ETHICAL CODE

Article 1.- Objective, scope of application.

The code of ethics, hereinafter code, provides the rules that should guide the behavior of all employees, collaborators, suppliers and professionals of Profile Software Services, S.L, hereinafter Profile, in decision making and in their day to day.

This code is mandatory for all persons who work or professionally collaborate with Profile, collaborators and supplier companies.

With the application of the code, it is intended that the people who perform their activities in our company demonstrate an upright, ethical and professional behavior at all times and thus contribute to the good environment. Report any inappropriate conduct that may damage the image or reputation of the company.

To this end, it is essential to comply with the law, which implies the obligation, without exception, to comply with the law and with internal policies and regulations. All staff, collaborators and professionals must behave ethically in all their actions and avoid any conduct that, even without violating the law, may damage Profile’s reputation and negatively affect its interests, that of its members and its public image.

Our professional behavior, both by action and omission, must be in strict compliance with this code, as well as with the socially acceptable standards of conduct at all times.

All the actions of the addressees of this Code, as a consequence of their relationship with Profile, must be guided and governed by the values and objectives contained herein.

Article 2.- Guidelines of conduct in Profile and the relationship with employees, professionals and collaborators in general.

1. Ethical commitment

Profile, assumes as a fundamental value of its performance the respect for the person and dignity, seeking to promote a healthy and productive work environment, which channels the potential of the people who work in it. In this sense, the company is committed to:

  1. Comply with labor laws and regulations.
  2. Respect and encourage respect for the differences and opinions of others, with the consequent prohibition of all types of harassment, discrimination, intimidation and offensive or inappropriate behavior, including proposals or suggestions of a sexual nature, graphic material and other actions that may offend the dignity of people.
  3. Promote equal opportunities in access to employment and professional promotion, avoiding situations of discrimination or inequality based on birth, sex, origin, social or sexual status, marital status, religion, union membership or any other personal or social circumstance.
  4. Promote a work environment that is compatible with professional development, collaborating with the people in their charge to reconcile work commitments with family responsibilities and personal needs in the best possible way.

This code serves as a basis, since it does not cover all conceivable situations and does not describe all the particular rules to be followed. It must therefore be borne in mind that violations of the law and ethical principles can have very serious consequences for the company. Employees and professionals who violate the principles contained herein cannot claim to have acted in Profile’s favor because any violation of the rules seriously harms the company.

We must avoid, identify and report both potential and actual conflicts of interest, never putting personal interests ahead of those of the company, including those arising from family or related relationships. In such situations we must:

  • Refrain from intervening or participating in the negotiation or operations in question.
  • Immediately inform our superior; from that moment on, it will be the superior or the person designated by him or her who will decide on the operation and take the corresponding decision, unless it corresponds to a higher instance.

Any gift, attention, discount or invitation that, due to its value, frequency or other characteristics, may be understood to affect the objective criteria in the decision making of the person receiving it, must be rejected. In this case, the employee shall inform his or her superior.

As an exception, promotional objects of low, symbolic or common value in the sector, invitations considered ordinary or customary in accordance with social and sectorial customs and within reasonable limits, as well as occasional gifts or attentions for commemorative circumstances or exceptional celebrations in accordance with social traditions and customary business practices, provided that they are merely representative in nature, are not affected by the above limitations and may therefore be accepted.

To avoid incurring in a breach of company regulations, in case of doubt about the acceptance of any gift, attention, discount or invitation, as well as its destination or enjoyment, the recipient employer shall inform his/her superior so that he/she may bring it to the attention of the competent body that must ensure compliance with and interpretation of this code.

Profile’s professionals and employees have the obligation to make responsible use of the goods and facilities that the company places at their disposal, with the utmost care and diligence, using them only for the purpose for which they have been delivered and refraining, in any case, from giving them a use that is not for the benefit of the company. In addition, the company’s resources must be preserved and protected from inappropriate or fraudulent use by third parties, which could pose a risk to Profile.

2. Professional secrecy, use of the information obtained.

In general, all collaborators are bound to professional secrecy regarding the information and data that Profile makes available to them and that they learn in the exercise of their professional activity, both related to the company, distribution companies, supplier companies, customers, or any third party that maintains a relationship with the company.

The use of the information will be exclusively for the performance of our professional activity, and we will not be able to facilitate it only to those collaborators and employees of Profile, who need to know it for the same purpose and subject to the same duty of professional secrecy.

We must consider the information to which we have access as reserved and, therefore, use it within the framework of the established rules, such as those regulating the protection of personal data. It is also necessary to remember that we must not transfer information about the company to the outside unless we are authorized to do so.

Information relating to commercial data, financial and personal conditions, addresses, production, accounting, taxation, business and, in general, any other information about the company must be treated in a confidential manner to ensure its confidentiality.

The information must never be used for personal benefit or for the benefit of a third party.

3. General guidelines of conduct.

The selection of suppliers will be carried out ensuring the application of objective criteria. Profile expects its suppliers to understand and share our standards of business ethics.

We must ensure that all relationships are conducted in a fair manner and in accordance with internally established rules.

If we are involved in the selection or decision on the procurement of supplies or services, or the negotiation of rates or other conditions, we will avoid any kind of interference that could affect the transparency and objectivity of the process.

4. Whistle-blower channel.

In order to promote the application of values in the organization and to structure the way to solve ethical dilemmas, this section establishes a mechanism for the administration of the code. Profile provides its employees and collaborators with a whistleblower channel through which all complaints received will be managed and resolved. This channel is managed and regulated by the person in charge of the company’s Labor Department, whose functions include resolving any doubts about the legal or ethical nature of a situation that is reported or denounced, the surveillance and monitoring of this code, reporting directly to the company’s Management.

The open communication of situations and concerns by professionals without fear of negative consequences is vital for the proper implementation of this code. Profile urges its staff and professionals to comply with the obligation to report any breach of this code, and everyone is committed to cooperate in any internal investigations initiated for non-compliance with this code.

The company will thoroughly investigate any communication made in good faith. Information submitted in connection with reported cases will receive a professional and confidential response.

The principles of behavior contained in this code are, as in the rest of the rules defined by the company, mandatory for all the people who are part of and participate in Profile.

Article 3.- Interpretation.

The contents of this Code must be interpreted in a manner consistent with the rest of the Company’s codes and standards, as well as in accordance with social customs and regulations in force at any given time.

Article 4.- Exceptions to compliance.

Any exception to compliance with the provisions of this Code of Ethical Conduct shall require the approval of the Company.