CODE OF ETHICS OF TRELIA DATA SL

INTRODUCTION
The code of ethical conduct is our guide to proper conduct, together with the established work rules and procedures, to guarantee what is correct and that, as a logical consequence, no crime occurs in the company.
The Code constitutes a guide for all employees of TRELIA DATA SL. in their professional performance in relation to their daily work, the resources used and the business environment in which they work. It offers guidelines that clarify the basic principles of all management and interpersonal relationships with colleagues, collaborators, bosses, suppliers, customers, shareholders and, in general, any person with a direct or indirect interest in the activity carried out by the company. Our actions are based on respect for our corporate values, and employees will accommodate behaviour principles that are respectful of business ethics and professionalism, with the aim of being a benchmark in these terms and thus being recognised.

AREA OF APPLICATION
This Code is addressed to all employees of TRELIA DATA SL., regardless of the contractual modality that determines their employment relationship, position they occupy or the place where they perform their work. There is an obligation for those related to the company to inform its main suppliers of the existence of this Code, which will be available for consultation on the company’s website www. treliadata.com

VALUES
Our values represent our identity as a collective. We are different because the people who work at TRELIA DATA SL make this company a unique and differentiating project. We are fast, we know how to listen, we seek innovation, we are helpful and we work rigorously and transparently as a team.

  • We make quick decisions and act quickly and dynamically.
  • We quickly focus on the solution to a problem by proposing realistic, quality and viable alternatives.
  • We quickly adapt to the changes and demands of the environment professional.
  • We listen carefully to our internal and external clients to know exactly their needs and propose appropriate solutions.
  • We have the eyes and ears of the client in any operation that develop, continually asking for your satisfaction.
  • We listen actively, with an open attitude and respect for the opinion of all parties involved in a situation.
  • We actively seek opportunities to improve products and services and create new business opportunities.
  • We take advantage of opportunities and problems to provide innovative solutions.
  • We constantly update our technological knowledge to be pioneers in innovation.
  • We know the needs and expectations of our clients to develop and apply solutions that increase their satisfaction.
  • We serve our clients efficiently, maintaining at all times an agile and decisive behaviour that enhances the credibility and reputation of the company and its professionals.
  • We serve clients with the utmost interest and strive to interpret their demands, this being the priority characteristic of the attitude of all our professionals.
  • We know how to work in multidisciplinary teams, from different units, companies and countries generating a climate of trust and mutual respect.
  • We cooperate with the rest of the organization assuming commitments aimed at achieving common goals.
  • We direct our efforts towards the same result, taking into account the contribution of each one of the members no matter how small it may seem.
  • We respect differences, opinions and diversity.
  • We are respectful with the environment and sustainability policies.
  • PRINCIPLES OF ETHICAL BEHAVIOR.

The ethical behaviour that governs this society is based mainly on:

GOOD FAITH
We adjust our actions at all times to the principles of loyalty and good faith with the company, with superiors, colleagues and collaborators with whom we interact. We emphasize the desire for achievement and the spirit of improvement. The concern to achieve the objectives set must be constant and continuous. We promote optimistic versus pessimistic attitudes. We subordinate personal objectives to the general ones of the Company. We ensure that there is no conflict between the two, and we act giving priority to the interests of the company over personal interests or those of third parties.

HONESTY
All employees of TRELIA DATA SL. undertake to declare any personal or professional relationship that could condition our behaviour as employees of the Company. In addition, as employees of TRELIA DATA SL., we do not accept compensation or undue advantages. We instil honesty and professional ethics in the usual commercial and professional relationships in the performance of our work, both in the private sector and in our relationships with Public Administrations. We do not offer gifts or promise undue favour treatment to third parties, whether public or private, in order to obtain an advantage. We promote trust to declare the gifts or advantages that we can obtain from third parties and make them available to the company. Any personal or professional relationship that affects the interests of the Company is reported to the immediate superior. We do not allow personal or family relationships in direct dependency or within the same organisational unit.
We avoid conduct contrary to free competition, or that suppose an act of unfair competition. In advertising campaigns we offer information clearly and truthfully.

RESPECT
Each and every one of us is responsible for generating an atmosphere of cordiality and friendliness in our surroundings. We promote respect and trust between people. We appreciate diversity in opinions, training and culture as a source of knowledge and competitive advantage. We take care of the language we use when talking about third parties and we encourage the non-existence of defamatory guidelines and comments inside and outside the organization. We promote respect for real equality of opportunities between men and women, avoiding any scenario of direct or indirect discrimination.
No person employed at TRELIA DATA SL. is discriminated against in the professional field due to race, physical disability, religion, age, nationality, sexual orientation, sex, political opinion or social origin. We maintain a work environment free of all discrimination and any conduct that implies harassment of a personal nature, not admitting any form of physical, sexual, psychological or verbal harassment or abuse. We respect the environment and collaborate with the sustainable development of society.

CONFIDENTIALITY
We refrain from providing, internally or externally, confidential data about people and/or activities carried out in the Company. We provide, however, the data that is necessary for other employees of TRELIA DATA SL to correctly perform their function, with strict respect for this duty of confidentiality. We avoid conduct contrary to free competition, or that which involves an act of unfair competition. In advertising campaigns we offer information clearly and truthfully. Principles of ethical behaviour, respect, confidentiality and use of information. We comply with the personal data protection regulations in relation to which we have access due to our job. The employees of TRELIA DATA SL. we are characterised by a marked proactive attitude in dealing with confidential information. The information is the property of the Company and should be shared whenever it is beneficial and necessary for the Company. In our conduct:

  • We provide those responsible with truthful, necessary, complete and timely information about the progress of activities in our area; and to our colleagues, that which is necessary for the proper performance of their duties.
  • We maintain the professional secrecy of the data, reports, accounts, balance sheets, strategic plans and other activities of TRELIA DATA SL. and its people, which are not of a public nature, and whose publicity may affect the interests of the company. We will not provide information on these, except when we are expressly authorized to do so.
  • We obtain information from third parties in an ethical and legitimate manner, rejecting any information obtained improperly or that involves a violation of company secrecy or its confidentiality.
  • In the event of having doubts about the proper treatment of the information, we request the assessment of our manager about its correct cataloguing.
  • We may not use the programs, computer systems, manuals, videos, courses, studies, reports, etc., created, developed or perfected in TRELIA DATA SL for our own purposes, or those of third parties, or for profit or profit, since the company retains at all times the intellectual property of these.
  • In general, we maintain the strictest confidentiality in the use of internal knowledge outside the scope of the company, preserving our know-how.
  • We will only use the computer systems, software, material, reports, etc. of which TRELIA DATA SL. has acquired the corresponding license, respecting at all times the intellectual and industrial property of these.
  • The use of computer equipment is subject to the information security policy of TRELIA DATA SL. with the aim of avoiding damage to third parties and/or the company itself.
  • We will not use access to the systems to act fraudulently or for our own benefit.

10 QUESTIONS BEFORE MAKING A DECISION
Asking yourself these questions will help you decide on the behaviour to follow.

  1. Is it against work regulations?
  2. Does it seem to be the right thing?
  3. Is it legit?
  4. Will it have a negative effect on my reputation or that of the company?
  5. Who else can be affected by this (other people in the entity, customers, suppliers?
  6. Would I feel ashamed if others knew that I have resolved to act this way?
  7. Is there an alternative solution that does not pose an ethical conflict?
  8. How would I look if the actions were published in the newspapers?
  9. What would a reasonable person think?
  10. Will I be able to sleep peacefully?

PRINCIPLES OF PROFESSIONAL BEHAVIOR

CUSTOMER SATISFACTION
All employees aspire to offer our customers a product of the highest quality and to have an excellent level of service. Excellence and quality of service are constant guidelines for action, promoting a healthy concern for continuous improvement. The resources provided by the company seek to promote innovation and the development of customer services, with profitability criteria. All of us, regardless of the functional area in which we work, are committed to our client’s satisfaction. We promote honest attitudes towards the client.

EFFICIENT MANAGEMENT
The employees of TRELIA DATA SL  work efficiently during the working day, making the most of the time and resources that the company makes available to us in a rigorous and rational manner. We all lend the dedication that the performance of our functions requires, aspiring to achieve results in the most optimal and productive way possible. The Company makes available to us all the necessary resources to carry out the work and improve performance by optimising the time and scope of the information necessary to fulfil our responsibilities. Therefore, we must make appropriate and reasonable use according to the professional needs of each one. We do not engage in personal activities during business hours that interfere with or prevent you from fulfilling job responsibilities.
We use e-mail, internet access and, in general, the Company’s computer systems exclusively for work purposes and their use for personal use is expressly prohibited. We expressly authorise the Company to control the use of these. Unacceptable use of company communications systems includes processing, sending, retrieving, accessing, displaying, storing, printing, or otherwise disseminating materials and information that are fraudulent, harassing, threatening, illegal, racial, sexist, obscene, threatening, defamatory, or otherwise inconsistent with professional conduct. In terms of safety at work and professional health, we will comply with preventive measures, using the individual and collective means of protection that the company has available. Managers will ensure that the members of their teams carry out their activity in safe conditions.

TEAMWORK
The company’s employees will favour teamwork and recognize the contribution of others in obtaining common results. As members of a team, we contribute with equal commitment both inside and outside our area. The teamwork attitude prevails and stands out over any performance at the individual level. An outstanding individual is also outstanding because of their ability to work as a team, and therefore there is no conflict between this behavior and being excellent individually. Individual interest does not prevail over the interest of the team. We avoid passive attitudes: we don’t get carried away and we don’t stay on the sidelines. We encourage enthusiasm and commitment to the group and therefore to the organization. We act in a spirit of cooperation, making available to the other areas and departments of the entity the knowledge and resources that facilitate the achievement of the company’s objectives.

PRESERVING OUR REPUTATION
We consider the image and reputation of the company as one of its most valuable assets to maintain the trust of its customers. We monitor the respect and correct use of the corporate image and reputation, by all the people in the company’s environment. The brand image is visually captured with our company logo, of which there are rules of use that protect its use and that we must respect. We are especially careful in any public intervention, and must have the necessary authorisation to intervene before the media, participate in professional conferences or seminars and in any public media, provided that they appear as employees of TRELIA DATA SL. We are all part of the corporate image and therefore we assume an ethical and responsible conduct that allows us to preserve the image and reputation of the company. At no time will we engage in behaviour that may damage the image. Our way of communicating, conducting ourselves and our own personal image will be in line with the professional context in which we operate.

PROFESSIONAL
Our professional growth and that of our teams is our key to being competitive. Employees are responsible for our professional growth, and consequently it is our duty to be permanently updated with the knowledge and techniques required for the efficient performance of our work. People with teams in charge must pay attention to the motivation and professional development of their collaborators, committing to provide them with development opportunities based on merit and their professional contribution. To do this, they will promote their continuous learning, they will recognize their efforts in a specific way and objectively assess their achievements, drawing up the precise action and support plans for their development.

ENFORCEMENT OF THIS CODE OF ETHICS

This Code of Ethical Conduct entered into force after its approval on May 6, 2022. The original Code of Ethics was implemented and approved by TRELIA DATA SL, on June 6, 2021.
The Code will be communicated to all members of the Company. It will be in force as long as its modification or cancellation is not approved, which will be duly communicated.
We each take it upon ourselves to review and follow this Code, and we comply with all applicable laws, policies and guidelines. This Code attempts to cover many of the situations that we face on a day-to-day basis, but it cannot consider all the circumstances.
All professionals must inform our supervisor of any conduct that we believe, in good faith, to be a violation of the Code of Ethical Conduct.
If any of the above three are involved in the situation we wish to report or cannot or have not adequately resolved our concerns, we will report them to a more senior manager or HR manager. H H. of the area or to the person in charge of criminal compliance of the company, and it is reported that all personnel have at their disposal an Ethical Channel through which it is possible to notify, in a totally confidential manner, behaviours or acts contrary to ethics, to current legislation , to this Code of Ethical Conduct or to the practices of good corporate governance that govern our Company, with special emphasis on those that could have criminal consequences.
We do not discriminate or retaliate against employees for reporting actual and proven violations in good faith. The Appointments and Remuneration Committee will ensure compliance with this Code, resolve incidents or doubts about its interpretation and adopt the appropriate measures for better compliance.
Failure to comply with this code may lead to the adoption of disciplinary measures, including the possibility of dismissal and, where appropriate, the exercise of appropriate legal actions