1. INTRODUCTION

This Code of Ethics gathers the ethical principles on which the activity of Grau Lloret, SL is based, contains a description of the behaviors that should be promoted and the behaviors that should be avoided.

2 . AREA OF APPLICATION OF THE ETHICAL CODE

The code of ethics includes the catalog of standards that are applicable to administrators and all employees of Grau Lloret, SL . including personal trainees and interns. With the application of the Code, it is intended that people who perform their activities within Grau Lloret, SL . Show a complete and professional behavior at all times and contribute to the good atmosphere and commitment of Grau Lloret, SL ., denouncing those behaviors that may damage their image and / or reputation.

 

The scope of this Code of Ethics will be extended, to the extent possible, to suppliers, customers and any other natural or legal person that may affect Grau Lloret, SL with its actions.

3. GENERAL PRINCIPLES OF THE ETHICAL CODE

  • People respect

    Grau Lloret, SL will promote at all times, relationships based on respect for others and reciprocal collaboration.

    Grau Lloret, SL . undertakes to ensure that there is a work environment free of any type of violence and / or harassment, with the consequent prohibition of all types of discrimination, intimidation and offensive or improper behavior, disrespect or any type of physical or verbal aggression in professional relationships within the society.
  • Principle of equality and non-discrimination

    Grau Lloret, SL . Its basic principle to maintain a work environment in which the dignity of all people is respected and any type of behavior that violates the fundamental rights protected by the Spanish Constitution and the general legal system is avoided.

    Grau Lloret, SL . expresses its firm commitment to the principle of promoting equal opportunities in access to work and professional development, avoiding at all times situations of discrimination or inequality based on gender, race, social or sexual status, marital status, religion, union membership , illness or disability or any other circumstance.
  • Work safety

    In Grau Lloret, SL, the applicable preventive measures in occupational health and safety will be respected at all times. To this end, they have the obligation to know and use the resources that Grau Lloret, SL . put at your disposal in matters of safety and prevention of occupational hazards and, where appropriate, ensure that the members of their teams carry out their activities in safety conditions.
  • Labor rights

    In no case will labor or Social Security conditions that harm, suppress or restrict the rights that workers have recognized by legal provisions, collective agreements or individual contracts be imposed in Grau Lloret, SL . Nor will workers be hired without communicating their registration in the corresponding Social Security regime.

    In relation to foreign workers, they will not be hired without having obtained the corresponding work authorization. Nor will contract simulation or placement techniques be applied in any case.

    In the personnel selection processes a methodology will be used that guarantees the veracity of the job offers and in no case will false or false working conditions be offered.

    In the case of contracting with foreign suppliers, Grau Lloret, SL will ensure that in none of them cases of child exploitation occur.
  • Reconciliation of work and personal life

    Grau Lloret, SL will promote a work environment compatible with personal development, facilitating among the people of its teams, access to measures that facilitate the reconciliation of the performance of the professional activity in Grau Lloret, SL . with the needs of your personal life, in order to improve the quality of employees lifes and their families.
  • Environmental Protection

    Grau Lloret, SL , in the scope of its powers, must comply with the legal requirements and procedures to be established at all times, to respect the natural environment, minimizing the consumption of resources, enhance sustainability and control all the environmental impact of their activities.

4. CONDUCT GUIDELINES FOR CONCRETE SITUATIONS

  • Conflicts of interest

    The administrators and workers will always act in such a way that their private interests, those of their relatives or other persons linked to them do not prevail over those of Grau Lloret, S.L. or there customers. This guideline of conduct will be applied both in relations with Grau Lloret, S.L., as with clients, suppliers or any other third party. Administrators and workers will identify and report situations of conflict of interest, both potential and real, including those arising from kinship or related relationships.

 

  • Inside Information

    Administrators and workers who have privileged information will not carry out operations on their own or another's account, directly or indirectly, on the securities or instruments they affect. Nor will they promote, protect or recommend that others do them.  

    It is considered privileged information, any information of a specific nature that has not been made public, and if made public, could significantly influence the organized system Grau Lloret, S.L.
  • Duty of Confidentiality

    Administrators and workers must keep professional secrecy regarding any data or information they know as a result of the exercise of their professional activity, whether they come from or refer to Grau Lloret, SL., As us workers, customers and suppliers or any other third party. They must comply with the obligation of secrecy even after their relationship with Grau Lloret, SL.
  • Relations with suppliers

    The process of choosing suppliers is characterized by the search for competitiveness and quality, ensuring equal opportunities for all.

    The administrators and workers and, especially, those parts with intervention in decisions on the contracting of supplies or services or in setting their economic conditions, will avoid any kind of interference that may affect their impartiality or objectivity in this regard.
  • Customer relations

    Efforts will be made to avoid the exclusive relationship with a client that may lead to excessive personal ties or restrict access to other employees or channels of Grau Lloret, SL .

    Any economic or other relationship that could involve a conflict of interest with them must be made known to the customers, taking the necessary measures to avoid interfering with the customer's relationship with Grau Lloret, SL.
  • Personal data protection

    The administrators and workers are obliged to respect the right to data protection, the right to honor and personal privacy of all the people whose data they have access due to the performance of their activity within Grau Lloret, SL.

    Such respect can be applied to any information concerning a person: family identification data, affiliation, economic, audiovisual or any other measures to be identified.

    The personal data will be treated in accordance with the principles established in the data protection regulations.
  • Rules of the Money Laundering Prevention Manual

    The administrators and workers will strictly comply with the regulations established in the Prevention of Money Laundering and Terrorism Financing Manual.
  • Use of Information and Communication Technologies

    The administrators and workers will ensure the prevention and control of crimes that may be committed through the use of information technologies, the most prominent are:

o   Unauthorized access to computer systems of competitors, customers or any other public or private company or organization.

o   Dissemination of viruses or programs that may cause damage to tangible or intangible assets.

o   Any other type of computer damage, including sabotage or the simple alteration of the data or information contained in a third-party computer system.

o   Electronic scams and any type of deception based on the use of information technologies.

o   Dissemination of rumors, criticisms and boycotts through the Internet and social networks, retweets and forwarding of messages of any kind.

o   Infringement of intellectual or industrial property of technological assets.

o   Industrial espionage over the Internet.

o   Unauthorized transfer of databases.

 

  • Group intellectual and industrial property rights

    Grau Lloret, SL . is the owner of the property and of the rights of use and exploitation of computer programs and systems, equipment, manuals, videos, projects, studies, reports , advertising campaigns and other works and rights created, developed, perfected or used by its employees , within their work activity or based on the computer facilities of Grau Lloret, SL . The administrators and workers :

o   Will respect the intellectual property and the right of use that corresponds to Grau Lloret, SL in relation to computer programs and systems; equipment, manuals and videos; knowledge, processes, technology, " know-how " , advertising campaigns, and in general, other works and developed or created in the society works. Therefore, its use will be made in the exercise of the professional activity and all the material in which they are supported will be returned when required.

o   They must also respect the principle of strict confidentiality regarding the characteristics of rights, licenses, programs, advertising campaigns, systems and technological knowledge, in general, whose ownership or exploitation or use rights correspond to Grau Lloret, SL

o   They must not exploit, reproduce, replicate or assign the computer systems and applications of Grau Lloret, SL for purposes other than the same, whether or not said activity is remunerated and although said activity is carried out using any computer system, medium or application of the Company even outside the employee's working hours.

o   They will not use the image, name, brands or logo of Grau Lloret, SL, except for the proper development of their professional activity in it.

o   They will respect the intellectual and industrial property rights held by third parties outside Grau Lloret, SL In particular, the use in the Company of any content belonging to third parties will require obtaining prior authorization from said third parties.

  • Corporate image and reputation

    Grau Lloret, SL considers its corporate image and reputation as a very valuable asset to preserve the trust of its shareholders, employees, customers, suppliers, authorities and society in general. The administrators and workers must take the utmost care to preserve the image and reputation of Grau Lloret, SL . in all his professional performances.
  • Tax Obligations and Social Security

    Lloret Grau, SL will comply promptly fulfill its obligations in tax and social security. The administrators will be informed of the fiscal policies applied by Grau Lloret, SL .

    The accounting of Grau Lloret, SL will faithfully reflect the economic situation of the same, all those practices that imply the illusion of the payment of taxes to the detriment of the Public Treasury and Social Security will be avoided.

    Grau Lloret, SL will be attentive to any client or supplier that tries to use the structure of Grau Lloret, SL for a money laundering operation or related to the financing of terrorist activities. Any suspicion of a risk situation in this matter will be immediately communicated to the Ethical Channel.

    Payments will not be made to individuals or legal entities other than those that appear on the invoice or in the contract that regulates their relationship with Grau Lloret, SL, except in the event that there is a legal justification (seizure, assignment of credits, etc. ) to authorize such payment.


No charges will be received from individuals or legal entities other than those that appear on the invoice or in the contract that regulates their relationship with Grau Lloret, SL, except in the event that there is a legal justification (seizure, assignment of credits, etc. ) to authorize the payment.

5 . SPECIFIC RULES TO AVOID CORRUPTION BEHAVIORS

  • Compliance with the law

    Grau Lloret, SL . It bases its relations with the public and private sectors, both nationally and internationally, on the principles of transparency and equal opportunities, and discards any action aimed at gaining an advantage over competitors, in the market or in public contracts or private that is based on an illegal act. Consequently Grau Lloret, SL .:

o   It rejects any conduct, practice or form of corruption, expressly prohibiting any action of that nature.

o   All professionals must observe ethical behavior in all their actions and avoid any conduct that, even without violating the law, may damage the reputation of Grau Lloret, SL . and negatively affect their interests and / or their public image.

 

  • Guidelines to avoid incurring corruption behavior of public officials

    Is absolutely prohibited delivery or acceptance, promise or offer of any kind of payment, commission, gift or remuneration which is wants authorities, public officials or employees or executives of companies or public bodies, both in Spain and abroad.

    In the event that Grau Lloret, SL . Contract with agents, intermediaries or advisors to carry out transactions or contracts involving a public Administration, a public body or a public company, both Spanish and foreign nationality, the following measures will be taken:

o   They will be used as agents, intermediaries or advisers, entities of known prestige in the market or sector in question.

o   Due diligence will be taken in the selection of the intervening persons and their collaborators, to ensure that they are trustworthy and do not carry out activities that may involve risks, economic damages or compromise the reputation and good image of Grau Lloret, SL .

In general, special precaution will be taken in those cases in which the remuneration of the agent, intermediary or advisor is linked to the success of the transaction or contract.

  • Guidelines to avoid incurring a conduct of corruption of individuals

    The delivery or acceptance , promise or offer of any kind of payment, commission, gift or remuneration to any employees, managers or administrators of other companies to favor Grau Lloret, SL with respect to other competitors is prohibited .

    Subject persons must reject and inform the Directorate of any request by third parties both in Spain and abroad for payments, commissions, gifts or remuneration of those mentioned above in favor of Grau Lloret, SL and to the detriment of third parties.

6. APPLICATION OF THE ETHICAL CODE

  • Prevention and control model

    Grau Lloret, SL has a Prevention and Control Policy in which a prevention and control model aimed at preventing crimes in the company will be described.

    This policy contains a description of the key elements, which Grau Lloret, SL applies to avoid violations of the law and acts that may be classified as a crime in the Criminal Code.

 

  • Competitions

    The administrators and workers have the obligation to communicate the risk situations that may occur inside or outside the company, which may cause damage or harm to any natural or legal person. In addition to situations of breach of the law, the Code of Ethics or the regulations that develop it.

    Grau Lloret, SL has an Ethical Channel to which the communications that alert about the existence of a risk or non-compliance situation can be addressed, as well as any proposal to improve the prevention and control model . The Ethics Committee will be responsible for managing the channel and attending to communications sent to it.

    The supervision of compliance with the Code of Ethics corresponds to the Ethics Committee, this will include in its review model the necessary controls to verify that the provisions of the Code of Ethics are complied with , will make the necessary proposals for its improvement, and periodically inform Grau Lloret SL about its application.
  • Breach and penalties

    The behavior of all professionals must conform to compliance with this Code of Ethics ; they will maintain a collaborative and responsible attitude in the identification of situations of real or potential breach of the ethical principles and norms of conduct contained in this Code, and will communicate them to the instances in charge of resolving them.

    Breaches of the Code of Ethics may result in the application of the sanctions regime established in e l corresponding Collective Agreement , subject to administrative or criminal penalties in their ca so, may be applicable.

    The sanctioning procedure will start from a communication, as a result of an investigation or in any other way that allows the alleged violation of the Ethics Committee.

    The investigation protocol of the alleged infraction will be the one established in the Prevention and Control Policy of Grau Lloret, SL and will be confidential.

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