Code of Ethics
1. Introduction and Purpose
LAUDE aspires to ensure that its conduct, and that of the individuals associated with it, complies not only with current legislation and its Corporate Governance System, but also with generally accepted ethical and social responsibility principles.
In accordance with the general procedures established for this purpose, this Code of Ethics and Conduct has been prepared to develop and define LAUDE’s Purpose and Values. Its aim is to establish the set of principles intended to guide LAUDE professionals so that they act with honesty and integrity in all activities carried out on behalf of the company.
The Code of Ethics forms part of the Corporate Governance System and fully respects the principles of corporate organisation established therein.
In addition, the Code of Ethics has been prepared taking into account good governance recommendations and the principles of responsibility adopted by the Company, constituting a fundamental reference for compliance throughout the organisation. It also responds to the prevention obligations imposed within the framework of the criminal liability of legal entities.
The Code of Ethics applies to all employees, collaborators, agents, consultants, business partners and any other individual or organisation providing services for or on behalf of LAUDE, regardless of whether they are permanent employees, temporary contractors, direct employees or supervised personnel. When using the term “LAUDE professionals”, this Code of Ethics refers to any such individuals collaborating with the company on a permanent or temporary basis, whether in internal company activities or in the delivery of services and projects to end clients.
This Code of Ethics has been approved by the Executive Committee and is available through our document management system as well as on the LAUDE website.
The Code of Ethics states that any breach of the law, this Code, or any other applicable policy or procedure may result in the corresponding disciplinary action, including dismissal, always in accordance with applicable legislation.
All professionals must commit to compliance with the Code of Ethics in order to enter into any contract or business relationship with LAUDE.
2. Ethical Structural Principles
2.1. Compliance with the Law and Human Rights
Within the scope of their activities, all LAUDE professionals must comply unequivocally with the law, as well as respect human rights and public freedoms. To this end, they shall adopt all necessary measures to guarantee respect for fundamental rights, the principles of equal treatment and non-discrimination, protection against child labour exploitation, and any other principles contained in the Universal Declaration of Human Rights and the United Nations Global Compact concerning human rights, labour rights, environmental protection and anti-corruption.
In the course of professional activity, any entity or individual working with, collaborating with or maintaining a relationship with LAUDE must diligently comply with applicable legislation, this Code of Ethics and LAUDE’s internal regulations (policies, rules and procedures) that may apply to them.
2.2. Quality and Excellence
LAUDE directs its research, development, commercialisation and operational activities towards achieving excellent quality standards in its services and products.
Excellence, as a core value of LAUDE, is reflected in a constant commitment to innovation and service, encouraging every team member to continuously strive for the highest standards across all operational areas. This principle lays the foundation for LAUDE’s sustainable growth and long-term reputation.
2.3. LAUDE’s Reputation and Prestige
LAUDE has built a strong reputation thanks to its extensive experience and a capable, loyal and committed team dedicated to the values and expertise that define LAUDE’s culture. Each and every professional contributes to strengthening LAUDE’s prestige and safeguarding its reputation.
2.4. Protection and Development of Human Resources
LAUDE promotes the professional development of individuals, taking into account a reasonable balance between company objectives and employees’ needs and expectations. Likewise, LAUDE encourages the continuous adaptation and improvement of the competencies and capabilities of the entire organisation.
2.5. Respect, Diversity and Workplace Safety
LAUDE is committed to creating a business environment in which diversity is respected and promoted. We seek to create a workplace where employees and collaborators feel valued and respected for their contributions.
All employees and collaborators must treat colleagues with respect. No discriminatory behaviour, harassment or intimidation (verbal, physical or visual) related to race, colour, religion, sex, age, origin, disability, sexual orientation or marital status will be tolerated. Employees must comply with our Equal Opportunities Policy in all aspects of their work, from recruitment and performance evaluation to interpersonal relations.
In addition, LAUDE is committed to providing a safe and healthy workplace. LAUDE professionals are responsible for carrying out their work safely for themselves and those around them. Regardless of their responsibilities, every LAUDE professional must perform their duties safely and immediately report to the Executive Committee any circumstance preventing the safe performance of their duties.
2.6. Respect and Commitment to the Community and the Environment
LAUDE is firmly committed to environmental protection and respect. Accordingly, it conducts its activities under the principle of minimising negative environmental impacts and preventing pollution, promoting research, development and innovation to improve processes, and ensuring that employees and professionals receive appropriate environmental management training.
LAUDE professionals are expected to adopt a proactive and participatory approach consistent with a commitment to the community, particularly in relation to social action and respect for social, economic and cultural environments.
2.7. Confidentiality and Transparency
All LAUDE professionals must protect the confidential information of the company and its clients. In the course of their activities, they may obtain information regarding LAUDE, its clients, suppliers or business partners that is confidential, commercially sensitive and/or private. In case of doubt, such information must always be considered confidential unless it is clearly identified as public.
Reasonable and necessary precautions must always be taken to protect confidential information against external disclosure and against unauthorised disclosure within LAUDE.
LAUDE information must only be used for company purposes, and only those individuals who genuinely need access to such information in order to carry out their duties shall have access to confidential information in accordance with the “need-to-know” principle.
Where business needs require the disclosure or sharing of confidential information, appropriate protection measures must be implemented. In case of doubt, the matter must be referred to LAUDE’s Security Officer.
2.8. Protection of LAUDE Property
All LAUDE property, whether tangible or intangible, must always be treated with respect and care.
LAUDE provides communication tools and devices, as well as Internet access at its facilities, for professional purposes. From time to time, they may be used for personal communications, but such use must always be brief and kept to a minimum. They must not be abused or used frivolously.
All forms of intangible property must be respected. This includes trademarks, copyrights and other assets (documentation, reports, etc.). Such assets must only be used to carry out professional activities.
Whenever possible, company facilities and other tangible assets must be protected against damage and vandalism.
Likewise, the intellectual property rights of others must be respected, and authorship must always be acknowledged.
LAUDE has developed its IT Resources and Security Usage Rules in order to specify the proper use of such resources.
3. Standards of Conduct
The specific standards of conduct regarding each of the groups and individuals with whom LAUDE interacts are aimed at:
- Quality and excellence in service in order to earn customer loyalty.
- The reputation and prestige we must convey to suppliers and business collaborators.
- The promotion and protection of our professionals.
- Strict compliance with the law in dealings with public authorities.
- Respect and commitment towards the community and the environment.
- Transparency in our activities in any organised markets in which we participate.
3.1. Relations with Clients
3.1.1. Honesty and Professional Responsibility
Any relationship with our clients must reflect a high level of honesty and professional responsibility, while also complying with the regulations applicable to client relationships.
Accordingly, commitments made to clients must be honoured, and any change, modification or variation to verbal or written agreements must be communicated sufficiently in advance. Transparency in relationships must be encouraged, and integrity maintained in all professional dealings with clients.
3.1.2. Contracts and Promotional Activities with Clients
Contracts and promotional activities involving LAUDE clients must be clear and straightforward, compliant with applicable regulations, and must not rely on evasive or otherwise improper practices, so that clients are provided with all relevant information necessary for informed decision-making.
LAUDE undertakes not to use misleading or false advertising tools. Marketing activities must provide clients with all relevant information required for appropriate decision-making.
3.1.3. Confidentiality and Privacy
Sensitive client information must be treated with absolute confidentiality and may only be disclosed to its legitimate owners or pursuant to an official request with the appropriate legal safeguards.
Commercial dealings with clients must, where appropriate, be conducted in an environment capable of ensuring the privacy and confidentiality of conversations, negotiations and documentation used.
LAUDE establishes that disclosing confidential information or using it for personal purposes constitutes a breach of this Code and may also amount to a criminal offence.
Accordingly, any reasonable indication of confidential information disclosure must be reported to LAUDE through the whistleblowing channel by anyone aware of such circumstances.
3.1.4. Conflicts of Interest
Any financial, family, friendship or other relationship between our professionals and clients may compromise independence in decision-making and could represent a potential risk of disloyal conduct arising from a conflict between personal interests and LAUDE’s interests.
Consequently, where such circumstances arise, they must be reported to LAUDE’s Executive Committee.
In particular, a conflict of interest shall be deemed to exist whenever the interests of the company conflict, directly or indirectly, with the personal interests of any LAUDE professional, as previously defined, or of any related person.
3.1.5. Gifts, Hospitality and Favours
LAUDE shall neither offer nor accept any gift or hospitality that could be interpreted as exceeding normal business or courtesy practices.
In particular, any form of gifts, hospitality or favours offered to clients that could influence their independent judgement or induce preferential treatment towards LAUDE or its professionals is prohibited.
Particular care shall be taken to avoid such conduct in international transactions involving LAUDE, given the potential difficulties in controlling such practices across jurisdictions and markets outside Spain and the negative impact such behaviour may have on the company’s international reputation.
LAUDE shall refrain from practices not permitted under applicable legislation, commercial customs, or the ethical or conduct codes, where known, of companies or entities with which it maintains business relationships.
Any gifts provided by LAUDE shall primarily be symbolic in value and intended solely to promote LAUDE’s brand image, never to restrict competition.
3.1.6. Complaints Management
Any complaint will be welcomed by our organisation, as it helps us to rediscover the direction that leads to excellence and professionalism in our services and products.
Accordingly, LAUDE professionals undertake to address, respond to, channel and, where appropriate, resolve any complaint or claim submitted by our clients.
3.1.7. Business Opportunities
No LAUDE professional may use LAUDE’s name or invoke their professional position in order to carry out transactions on their own behalf or on behalf of related persons.
No LAUDE professional may, for their own benefit or that of related persons, make investments or engage in transactions relating to LAUDE assets of which they became aware in the course of their professional duties, where such investment or transaction had been offered to LAUDE or where LAUDE had an interest therein, provided that LAUDE had not rejected such investment or transaction without the influence of the relevant professional.
3.2. Relations with Suppliers and Other Collaborators
3.2.1. Our View of Suppliers as Collaborators
New market challenges require a collaborative approach between LAUDE and its suppliers. Suppliers of LAUDE products and services are regarded as professionals or business collaborators.
3.2.2. Selection of Suppliers and Other Collaborators
The processes for selecting collaborators must be characterised by the pursuit of competitiveness and quality. In particular, LAUDE professionals shall not exclude any party that meets the required criteria from competing in the procurement of products and services, and selection decisions among candidates shall be based on objective and transparent criteria.
Where a supplier or collaborator, in the course of carrying out activities for LAUDE, adopts conduct inconsistent with the general principles of this Code of Ethics, LAUDE shall be entitled to take appropriate measures and may refuse future collaboration with such supplier.
3.2.3. Relationship with Suppliers
Relations with our suppliers are governed by common principles and are subject to rigorous quality, compliance and excellence controls by LAUDE.
Entering into a contract with a supplier must always be based on clear relationships and must avoid any form of dependency.
3.2.4. Relationship with Commercial Agents
LAUDE considers that commercial agents may represent part of its business strategy and that, on many occasions, the image projected by LAUDE to its clients may be closely linked to the professional conduct of its agents.
For this reason, LAUDE shall require every commercial agent or collaborator representing the company to be fully aware of and strictly comply with this Code of Ethics, and it shall act decisively in the event of any breach thereof.
3.2.5. Independence
The purchase of goods or services shall be carried out, at all levels, with complete independence of judgement and based primarily on quality and price criteria.
Any economic, family or other type of relationship must take into account the provisions set out in the previous section regarding potential conflicts of interest.
3.2.6. Gifts, Hospitality and Favours
Procurement managers shall exercise particular care in avoiding such practices.
3.3. Human Resources
3.3.1. Recruitment and Professional Promotion
LAUDE rejects any form of discrimination against its employees.
Within people management and development processes, as well as during recruitment and professional promotion stages, decisions shall be based on the suitability of expected profiles and the merits and qualifications of professionals.
Access to functions and positions shall also be determined according to competencies and capabilities. Furthermore, whenever compatible with overall operational efficiency, flexible working arrangements shall be encouraged in order to facilitate work-life balance.
3.3.2. Training
LAUDE provides all employees with information and training tools aimed at enhancing their specific competencies and developing the professional value of individuals.
Training responds to objectively identified organisational needs and takes into account the professional development of employees.
3.3.3. Gender Equality
LAUDE professionals shall respect the right to equal treatment and equal opportunities between women and men. In general, they shall actively promote the absence of any direct or indirect discrimination based on gender, as well as the defence and effective application of the principle of equality between women and men within the workplace, advancing measures that support work-life balance.
The principle of equal treatment and equal opportunities between women and men shall be guaranteed both in access to employment and in vocational training, professional promotion and working conditions, as defined in LAUDE’s Equality Plan.
LAUDE shall adopt the appropriate measures and decisions in response to any conduct that constitutes or causes gender-based discrimination.
3.3.5. Right to Privacy
LAUDE respects the right to privacy of all professionals in all its forms, particularly with regard to personal data.
Accordingly, LAUDE undertakes to request and use only such data as may be necessary or required by applicable regulations.
LAUDE shall not disclose the personal data of any professional without their express consent, except where legally required or in compliance with judicial or administrative decisions. Under no circumstances may employees’ personal data be processed for purposes other than those legally or contractually established.
3.3.6. Occupational Health and Safety
LAUDE declares its firm commitment to maintaining and developing the implemented Occupational Risk Prevention system, recognising the protection of workers as its primary objective in this area and promoting the integration of prevention measures at all levels of the Company.
LAUDE shall adopt the necessary measures to eliminate or reduce risks, ensuring compliance with applicable legal requirements, encouraging consultation and participation by employees, and raising awareness among all staff regarding risk prevention.
3.3.7. Moral Integrity
LAUDE undertakes to safeguard the moral integrity of its professionals by guaranteeing the right to working conditions that respect human dignity. For this reason, it protects employees against acts of psychological violence and opposes any discriminatory or harmful behaviour or attitude affecting individuals, their beliefs or their preferences.
Necessary measures shall be adopted to prevent and, where appropriate, correct sexual harassment, workplace harassment and any other form of violence or discrimination, ensuring that no LAUDE professional engages in conduct or speech that may offend personal sensitivities.
3.4. Relations with Public Authorities
3.4.1. Legality and Integrity in Relations with Public Authorities
LAUDE’s business activities frequently require participation in public tenders and procurement procedures, both domestically and internationally, which entails regular interaction with public authorities, officials and government bodies.
The principle governing all relations between LAUDE and public authorities, officials and government bodies shall be strict compliance with the applicable legal framework.
In particular, with regard to obligations assumed by LAUDE with public administrations both in Spain and abroad, special attention shall be paid to strict compliance with applicable tax, social security and anti-money laundering regulations.
3.4.2. Gifts, Hospitality and Favours
The principles set out in the previous section concerning gifts, hospitality and favours to clients shall equally apply to LAUDE’s relations with public authorities.
LAUDE shall neither offer nor accept from public officials, authorities or public bodies any gift or hospitality that could be interpreted as exceeding normal courtesy practices.
In particular, any form of gifts, hospitality or favours offered to Spanish or foreign public officials, auditors, board members, etc., which could influence independent judgement or induce preferential treatment, is prohibited.
LAUDE shall refrain from practices not permitted under applicable legislation, commercial customs or the ethical or conduct codes, where known, of the public administrations or authorities with which it maintains business relations.
Any gifts provided by LAUDE shall primarily be symbolic in value and intended to promote LAUDE’s brand image.
3.4.3. Political Parties
In compliance with the legislation of each country in which it operates, LAUDE shall refrain from engaging in any prohibited activity relating to the financing of political parties or the sponsorship of events whose sole purpose is political activity.
LAUDE shall also refrain from exerting any form of direct or indirect political pressure.
3.4.4. Competition Law and Regulatory Authorities
LAUDE complies and undertakes to comply with all local, national and international competition law regulations and shall cooperate with market regulatory authorities.
3.5. Relations with the Community and the Environment
3.5.1. Environmental Policy
LAUDE has environmental and sustainable business activity policies in place in accordance with current environmental legislation.
LAUDE’s environmental policy is also supported by the awareness that respect for the environment may represent a competitive advantage in an increasingly broad and demanding market in terms of quality and conduct.
3.5.2. Community
LAUDE affirms its commitment to contributing to the improvement of quality of life and the creation of wealth, both through the provision of its services and through new business activities or, in certain cases, by promoting the economic, social or cultural development of the communities in which it operates through non-commercial means.
3.6. Operations in Organised Markets
3.6.1. Transparency
LAUDE acts with complete transparency in order to guarantee the accuracy and truthfulness of the corporate, financial and corporate governance documentation it provides to organised markets and to prevent corporate offences and market abuse.
3.6.2. Information Control
LAUDE has procedures in place for the management and handling of confidential information, including protocols governing the external communication of documents and information relating to LAUDE, with particular reference to inside information.
In accordance with the above, all LAUDE professionals in possession of inside information are required to safeguard it and adopt the appropriate measures to prevent such information from being disclosed improperly.
4. Implementation
LAUDE’s Executive Committee is responsible for adopting policies that promote LAUDE’s ethical conduct and compliance with this Code of Ethics.
This Code of Ethics provides guidelines for day-to-day activities, but it does not cover every possible case or situation. Accordingly, employees’ conduct must always be guided by the principles set out in this Code.