ETHICAL CODE

1. INTRODUCTION

1.1. Objective

The present Code of Conduct of the BBC Group (BBC Packaging and Click Coin) establishes the set of principles and behavioral guidelines that must govern the company with the aim of consolidating business ethics.

1.2. Scope of Application

The Code is directed and linked to all executives and workers of the Group, regardless of the contractual modality that determines their connection, hierarchical position, or function.

1.3. Compliance

Group Professionals are obliged to comply with what is established by this Code, respecting the principles, values, and standards of behavior it sets. Professionals, particularly those who have other employees under their charge, will make efforts to comply with and enforce the provisions of the Code, leading by their own example in the day-to-day conduct of ethics and integrity.

1.4. Communication, Dissemination, and Commitment

The BBC Group will communicate and disseminate the Code to the entire staff by providing a copy through the company’s intranet. Additionally, the BBC Group will communicate and disseminate the Code among all interested parties: suppliers, Public Administrations, clients, collaborators…

2. VALUES AND CORPORATE PHILOSOPHY

The performance of the BBC Group is based on the principles and values described below.

Principles of Social Responsibility
Compliance with legality, rights, and fundamental freedoms
Labor rights: The company will generate spaces of trust with its employees, aiming for long-term relationships that allow for the best personal and professional development. It commits to defending, respecting, and protecting basic labor rights, complying with current labor legislation, and eliminating forced labor, child labor, and work performed in harsh, extreme, inhuman, or degrading conditions.

2.1.3. Personal Development

The company will promote the development of its workers, ensuring equality of opportunities between men and women, the absence of any kind of discrimination, and respect for diversity, guaranteeing a safe and healthy environment.

2.1.4. Safety, Health, and Environment

The company will enhance the provision of services that contribute to the use of resources, sustainable development, and respect for the natural environment, applying best practices in terms of safety, health, and environmental protection. It will also encourage participation, training, and information in this area and will require its suppliers and collaborators to comply with standards and programs concerning safety, health, and the environment.

2.1.5. Business Development

The company will promote the development of its activity in an efficient and competitive manner, optimizing the resources it possesses, being capable of growing and being profitable under the principle of responsible and transparent management.

2.2. Our Values

WE ARE PROFESSIONALS, integral, honest, and transparent in our relationship with customers and society, thus generating trust, credibility, and respect towards our organization. WE THINK OF THE CUSTOMER. We place them at the center of our attention. We are close in service and close to companies. We maintain a constant listening attitude to provide practical and real solutions to their needs.

3. RULES OF CONDUCT

3.1. Compliance with Legality

All professionals in the company must comply with current legality, regardless of the place where they carry out their activity and provide their services, also respecting the commitments and obligations acquired in their relationships with third parties.

3.2. Equality of Opportunities

The company is committed to ensuring that its policies and practices of selection, hiring, and remuneration, employment conditions, or access to training and promotion for professionals, exclusively consider merit criteria and specific capacity requirements in each case. It particularly ensures the principle of equal treatment between men and women, promoting an environment where equal opportunities reach each of them, ensuring non-discrimination based on race, gender, ideology, nationality, disability, belief, or any other personal, physical, or social condition.

3.3. Safety and Health in the Workplace

The company will promote an adequate policy of occupational hazard prevention, ensuring its dissemination to the entire staff to guarantee safety and health at work, compliance with current regulations, and the adoption of necessary or convenient preventive measures in each case. The company’s professionals should know and comply with health and safety at work protection rules, labor risk prevention, and, within the scope of their functions, ensure their safety and that of other workers, clients, suppliers, and collaborators.

3.4. Environmental Protection

Respect for natural resources and the environment is one of the basic principles of the company’s actions, guaranteed through the approval of a well-implanted environmental policy.

3.5. Fight Against Corruption and Bribery

The BBC Group will ensure and encourage compliance with the law and refrain from engaging in practices that could be considered irregular in its relationships with clients, suppliers, collaborators, competitors, authorities, etc., including those related to money laundering. In relation to gifts, invitations, and other types of remuneration, the company establishes specific guidelines that tend to limit, and in some cases prohibit, gifts and invitations. The following guidelines should be applied:

It is prohibited to offer or receive a gift or an invitation that, for one reason or another, might make the professional feel uncomfortable, influence, or could be interpreted as influencing decision-making.
It is prohibited for professionals to present favors, compensation, or remunerations of any kind, regardless of the amount, to authorities or public officials.

3.6. Conflicts of Interest

Workers should avoid all situations that could give rise to a conflict of interest and refrain from influencing or intervening in decision-making in situations where they may have a direct or indirect personal interest favoring other related individuals, themselves, or external companies, which could harm the interests of the company. BBC Group workers cannot use or supply privileged information to which they have had access through the exercise of their professional activity.

3.7. Relationship with Customers, Suppliers, and Collaborators

The BBC Group aims for the satisfaction of customers’ needs and expectations. To this end, they should promote the establishment of long-term commercial relationships with customers based on a permanent attitude of service, trust, and value contribution, maintaining a high commitment to honesty, respect, integrity, transparency, and professional responsibility. Likewise, suppliers and collaborators will be asked for relationships based on trust, information transparency, and the sharing of knowledge, experiences, and capabilities.

3.8. Relationship with Competitors

The BBC Group commits to competing in the markets fairly and transparently, refraining from engaging in misleading advertising, fostering free competition and fully respecting current regulations.

3.9. Protection and Appropriate Use of Company Assets

The company provides its employees with the necessary resources, means, and tools for the performance of their professional duties, which should not be used for other purposes.

3.10. Data Protection and Treatment of Reserved and Confidential Information

The company will comply with current legislation on the protection of personal data entrusted by its employees, clients, suppliers, candidates in selection processes, or other individuals. It will appropriately preserve and allocate them for authorized purposes and will not disclose them unless with the consent of the interested parties or in compliance with judicial resolutions.

3.11. Respect for Intellectual Property Rights

The BBC Group will proactively ensure the good use and protection of its intellectual property rights. Employees within the Group may not, under any circumstances, reproduce, plagiarize, distribute through any means, in whole or in part, the company’s intellectual property.

4. COMPLIANCE WITH THE CODE OF CONDUCT

The principles and performance criteria contained in this Code are mandatory for Group workers. To ensure its application, as well as supervise and control its compliance, the company’s management will personally take charge, with the necessary collaboration to:

· Promote knowledge, compliance, and dissemination of the Code among Group Professionals.
· Resolve any doubts that may arise about the interpretation and application of the Code.
· Analyze and resolve reports of actions contrary to the principles set forth in the Code.
· Ensure compliance with the Code and propose its periodic review and update.