are indirectly or directly intended to obtain a benefit, whether present or future, for ADELTE Group, nor for themselves or for a third party. In particular, they may not promise, offer, give, accept or receive any kind of bribery, from or performed by any other party involved, such as public officials, whether Spaniards or foreign, staff of other companies, political parties, authorities, clients, suppliers and shareholders.

Acts of bribery, which are expressly forbidden, include the offer or promise, whether direct or indirect, of any kind of improper advantage, any instrument to conceal them, and influence-peddling. Also, Professionals shall not be able to receive, on a personal level, money from clients or suppliers, even in the form of loans or advances. The Professionals of ADELTE Group shall not be able to promise, offer, give, accept or receive hospitality that influences, might influence or can be interpreted as an influence in the making of decisions.

When there is doubt as to what is acceptable, the offer must be turned down or, if necessary, previously discussed with the immediate hierarchical superior, who may refer the question to the Compliance Unit.

A conflict of interest shall be deemed to exist in situations in which the personal interest of the Professional and the interest of the ADELTE Group collide, whether directly or indirectly.

Personal interest of the Professional shall exist when the matter affects the professional or a person related to them. The following shall be considered as persons related to the Professional (“Related Persons”):

a) The spouse of the Professional or the person with a similar relationship of affection.

b) The ascendants, descendants and siblings of the Professional or the Professional’s spouse (or person with a similar relationship of affection).

c) The spouses of the ancestors, descendants and siblings of the spouse (or person with a similar relationship of affection).

d) The entities in which the Professional, or Related Persons, by themselves or through an intermediary, are in any of the control situations established by law.

e) Companies or entities in which the Professional, or any of the Related Persons, by themselves or through an intermediary, exercise an administration or management position, or a position from which they receive remuneration for any reason, provided that they also directly or indirectly have a significant influence on the financial and operating decisions of such companies or entities.

By way of example, these are some situations that could give rise to a conflict of interest:

a) Negotiating or formalising contracts on behalf of the company with any Related Persons of the Professional or with legal entities in which the Professional, or a Related Person, holds a management position, is a significant shareholder or a director.

b) Being a significant shareholder, director, adviser, etc. of clients, suppliers, or direct or indirect competitors of the company. Regarding possible conflicts of interest, the Professionals of Adelte Group shall abide by the following general principles of action:

a) Independence: To act at all times with professionalism, with loyalty to ADELTE Group and its shareholders and independently of their own or third parties’ interests. Consequently, they shall always refrain from giving priority to their own interests at the expense of ADELTE Group.

b) Abstention: To refrain from participating or influencing decision-making that may affect ADELTE Group with which there is a conflict of interest, from participating in meetings at which such decisions arise, and from accessing confidential information regarding such conflict.

c) Communication: To report on conflicts of interest that may arise, prior to the execution of an operation, to the Compliance Unit. The latter shall assess the situation and make the appropriate decisions, providing advice, if necessary, on the appropriate actions in each circumstance. To be able to determine the existence of possible incompatibilities before accepting any public position, the Compliance Unit or administrative body of ADELTE Group shall be informed thereof.

Business opportunities shall be considered those investments or any operations related to the assets of ADELTE Group which the Professional becomes aware of in the course of their professional activity, when the investment or operation has been offered to the group or when it has an interest in therein.

Professionals shall not be able to take advantage of business opportunities for their own benefit or of Related Persons, unless ADELTE Group has ceased to exploit the business and the Professional is authorised by the group to carry out such business. However, they shall not be able to use the name ADELTE to carry out
operations for their own account.

ADELTE Group shall inform its Professionals about the main lines of its strategic objectives and the progress of the group. Professionals shall respect the confidentiality principle regarding the characteristics of the rights, licenses, programmes, systems and technological knowledge, in general, owned by ADELTE Group or which it has the right to operate or use. The disclosure of any information related to such characteristics shall require prior authorisation from the superior.

The use of the equipment, systems and software that ADELTE Group makes available to professionals for the performance of their work, including easy access and operation on the Internet, must comply with safety and efficiency criteria, excluding any use, action or computer function that is unlawful or contrary to the rules or instructions of ADELTE Group and its computer regulations. The Professionals shall not exploit, reproduce, duplicate or transfer the computer systems and applications of ADELTE Group for purposes that are beyond their control. Likewise, Professionals shall not install or use, inside the computer equipment provided by the group, programmes or applications the use of which is illegal or that may damage the systems or damage their image or their interests, or the image and interests of clients or third parties.

ADELTE Group reserves the right to check that Professionals comply with the rules regarding the use of computer equipment, systems and software.

Non-public information owned by ADELTE Group shall generally be deemed to be for internal use, unless it has been classified as private or confidential. In any case, it shall be subject to professional secrecy and it shall not be provided to third parties other than in the normal course of their work, profession, or duties, provided, however, that those to whom the information is disclosed are subject, by law or under contract, to a duty of confidentiality and that they have confirmed the company that they have the necessary means to protect it.

It is the responsibility of ADELTE Group and all its Professionals to take sufficient security measures and to apply the established procedures to protect the internal, confidential and private information recorded on physical or electronic media, against any internal or external risk of unauthorised access, tampering or destruction, both intentional and accidental. For these purposes, the Professionals of ADELTE Group shall keep the contents of their work confidential in their relations with third parties.

Disclosing confidential or private information, or using it for private purposes, is a breach of this Code of Ethics. Any reasonable indication of leakage of confidential or private information for personal purposes must be notified by those who are aware of it to the general management or to the Compliance Unit.

In case of termination of the employment or professional relationship, all internal, confidential and private information shall be returned by the Professional to ADELTE Group, including documents and storage media or devices, as well as information stored in any corporate or personal electronic device. In any case, the
duty of confidentiality of the Professional shall continue.

4. Relationship with Stakeholders

ADELTE Group, in all cases applying transparency, information and protection rules, undertakes to offer services and products with a quality equal to or higher than legally established requirements and quality standards, competing in the market and carrying out marketing and sales activities based on the merits of its products and services.

The Professional shall keep its clients’ data confidential, undertaking not to disclose them to third parties, unless the client consents, or due to legal obligation or in compliance with judicial or administrative decisions.
The collection, use and processing of personal data of clients must be carried out in a way that guarantees the right to privacy and the compliance with the legislation on the protection of personal data, as well as the rights granted to clients by the legislation on information society and electronic commerce services and other applicable provisions.

Contracts with ADELTE Group clients shall be drafted in a simple and clear way. Transparency shall be favoured in pre-contractual and contractual relations with customers. The latter shall be given the several existing alternatives, particularly regarding services, products, and rates. Contracts shall include an “anti-bribery clause”.
The processes for supplier selection implemented by ADELTE Group shall be objective and impartial, and they shall avoid any conflict of interest or favouritism in their selection.

The Professionals of ADELTE Group accept to comply with the internal procedures established for the awarding processes, including, especially, those related to the approval of suppliers.

The prices and information submitted by suppliers in a selection process shall be treated confidentially and shall not be disclosed to third parties, unless the interested party consents or there is a legal obligation, or in compliance with
judicial or administrative decisions.

The Professionals of ADELTE Group who access personal data of suppliers or customers, must keep such data confidential and comply with the provisions in the legislation on protection of personal data, to the extent applicable.

The information provided by the Professionals of ADELTE Group to the suppliers shall be truthful and not intended to be deceiving.

All Professionals of ADELTE Group are subject to this Code of Ethics. Professionals shall be treated with dignity, respect and justice, taking into consideration their differences.

Professionals shall not be discriminated against because of their race, religion, age, nationality, sex, sexual orientation or any other personal or social condition that is outside their merit and capability. The remuneration and promotion of the Professionals shall be linked to their merit and capability conditions.

As stated in Section 3.2, ADELTE Group rejects any type of harassment, whether physical, psychological or moral, as well as any conduct that may lead to a hostile environment.

The consumption of alcohol, tobacco, or illegal substances in any work centre of ADELTE Group is considered unethical. Clear criteria and rules shall be established and disseminated in order to keep the rights of ADELTE Group and Professionals balanced in contracting processes, and in the event of their termination, even in case of voluntary change of employee. It shall seek the work integration of people with disabilities, eliminating all types of barriers within the company to favour their inclusion.

The Professionals of ADELTE Group are committed to competing in the markets in a fair way, and shall not carry out misleading or denigrating advertising of its competition or of third parties.

Obtaining information from third parties, including information from the competition, shall be inexcusably be carried out in a legal way. The Professionals of ADELTE Group are committed to promote free competition for the benefit of consumers and users, to comply with regulations on protection of competition, avoiding any conduct that constitutes or may constitute a collusion, abuse or restraint of competition.

Relations with the media shall be channelled through the Marketing Department of ADELTE Group.

Transparency regarding the information to be disclosed is a basic principle that should govern the performance of the Professionals of ADELTE Group. The economic and financial information, especially the annual accounts, shall faithfully reflect its economic and financial position, and its equity, in accordance with generally accepted accounting principles and applicable international financial reporting standards.

Lack of honesty in the communication of information, whether internally or externally, is considered a breach of the Code of Ethics. There is also lack of honesty when delivering incorrect, incomplete information, organising it in an incorrect way or trying to confuse those who receive it.

Human rights and democratic institutions shall be respected and promoted where possible. ADELTE Group expresses its commitment and solidarity with the human and workers’ rights recognised in national and international law, and with the principles that serve as a basis for the United Nations Global Compact, the United Nations Norms on the Responsibilities of Transnational Corporations and Other Business Enterprises with Regard to Human Rights, the OECD Guidelines for Multinational Enterprises, and the Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy of the International Labour Organisation, as well as such documents or texts that replace or supplement the ones mentioned above.

Specifically, ADELTE Group expresses its total rejection of child and forced or compulsory labour, and undertakes to respect freedom of association and collective bargaining, as well as the rights of ethnic minorities and indigenous peoples wherever it develops its activity. The principle of political neutrality shall be maintained, not interfering politically in the communities where it develops its activities, also as a matter of respect for the different opinions and sensibilities of the people linked to ADELTE Group.

The Professionals of ADELTE Group shall interact with the public authorities and institutions in a lawful and respectful way. The provision of employment or professional services, or their own account or for the account of another, to companies or entities other than ADELTE Group, as well as a professional engaging in or participating as educational staff in academic activities when they are related to the activities of the group or the functions that
the Professionals perform in it, must be authorised in advance and in writing by
the management responsible for human resources.
Prior approval from the management in charge of human resources shall also be necessary in the following cases:

a) Active participation or appointment of the Professional in the administrative or management bodies of professional or sectoral organisations or associations representing ADELTE Group.

b) Any other kind of external activity that may affect the professional dedication of the Professional to their duties or may cause a potential conflict of interest situation. ADELTE Group respects the performance of social and public activities by its Professionals, as long as they do not interfere with their work in the group.

The connection, membership or collaboration of the Professionals with political parties or with other types of entities, institutions or associations for public purposes, shall be made in such a way as to make clear their personal nature, thereby avoiding any connection with ADELTE Group. Likewise, the creation, membership, participation or collaboration of the Professionals in social networks, forums or blogs on the Internet, and the opinions or statements that take place in them, shall be made in such a way as to make clear their personal nature. In any case, the Professionals must refrain from using the image, name or brands of ADELTE Group to open accounts or to register in these forums or networks.

ADELTE Group expresses its firm commitment to the principles set out in the Code of Ethics on combating corruption and fraud and on crime prevention, and in particular the failure to carry out practices that may be considered illegal in the performance of their relationships with customers, suppliers, competitors, authorities, etc., including those related to money laundering.

The Professionals shall be able to collaborate with the Public Authorities and with entities and non-governmental organisations dedicated to improving the levels of social welfare for the most underprivileged.

ADELTE Group, either directly or through intermediaries, shall refrain from making contributions that are not in accordance with the social responsibility strategy in this sense. All welfare contributions made, regardless of their legal form, either through a collaboration agreement, a donation or any other legal figure or business, and regardless of the area of social responsibility for which they are intended (promotion of education, culture, sports, protection of vulnerable groups, etc.), must meet the following requirements:

  • have a legitimate purpose,
  • not be anonymous,
  • be formalised in writing,
  • when they are monetary contributions, be made by any payment method that allows for the identification of the recipient of the funds. Cash contributions are forbidden.

ADELTE Group performs its activity based on respect for the environment. It meets or exceeds the standards established in the environmental regulations that are applicable, and it minimises the impact of its activities on the environment. The companies of ADELTE Group assume conduct guidelines to minimise waste and pollution, preserve natural resources, promote energy savings, as well as to carry out and sponsor research and development projects that promote the protection of the environment.

5. Complaints Channel

This Code of Ethics is mandatory for all employees and Professionals of ADELTE Group, who must adhere to it, personally committing to its compliance, as well as to communicate possible breaches they become aware of. For such purpose, ADELTE Group has implemented a complaints channel that allows confidential communication of any irregularities they may encounter.

All Professionals of ADELTE Group are obliged to inform the Compliance Unit of the initiation, evolution and outcome of any judicial, criminal or administrative procedure of a punitive nature, in which a Professional is the defendant or accused party, and that can affect the latter in the exercise of their functions as an employee of ADELTE Group or damage the image or the interests thereof.

The Compliance Unit has created a mailbox (“Mailbox”): compliance (at) adelte.com, in order to promote compliance with the law and rules of conduct established in this Code of Ethics. The mailbox is a channel for Professionals of ADELTE Group to inform about any conduct that may involve the commission of an irregular act or an act in violation of legal provisions or of the rules of conduct laid down in the Code of Ethics or to ask questions that may arise regarding the interpretation thereof Communications addressed to the Mailbox may be sent by completing an electronic form that shall be available in the “Mailbox” section, in the subsection dedicated to Criminal Compliance.

Professionals who have reasonable indications of the commission of any irregular act or of any act in violation of legal provisions or of the rules of conduct laid down in the Code of Ethics, must report it through the Mailbox or any of the other mechanisms established by ADELTE Group for this purpose. In any case, such communications must always meet the criteria of truthfulness and proportionality, in such a way that this mechanism cannot be used for purposes other than those that seek compliance with the rules of the Code of Ethics.

The identity of the person reporting an irregular action through the Mailbox shall be deemed to be confidential information and, therefore, it shall not be communicated to the reported party without the consent of the reporting party. This ensures non-disclosure of the identity of the reporting party and avoids any kind of response towards the reporting party from the reported party as a consequence of the report.

ADELTE Group undertakes not to take any form of retaliation, whether direct or indirect, against Professionals who have, in good faith, reported through the Mailbox an action among those referred to in the framework of this Code of Ethics. Notwithstanding the foregoing, the data of the persons making the communication may be provided to the administrative or judicial authorities, to the extent that they are required by such authorities as a result of any proceeding arising from the subject matter of the complaint, as well as to persons involved in any subsequent investigation or judicial proceedings initiated as a result of the investigation. Such provision of data to the administrative or judicial authorities shall always be carried out in full compliance with personal data protection legislation.

The processing of the complaints made through the Mailbox corresponds to the Compliance Unit. In the event that the complaint affects a member of the Compliance Unit, such member shall not be able to participate in its processing. In any investigation, the rights to privacy, defence and presumption of innocence of those investigated shall be guaranteed.

No one, regardless of their level or position, is authorised to request that a Professional commit an illegal act or breach of provisions of the corporate governance system, especially the Code of Ethics. In turn, no Professional can justify improper or unlawful conduct or conduct that contravenes what is established in the governance system of ADELTE Group, based on an order from a superior.

If the Compliance Unit determines that an employee or Professional of ADELTE Group has engaged in activities that breach the provisions of law or the Code of Ethics, it shall entrust to the general management the application of disciplinary measures in accordance with the offences and penalties system set forth in the collective bargaining agreement in which such Professional is included or in the applicable employment legislation.

The data that are provided through the Mailbox shall be included in a personal data file owned by ADELTE Group for the management of the communication received in the Mailbox, as well as to carry out of any investigation actions necessary to determine the commission of the breach.

ADELTE Group undertakes to treat all personal data received through the Mailbox as completely confidential at all times and in accordance with the purposes contemplated in this Section 5, and it shall adopt such technical and organisational measures as may be needed to ensure the safety of the data and avoid the alteration, loss, or unauthorised processing thereof or access thereto, taking into account the current state of the art, the nature of the data stored, and the risks to which they are exposed, all in compliance with the laws on personal data protection.

In any case, ADELTE Group shall use in each data collection form those notices legally required to clearly inform the interested parties of the purposes and uses of the processing of their personal data. In general, the reported party shall be informed of the existence of a complaint at the time of the initiation of the investigation. However, in those cases in which there is a significant risk that such notification could jeopardize the ability to effectively investigate the allegation or collect the necessary evidence, notification to the reported party may be delayed for as long as such a risk exists, complying with the applicable legal regulations in all cases.

Persons who make a communication through the Mailbox must guarantee that the personal data provided are true, accurate, complete and up to date. In any case, data processed under the investigation shall be deleted as soon as it has finished, unless administrative or judicial proceedings are taken as a consequence of the measures taken. Likewise, ADELTE Group shall keep said data duly blocked during those periods in which any liability may arise from the reports carried out by Professionals of ADELTE Group or actions carried out by the latter, or during those periods that are legally applicable, if these are shorter.

Users of the Mailbox may at any time exercise their rights of access, correction, cancellation and objection regarding their personal data by means of a written communication addressed to ADELTE Group’s registered office, accompanied by a photocopy of their national identity document and mentioning the specific right they wish to exercise.

6. Updating

The Code of Ethics shall be revised and updated periodically, in accordance with the annual report of the Compliance Unit, as well as suggestions and proposals made by the Professionals of ADELTE Group.

The Board of Directors and the Compliance Unit may make proposals to improve or promote the adaptation of the Code of Ethics as a whole. Any revision or updating that involves an amendment of the Code of Ethics, even if
required by the domestic legislation of one of the countries in which ADELTE Group
operates, shall require the approval of the Board of Directors.

7. Acceptance

The Professionals of ADELTE Group expressly accept the rules of conduct established in the Code of Ethics. Professionals who in the future join or become part of ADELTE Group, shall expressly accept the principles and rules of conduct established in the Code of Ethics.
The Code of Ethics shall be annexed to the future employment contracts of all Professionals of ADELTE Group. A copy of this Code of Ethics shall be delivered to all Professionals of the group who must adhere to it and commit to its compliance, and report possible breaches.

8. Approval

The Code of Ethics was approved at the meeting of the Board of Directors of ADELTE Group S.L. held on 26 April 2017.