Suppliers Code of Conduct

OBJECTIVE

This Supplier Code of Conduct (“Supplier Code”) sets forth the principles and considerations for entities or individuals delivering goods or services (“Supplier”) to INOX TORRES GROUP, S.L. (ITG) or on its behalf. In this document, the term Supplier also includes independent contractors and subcontractors who provide goods or services to ITG or on its behalf.
ITG does not condone illegal or unethical behavior by its Suppliers, contractors, and partners; it selects its Suppliers through a fair procurement process. This code of conduct details the minimum required standards and complements the terms and conditions of Supplier purchase contracts with ITG. This Supplier Code of Conduct does not exempt the Supplier from its financial responsibility, practicing good practices, and obtaining guidance related to business conduct.

PROFESSIONAL REQUIREMENTS

ITG is required to comply with various laws, regulations, and professional standards to maintain independence from clients, which may also affect Suppliers. When appropriate, ITG will guide Suppliers regarding these requirements. Additionally, ITG will conduct due diligence questionnaires with Suppliers to evaluate the relationship with ITG. If necessary, the Supplier must provide information to ITG to assist in this process.

PRINCIPLES GOVERNING THE SUPPLIER CODE

ETHICS AND INTEGRITY

Suppliers must not engage in any illegal or unethical practices and are expected to maintain fair business practices. They must also commit to providing tools that allow their employees and contractors to report incidents related to unethical behavior.

CORRUPTION

Suppliers must not offer or accept bribes, nor influence a third party to offer or accept bribes on their behalf. It is prohibited to offer, give, request, or receive any type of bribe; to offer or provide any item of value to a third party for an inappropriate purpose or to gain an unfair advantage; and to offer incentive payments. Suppliers must make reasonable efforts to prevent bribery in all its forms and support efforts to combat corruption.

GIFTS AND ENTERTAINMENT

Suppliers must not offer, accept, or request gifts, entertainment, and hospitality that could be considered a subterfuge for a bribe or could improperly influence decisions or harm the objectivity of their business.
MONEY LAUNDERING AND SANCTIONS
Suppliers must not engage in activities, conduct business, or enter into agreements that could directly or indirectly involve ITG in money laundering or terrorist financing activities. Suppliers must comply with current laws and regulations and trade control regulations regarding the import, export, and transfer of goods and services.

INSIDER TRADING

Suppliers must not engage in transactions or speculation with non-public and confidential information obtained from their relationships with ITG.

CONFLICTS OF INTEREST

Suppliers must not allow prejudices, conflicts of interest, or inappropriate third-party influences to override their professional judgments and responsibilities. They must not engage in transactions that could create a conflict of interest concerning the supply of goods and/or services. Suppliers must immediately inform ITG of any potential conflict of interest regarding business with ITG.

IT SECURITY, PRIVACY AND CONFIDENTIALITY

Suppliers must always take necessary measures to protect, collect, and handle confidential and personal information appropriately, including physical and electronic assets obtained from ITG or ITG’s clients. This information should be used strictly for the purpose it was provided. Suppliers must immediately inform ITG of any incident involving unauthorized access, disclosure, or loss (potential) of such information, including, but not limited to, theft, damage, destruction, cyber-attack attempts, etc.

HUMAN AND LABOR RIGHTS

Suppliers must maintain a workplace characterized by professionalism and respect for the dignity of each worker and each person with whom their workers interact. They must treat all workers with dignity and respect and must not subject them to degrading conditions; they must not tolerate discrimination; they must foster a culture and workplace where equal opportunities for all are promoted and must not tolerate harassment, threats, or retaliation for reporting harassment.

Suppliers must not engage in or support human trafficking or slavery and must not use forced or involuntary labor, nor require work or service from a person under threat or coercion. Suppliers must not benefit from child labor, nor hire underage workers.

Suppliers must respect workers’ right to freedom of assembly and must not prevent workers from organizing legally and joining associations.

Suppliers must conduct background checks on their workers to ensure their integrity and good reputation. It is expected that candidates and workers will be evaluated based on their ability to perform the job.

Suppliers must comply with all applicable standards regarding the working conditions of their employees, including, but not limited to, laws, regulations, and standards related to the payment of legal minimum wages or wages that meet local industry standards.

HEALTH AND SAFETY

In addition to complying with the minimum legal and regulatory requirements for working conditions, Suppliers must provide a safe and healthy work environment and comply with applicable health and safety laws.

ENVIRONMENTAL

Suppliers are encouraged to improve energy efficiency and reduce the consumption of natural resources, including electricity, heating, water, and fuel. Suppliers are encouraged to use innovations and environmentally friendly practices that reduce negative environmental impact. Suppliers should take reasonable steps to comply with environmental laws to minimize greenhouse gas emissions and hazardous pollutants, where applicable. Suppliers are expected to make efforts to eliminate or reduce the levels of waste (both solid and residual) generated.

RESPONSIBLE BUSINESS PRACTICES

Suppliers must not subcontract services or activities that they perform and that may directly affect the delivery of goods and services to ITG or its clients without ITG’s prior written approval. When Suppliers subcontract certain activities related to the services provided to ITG, they must oversee the subcontracted party to ensure compliance with the Supplier’s contractual obligations and this Supplier Code.

SOCIAL MEDIA

Suppliers must not act or speak on behalf of ITG, present themselves as ITG, or express any viewpoint attributable to ITG unless expressly authorized by ITG.

LEGAL

When there is a conflict of terms between the Supplier Code and the Supplier’s contract with ITG, the ITG contract will take precedence to the extent legally permitted.

Violations of the Supplier Code are taken seriously and must be reported as soon as the Supplier becomes aware. In case of any violation of this Supplier Code, recommendations may be given, corrective action plans may be required to be implemented, or the Supplier may be preferred not to work with or even have their contract terminated. Violations can be reported directly to your procurement representative, any other ITG employee you feel comfortable discussing the matter with, or through ITG’s Ethics Help Line website at XXXXXXX