Code of Conduct

Milexia stands by a simple golden rule: doing what’s right. We believe in promoting a culture of honourable behaviour in all business relationships and throughout the company. This Code of Conduct aims to develop and consolidate this culture and our Policy of Corporative Social Responsibility to provide our companies with ethical and responsible principles so that all our employees and business acts are imbued with the philosophy of the group.

Managers are responsible for the distribution, understanding and application of the Code of Conduct throughout their teams.

Business Ethics & Integrity

Being ethical applies to all aspects of how Milexia conducts its business, from corporate strategies to our sales and administrative practices. It is the responsibility of every board member, manager and employee to behave following the highest standards and set an example to others.

No member of Milexia can act arbitrarily or in their own interest or that of third parties, either to favor or harm them, taking decisions that are not those that objectively are more convenient to the interests of the company.

Corruption

Corruption is a global threat to public and private sectors. It can take many different forms, like bribery, influence peddling, abuse of power or functions, conflicts of interest and others. Milexia absolutely prohibits any action that could constitute an act of corruption. All transactions and relations maintained are carried out ethically, with transparency and accountability, within the corresponding regulatory framework.

We have a reputation for acting with integrity and transparency because we recognize the importance of its effects on our company, employees, business partners and society. All our staff must comply with this code to safeguard our interests and those of all influenced by our business. In all circumstances, when someone becomes aware of a conduct that may be in breach of this Code, acting in good faith and in an impartial manner, must alert their manager, the local Compliance Officer or Compliance Manager. Milexia assures that no reprisals will be taken against anyone who raises concerns and that all concerns will be examined confidentially and in accordance with the rules of personal data.

Legal And Regulatory Compliance

Milexia complies with the regulatory framework of all the places where it conducts its business activity. The employees must follow the norms and procedures of the company, this current Code of Conduct, as well as the legal regulations in force from the places where they work. Any failure to fulfil this code or the corresponding applicable regulations by one of our clients, suppliers or collaborators, will receive a warning from our group to regulate the situation and, if that conduct persists, it will entail the termination of the relations with the group.

Accounts

Milexia ensures and maintains complete and accurate financial records. All transactions are properly, accurately and fairly recorded in every entity’s books in accordance with applicable regulations.

Confidentiality

Confidential information held by Milexia must be handled with particular care. No personnel or shareholder at Milexia will, at any time, divulge confidential information concerning the business, Company or Partner’s affairs. It is everyone’s individual responsibility to ensure that information obtained through the

Company, regarding the Company, suppliers and customers, is kept secure at all times. Such information will not be disclosed without prior consent of the individuals or companies concerned.

Data Protection

At Milexia we give maximum importance to the protection of your personal data, therefore we take all reasonable action and care to ensure that your personal data is processed safely. Milexia complies with the General Data Protection Regulations and has established the necessary security measures to preserve secrecy, confidentiality and integrity when handling your personal data. The information provided will be kept as long as the relationship continues. The data will not be forwarded to third parties except when legally obliged.

Respect & Equality

Milexia guarantees all its employees equal and non-discriminatory treatment regardless of their race, colour, religion, belief, civil sex and sexual orientation, nationality, civil status, age, disability and other legally protected circumstances. We promote an inclusive work environment and are fully committed to providing equality in the workplace. We aim to create a working environment that is free from discrimination and harassment in any form, in which all employees, customers, suppliers and third parties are treated with dignity and respect.

Speak Up

Milexia promotes a “speak-up” culture that does not tolerate retaliation. We provide the means and environment for our employees and business partners to speak up freely if they have concerns that something involving our business is unsafe, unethical or potentially harmful.

Maria Gonzalez Müller, Chief Compliance Officer

Updated: September 2022