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Code of Ethics and Conduct

Ethics and integrity, fundamental foundations of our organization

For Professionals of Legal Compliance, S.L.

Introduction

In Legal Compliance Spain (LCS) , ethics and integrity are the foundation of our organization. We expect all our staff to be honest and behave in accordance with the highest ethical standards, being governed by their desire to do the right thing.

This Code of Ethics and Conduct aims to serve as a guide, informative reference and source of inspiration to help all the professionals of our firm to choose the ethically most appropriate option in any circumstance.

Ethics programs and standards compliance play a key role, both to help early avoidance and detection of inappropriate behavior by organizations, and to promote ethics in business.

The development and rigorous implementation of effective ethics and compliance programs protects employees, investors, the business community, and the public at large. Our ethics and compliance professionals understand that the services we provide require the highest levels of professionalism, integrity and competence. The Code of Ethics recognizes the responsibilities of our professionals towards the general public, employers, clients and the profession itself. The Code of Ethics must be adopted by our employees and professionals in the discharge of their responsibilities.

The Code of Ethics is based on two kinds of rules: Principles and Rules of Conduct. The principles are broad rules that provide a general framework for the more specific and detailed Rules of Conduct. The Rules of Conduct contain specific standards that recommend the level of professional conduct expected of our employees and professionals. Compliance with these rules of conduct depends first and foremost on our own understanding and the voluntary actions of our professionals and, secondly, on the reaffirmation of compliance with these norms with co-workers and the general public.

Principle I

Obligations to the Public

Our professionals in ethics and compliance must accept and promote the values of corporate social responsibility and ethics in business with the spirit and code that govern the conduct of the organization and, through their professional conduct , To become a reference for the application of the highest standards in ethics to contribute to the public good.

Our professionals will not assist, assist, or engage in inappropriate acts, take steps to prevent irregular conduct, and promote compliance by the organization and all of our clients.

We take as objective the highest requirements that clients and the general public can expect in the provision of services by Legal Compliance as we understand that our reputation depends on the Quality of the services we provide, which is the responsibility of each and every member of our team.

Corruption undermines integrity and misuses power and position, which has a disproportionate impact on the most disadvantaged. Legal Compliance stands in an anti-corruption position in its actions.

Principle II

Obligations towards Institutions

Our organization undertakes to establish a climate of cooperation with the Authorities and Institutions and to remain permanently informed about the obligations that may correspond to it.

Principle III

Obligations to our customers

Our ethics and compliance professionals must serve our clients with the highest sense of integrity, make objective and impartial judgments, independently, without incurring any conflict of interest and promoting effective ethics and compliance programs in a personalized way And adapted to the context of the client and their true needs.

The services we offer to our clients must respect and comply with the standards and customs of the profession in the provision of services, and constantly strive to improve their quality. We respond to any need, adapting to your requirements under a firm commitment: to satisfy your concerns.

Our professionals and employees will be diligent in the management of the commitments established with the clients, covering their needs with appropriate personnel, with the adequate technical and professional level, keeping up-to-date continuously, in search of professional development and with adequate continuous training.

They will constantly monitor the quality of the services, the fulfillment of the commitments acquired with the clients and the adequacy of the reports issued to the standards of the profession.

We will always take the necessary steps, to help our clients to fulfill all their compliance obligations.

Our compliance professionals must reserve the confidentiality of the information obtained during the services provided to the clients by treating it with special responsibility, control and protection. In any circumstance, information owned by a client or Legal Compliance , whether confidential or not, obtained through work, must be used for strictly professional purposes. Any other use of such information is strictly prohibited.

All proposals to our clients will accurately describe the scope of services, experience in similar jobs and the curriculum summary of our professionals. We offer only those professional services that we are willing to fulfill and for which we have the experience and high professional knowledge. In no case do we offer services that could damage our trust in us or our independence and integrity towards our clients.

Our professionals will take special care to avoid any real, potential or perceived conflicts that may arise between Legal Compliance's interests and their personal interests, as well as the interests of other professionals, individuals and / or third parties. All decisions must be taken without being influenced by factors unrelated to professional judgment, always ensuring that an image of impartiality is offered, always acting in a legal and ethical manner before the appearance of any conflict of interest.

Principle IV

Obligations to Shareholders and Senior Management of LCS

Both the shareholders and senior management, as well as the highest governing body at all times, will be kept informed of the status and evolution of the ethics and compliance program, both as regards the implementation of the program and the Areas of risk in compliance. This rule complements the duty of senior management and the highest governing body to ensure that there is a system of information and reporting in the organization, reasonably designed to provide senior management and management with accurate and sufficient information to enable That management and management, each within its reach, can formulate an informed judgment, both on the organization's compliance with the law and on its business performance.

Principle V

Internal Obligations

We are committed to achieving the highest quality individually, in a team and in a corporate way.

We are required to strictly comply with all laws, regulations and rules applicable to our provision of services.

We represent Legal Compliance always and everywhere, with honesty and frankness, with maximum objectivity when it comes to alluding to facts or opinions.

Develop all our relationships with integrity, ethics and responsibility.

Be honest in our way of doing business and in the relationship with co-workers.

Ensure the confidentiality of the information that has been entrusted to us and protect the information whose rights belong to the signature.

Maintain our competitiveness with respect to developments in the profession, including the knowledge and familiarity of current theories, industry best practices and laws.

Legal Compliance recognizes that people and trust are the reason for their success. Therefore, it guarantees respect for human rights and pays special attention to the working conditions of its workers, as well as the health and safety conditions of its professional activity.

Principle VI

Obligations to the profession

Professionals in ethics and compliance must strive, through their actions, to maintain the integrity and dignity of the profession, to foster the effectiveness and advancement of ethics and compliance programs, and to promote professionalism in compliance Of such norms and ethics.

Our professionals will perform their professional duties, including investigations of irregular conduct, with honesty, fairness and diligence and exquisite professionalism.

Likewise, they will never disclose, without mediating a consent or coercive legal procedure, confidential information about the business affairs or technical procedures of our clients, whether present or past. Such disclosure could undermine confidence in the profession or affect the ability of ethics and compliance professionals to obtain such information from others in the future. Open communication depends on trust. The misuse and abuse of professional secrecy by ethics and compliance professionals poses a serious threat to ethics and compliance programs.

Principle VII

Obligations to the Environment

Our organization, in accordance with its Code of Ethics and Conduct, is committed to comply with the standards of respect and protection of the environment and its corresponding obligations in this field.

Código de ética y conducta Legal Compliance