Index

1 INTRODUCTION
2 CORPORATE VALUES
3 AIM
4 COMPLIANCE WITH CURRENT LEGISLATION
5 INTEGRITY, RESPONSIBILITY AND TRANSPARENCY
6 RESPECT, DIGNITY AND NON-DISCRIMINATION
7 ETHICAL BEHAVIOR
8 DIGNIFIED AND PLEASANT WORK ENVIRONMENT
9 OCCUPATIONAL HEALTH AND SAFETY
10 ABSENCE OF ILLEGAL DRUGS
11 CONFLICTS OF INTEREST
12 CONFIDENTIAL INFORMATION
13 USE OF DATA AND INFORMATION SYSTEMS
14 THEFT AND MISAPPROPRIATION OF ASSETS AND INFORMATION
15 PRIVACY AND DATA PROTECTION
16 BUSINESS RELATIONS
17 FRAUDULENT PRACTICES, FRAUD AND DECEPTIVE PROMISES
18 DISTURBANCES IN THE MARKET AND UNFAIR COMPETITION
19 BRIBES, CORRUPTION AND ILLEGAL COMMISSIONS
20 FACILITIES
21 RESPECT FOR THE ENVIRONMENT, COLLABORATION IN REDUCING ENVIRONMENTAL IMPACTS AND EFFICIENT USE OF ENERGY AND RESOURCES
22 COLLABORATION AND SUPPORT IN THE DEVELOPMENT OF SOCIETY
23 ORGANIZATION BEFORE THE PUBLIC AUTHORITIES
24 THE COMPANY AS THE CORE UNIT
25 FOLLOW-UP

1 Introduction
An ethics code is a set of guidelines that aims to establish acceptable behaviors and good practices for members of a particular group, association or profession.
Since its creation, Montero Traducciones, S.L. has been guided by client needs and expectations to offer language services of the highest quality. It strives to maintain this level of quality while respecting the environment, health and safety in the workplace, social responsibility and preventing criminal offences.
Today’s clients, shareholders, suppliers, private and public entities, and society in general, demand higher levels of responsibility and ethical behavior from companies. To meet this demand, Montero Languages Services Group requires all employees and subcontractors to act with integrity, responsibility and respect.
The main purpose of this Ethics Code is to highlight the values and principles required by the Company to carry out its daily activities.
This Ethics Code of the Montero Language Services Group. must be complied with by all employees, managers and administrators, meaning that it must be read, understood, accepted and shared and is sent to critical providers and collaborators so that they may voluntarily abide by it.

2 Corporate Values
The Montero Language Services Group, defines its “Corporate Values” as values that should be understood, adopted and implemented by all persons pertaining to or related to the Group in order to fulfill the following purposes and commitments set forth by the Group:

* Focus on customer satisfaction.
* Defining objectives that are aimed at meeting the needs and expectations of the Company.
* Social Responsibility. Commitment to the needs of the groups that are related to the Company and improving the quality of life of people.
* Commitment to the Environment. Commitment to the sustainable development of the Organization to minimize pollution.
* Fostering professional development. Commitment to analyzing employee training needs.
* Commitment to Health and Safety in the workplace. Commitment to action in order to prevent injuries and the deterioration of health.
With the “Corporate Values” established by the Montero Language Services Group, the Group aims to define the aspects in which people should establish the conditions and relationships in their professional activities. Observing these values is the foundation of this Ethics Code established by the Montero Language Services Group.

3 Aim
This Ethics Code aims to present the set of principles and recommended behaviors that will achieve ethical and responsible management in carrying out the company’s daily activities.
Its application will help ensure that the results obtained are consistent with the relevant legislation and with the image that the Company wishes to project both internally and externally.
This Ethics Code must be followed by all employees of the Montero Language Services Group, regardless of their position or time in the company.
Employees of the Montero Language Services Group participated in the drafting of this code by providing comments and suggestions prior to its approval.
This code is a regulatory tool that establishes the behavioral guidelines and directives in all areas of activity of the Montero Language Services Group. It also serves as a guide for making decisions in specific situations that involve employees.
The principles of the Ethics Code are the principles and guidelines that employees of the Montero Language Services Group should be governed by when performing their duties and responsibilities in all professional areas in which the Organization is represented.

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

5 Integrity, responsibility and transparency
Employees, managers and administrators of the Montero Language Services Group are committed to carrying out their roles and responsibilities in accordance with the established procedures.
Disparaging remarks or criticism that may undermine stability shall be avoided. All of this will result in establishing the reputation of the Company as an inclusive business that respects its clients, suppliers and other interested parties with which it maintains a relationship.
People in the Company will commit to acting with integrity and transparency when carrying out their activities.

6 Respect, dignity and non-discrimination
All employees of the Montero Language Services Group shall show respect and courtesy to their colleagues, clients and interested parties with whom they have or may have a relationship. The basis of a fruitful and satisfactory relationship begins with respect for the dignity of people, equal opportunities, dialogue and the non-existence of discriminatory or derogatory behaviors. All employees of the Montero Language Services Group have the right to work in a free and respectful environment.
Threats and acts of violence or intimidation will not be tolerated. Abusive, degrading or offensive behavior, whether verbal or physical, will not be allowed nor will any type of discrimination based on race, gender, age, nationality, religion or opinion in any other condition or circumstance, be it personal or collective.

7 Ethical behavior
In all work-related activities, decision-making or participation in decision-making and interpersonal relationships in the workplace, as well as compliance with legal obligations, conduct should be honest and transparent.
Ethical behavior must be based on three pillars: neutrality, confidentiality and loyalty.

8 Dignified and pleasant work environment
The Montero Language Services Group considers favorable and safe working conditions to be the basic elements of a work environment, referring to health protection, respect and equal opportunities.
The Company is committed to providing a workplace which is tidy and in accordance with the requirements of the applicable legislation for occupational risk prevention.
Employees will collaborate in keeping workstations clean and tidy, since an untidy workplace or area hampers efficient management of duties, responsibilities and resources.

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

10 Absence of illegal drugs
The possession, distribution or consumption of any type of drugs in the Group’s facilities is strictly prohibited. Likewise, smoking within the facilities is prohibited in compliance with current regulations.
No person shall be permitted to work under the influence of alcohol or illegal drugs.

11 Conflicts of interest
Conflicts of interest appear when a circumstance or situation arises where the personal interests of an employee differ from those of the Company.
An employee who detects any type of labor conflict should communicate it to the Department Managers, so that it is resolved as quickly and efficiently as possible.
All actions or decisions in which a person from the Group participates must be oriented towards the aim of maintaining the continuity and prosperity of the Group, as well as maximizing client satisfaction, respect for the environment, health and safety in the workplace, and the sustainable development of society.
Employees shall not carry out any activities or offer any services outside of the work relationship with the Montero Language Services Group that lead to a loss of efficiency or productivity in their work. Similarly, they shall not provide services to another entity related to language services in order to avoid conflicts of interest, nor shall they maintain business relationships with companies where there are personal or family interests, without prior notification to Company management.

12 Confidential information
If, for work reasons, there is access to confidential information or it can be used for personal gain, under no circumstances may it be used. Improper use may put the Company in a difficult situation in which its financial status could be affected. Confidential information shall be protected to ensure that no third parties read or obtain access to it.
Always try to avoid:
* Legible confidential papers on desks
* Absence from the workstation leaving visible information on the computer screen
* Transporting outside of the office and without adequate permission portable discs, USB drives or confidential information that has not been duly protected or encrypted,
* Including confidential information on servers or repositories with unrestricted access
* Failing to properly protect the confidentiality of personal passwords (sharing them with internal or external staff, writing them in visible places, passwords that are easily to guess)
* Failing to destroy sensitive information after its legitimate use
The commitment to neither supplying nor disclosing any type of private or confidential information about the Group and about participants or organizations related to the Group must be maintained.

13 Use of data and information systems
The use of e-mail and the Internet must be that which is necessary to carry out the job and its functions. These tools shall not be used in an abusive way for personal benefit nor for activities that may affect the image of the Company.
Nor will they be used to commit illegal acts or infringe the rules established by the Group in this Ethics Code. Only those with prior authorization shall have access to the IT systems, and no software that may affect the security of the systems shall be installed, used or distributed. Actions shall not be carried out that allow the entry of computer viruses. Unauthorized copies of computer programs are also prohibited.

14 Theft and misappropriation of assets and information
All employees shall safeguard assets and tools owned by the Montero Language Services Group as well as by third parties who may be at the Group’s facilities. This not only includes protection against non-authorized use, but also against the theft and use for illegal or improper purposes.
The removal, disposal or destruction of any object of value owned by the Group, except when carried out by managers in charge of this task, is prohibited.
All information contained in any physical medium (paper, cardboard, etc.) or in electronic medium is part of the knowledge base and value of the Group, and therefore is part of its property. It cannot be sold, transferred or acquired without authorization of the relevant department.

15 Privacy and data protection
All personal data received by the Montero Language Services Group (clients, CVs, suppliers, etc.) shall be kept completely private, since they pertain to Interested Parties that are essential for the continuity of the Group.
Likewise, the confidentiality of persons who file a complaint or make comments about any non-compliance of what is specified in this code shall be guaranteed. There is a channel established for this purpose called “Queremos saber (We want to know)” on the corporate website in the “Contact” section.

16 Business relations
All interested parties (shareholders, clients, suppliers, management, etc.) that have a relationship with the Montero Language Services Group are essential for projecting, maintaining and developing the image of the Group. Therefore, these relationships must be frank, loyal, respectful and ethical.
Relationships with suppliers and clients are of special importance, given their greater implication with the processes of the Group. There must be a commitment to provide clients with services that give them the greatest satisfaction, satisfying their needs and expectations.
When choosing suppliers, it is important to take into account product quality, cost of supplies and how environmentally and socially responsible the supplier is.

17 Fraudulent practices, fraud and deceptive promises
Interested parties have the right to receive information that is correct, specific and timely. When dealing with interested parties, no false promises or statements shall be made that are not the personal responsibility of those making them, or that compromise the image of the Group or make commitments knowing that they cannot be carried out, or that there is the intention of not carrying them out.
All employees of the Group shall ensure contractual integrity, ensuring that Suppliers and Clients comply with the established criteria during the duration of the contracts.

18 Disturbances in the Market and Unfair competition
The Group shall not partake in unfair client acquisition.
Acts of unfair competition are considered to be those that violate the national and regional laws that protect fair competition, in particular the following:
* All practices related to direct or indirect client acquisition that infringe upon the dignity of individuals,
* The use of third parties as a means to evade ethical obligations,
* The receipt or payment of compensation that does not comply with the legal regulations on competition,
* As well as all actions and behaviors gathered in Articles 5 to 17 of the Law on Unfair Competition, and the subsequent modifications, developments and interpretation of the relevant courts in this regard.
* Price-fixing with the competition
* Market-sharing with the competition
* Creating non-aggression pacts with the competition

19 Bribes, corruption and illegal commissions
All practices of corruption, bribery, favoritism, or illicit situations are prohibited. Persons of the Montero Language Services Group undertake not to request, accept or offer any form of illegal payment or commission.
Gifts, loans or invitations from third parties that could compromise independence or impartiality in business relationships shall not be accepted.

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

21 Respect for the environment, collaboration in reducing environmental impacts and efficient use of energy and resources.
Respect for the environment that minimizes as much as possible any impact we create with our activities creates well-being and is the base for sustainable development.
Reliability and maintenance of resources is essential for the Group’s credibility. The care, order and state of facilities and vehicles are necessary for the proper provision of the service. The misuse or overuse of resources increases environmental impact, such that the correct maintenance of installations, vehicles, assets, knowledge and efficiency when using resources is essential.
Each employee shall be responsible for the use of each resource, ensuring it is used efficiently, without loss and trying to generate the least amount of waste as possible and suitably managing them.
Employees of the Montero Language Services Group shall adopt the principles contained in the Manual of Best Environmental Practices.
Respect and compliance with this manual will ensure that environmental impact is minimized and that there is a rational use of resources.

22 Collaboration and support in the development of Society
The Montero Language Services Group is committed to the development of society. Active and committed behaviors will serve to create an ethical and responsible company that is engaged in sustainable development.
A responsible organization that aspires to form part of civil society must take into account the problems in society, as well as the support requested by governmental and non-governmental organizations.
The Montero Language Services Group will carry out actions and projects that reduce social needs and problems in a transparent way, so that the company’s development and economic growth is harmonious with society.
The Group will also support efforts against social inequality, hunger and disaster situations.

23 Organization before the Public Authorities
The Montero Language Services group has set forth the following core principles transparently, so that its economic development and growth remains in harmony with the public authorities:
* Cooperation and transparency
Maintain a relationship of transparency, collaboration and compliance with tax obligations with different government entities.
* Non-interference
Refrain from all forms of undue interference in political activity
* Honesty and the fight against corruption: the company shall maintain strictly professional relationships with political figures and civil servants. Management and employees are not permitted to offer payments, gifts, or any other special treatment, whether direct or indirect, which may constitute bribery or lead to the extortion of civil servants, political staff, parties, candidates, etc.

24 The Company as the core unit
In today’s socioeconomic world, Companies are centers of professional, economic and social development, such that as the value of a Company increases, so does the well-being and prosperity of its employees and its surroundings.
The Group is committed to:
* Continuous improvement
The commitment to management is based on efficient processes and systems, the systematic search for improvements, the identification and application of practical improvements and the internal analysis of the results obtained. The integrated and prioritized management of these activities is the principal channel that will ensure the Group’s survival and growth.
* Taking responsibility for actions carried out
In the event of consequences and claims arising from the actions carried out or the results obtained, they shall be responded to with respect, attention and appropriate responses. This includes the rational and thoughtful analysis of the circumstances that triggered them and the conveyance of an honest, ethical, swift and committed response.
* Fair Competition
Competition with other Companies should be fair and based on the search for differentiation through legal means. Advertisements shall always be truthful, without lying to enhance the Company’s own services or discrediting or criticizing the competition.

25 Follow-up
Management will hold a regular meeting once a year, and it shall be governed by the provisions of its regulations. To verify the effectiveness of this code, Management will be guided by the document that comprises all of the tools that are used by the organization, being able to request any clarification or additional information about them.
If, when carrying out its responsibilities, Management sees that the ethical values and principles of the Group or the regulations of this Code of Conduct are not followed, it will inform the relevant parties, taking into account the severity or significance of non-compliance in order to implement the appropriate measures.
Any person with questions about the Code of Conduct or who notices possible non-compliance should contact Management through its suggestions box, by sending an email or through the communications channel found on the corporate website, “Queremos saber (We want to know)”.
Management, when appropriate, will communicate this to the person or entity concerned, which will be responsible for responding to the person who had the question or informed of possible non-compliance.

In Brunete on April 08, 2020

MONTERO LANGUAGE SERVICES GROUP
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