Approved by the Shareholders' Meeting on October 21, 2021
INDEX
| INDEX | 2 |
| CHANGE CONTROL | 3 |
| I.- OBJECTIVE | 4 |
| II.- PRESENTATION OF THE ORGANIZATION | 4 |
| III.- RECIPIENTS | 5 |
| IV.- FUNCTIONS OF THE INVOLVED | 5 |
| 1. Governing Body: Shareholders / Partners Board | 5 |
| 2. General Directorate and Area Directorates | 6 |
| 3. Employees | 6 |
| V.- COMMITMENTS AND CONDUCT GUIDELINES | 6 |
| . Discovery and disclosure of secrets and Protection of Personal Data and computer damage. | 7 |
| 2. Heritage and socio-economic performance | 8 |
| 3. Anti-corruption | 8 |
| 4. Intellectual and Industrial Property | 9 |
| 5. Obligations with the Treasury and Social Security | 9 |
| 6. Accounting and economic transparency and prevention of money laundering and terrorist financing | 10 |
| 7. Market Defense | 11 |
| 8. Labor rights | |
| 9. Health and Safety at Work | 11 |
| 10. Fundamental rights and public liberty | 12 |
| 11. Commitment to the Protection of the Environment | 12 |
| 12. Performance before inspection bodies | 13 |
| VI.- PUBLICITY OF THE CODE | 14 |
| VII.- ETHICAL CHANNEL | 14 |
| VIII.- DISCIPLINARY SYSTEM | 15 |
| IX.- COMPLIANCE OFFICER | 15 |
| X.- APPROVAL AND ENTRY INTO FORCE | 16 |
CHANGE CONTROL
Identification and description:
| QUALIFICATION | Code of Ethics of TRADINFORME, SL and TRADINFORME ABOGADOS, SLP | |
| DESCRIPTION | Values and guidelines of conduct applicable to all members of the Company. | |
| AUTHOR | HELAS CONSULTORES, S.L. | |
| REVIEWED BY | COMPLIANCE OFFICER | 10/15/2021 |
| APPROVED BY | SHAREHOLDERS' MEETING | 10/21/2021 |
Format:
| IDIOM | Castilian |
| MEDIUM | Paper, Electronic |
Version log:
| DATE | EDITION | REVISION | RESPONSABLE | DESCRIPTION OF CHANGES |
| 19/10/2021 | 00.00 | 0 | Helas Consultants | Initial edition |
| 25/03/2022 | 01.00 | 1 | Helas Consultants | Adaptation changes to the Tradinform Equality Plan and ANGECO's Code of Ethics |
I.- OBJECTIVE
This Code of Ethics (hereinafter the "Code") includes the values and principles that will be applicable to the activity of TRADINFORME, SL and TRADINFORME ABOGADOS, SLP hereinafter, Tradinforme
The Code offers behavioral guidelines so that, with due diligence and integrity, Tradinforme members are able to avoid or minimize the possibility of malpractices occurring both in terms of the resources used and the activity carried out.
II.- PRESENTATION OF THE ORGANIZATION
Tradinforme, SL is a company specialized in the recovery of debts from Financial and Banking Entities, Insurance Entities, Companies and individuals, established in 1992.
The company not only seeks to maintain the degree of trust of its customers, but has also established itself and specialized in the collection management of any financial product or debt.
Tradinforme seeks to maintain the highest quality standards and excellent treatment with bankrupt companies, public representatives, suppliers, creditors, third parties, and any other business partner.
Along with the high level of professionalism of all its staff, confidentiality and discretion are taken into account.
Tradinforme is a member of ANGECO, the National Association of Collection Management Entities that groups together companies whose corporate purpose is to provide collection management services for unpaid amounts, both amicably and judicially, which implies, among others, compliance of its Code of Conduct established at European level by FENCA for the debt recovery sector.
ANGECO has also approved its own Code of Ethics and Conduct, which aims to establish a standard of behavior in the development of business relationships, both internal to the association itself and external to its associates, among which is Tradinforme SL
On the other hand, Tradinforme Abogados, S.L.P. is a professional firm that acts in legal claims and legal, economic, accounting, financial and real estate advice, both to natural and legal persons, of a public or private nature.
To achieve its objectives, Tradinforme Abogados SLP , and its team of highly experienced professionals, and relying on a structure as accredited as Tradinforme SL itself , develops its judicial recovery activity immersed in the same philosophy that presides over the performance of the business group of which it is part. That is to say, not to increase the cost of the client by exhausting the ways of recovering his unpaid credits.
In addition, the long experience of the professionals that make up Tradinforme Abogados SLP , allows us to offer a complete legal advice service whose horizon goes beyond the simple judicial claim of credits. Its structure allows it to offer comprehensive commercial, corporate, civil and labor advisory services as part of the legal needs of any company.
The main objective is to help clients to prevent risks (preventive advice) and to recover their credits (legal claim).
This Code, along with other internal policies, are a sample of Tradinforme's commitment to compliance with laws, good corporate governance and transparency.
III.- RECIPIENTS
The Code is aimed at all those people who are part of Tradinforme , regardless of the type of contract they have, the position they occupy or the functions they perform.
All of them are equally obliged to know and comply with this Code and to collaborate in its correct implementation.
Tradinforme will promote among its suppliers the adoption of behavior guidelines consistent with those defined in this Code.
The application of the Code may be contractually extended to any other natural or legal person that maintains commercial and collaborative relationships and participation with Tradinforme when, for the purpose of said relationship, their activities may affect the reputation of the Company.
IV.- FUNCTIONS OF THE INVOLVED
1. Governing Body: Shareholders / Partners Board
The active involvement of the Governing Body is essential to transmit to all interested parties a clear message, by word and action, that Tradinforme will fulfill its obligations, thus serving as an example for all.
Therefore, it will ensure that the necessary resources are allocated to establish, develop, implement, evaluate, maintain and improve the Culture of Compliance within Tradinforme and the specific compliance with this Code and its own Commitment regarding compliance. normative.
It will adopt values that promote Honesty, Commitment, Professionalism, Discretion, Responsibility and Transparency.
You are expected to pay the utmost attention to compliance with the values and principles of this Code both in your own actions and by the employees under your direction, and to demonstrate, in all your actions, a clear and proactive commitment to your actions. objectives.
Likewise, it must foster an environment in which both its employees and their families or dependents feel free to express their concerns without fear of retaliation and actively participate in the management and resolution of incidents and issues related to compliance with the Code.
2. Address General and Area Directions
The General Management and the Area Managements must demonstrate their leadership and commitment to compliance with this Code of Ethics and be a model for employees.
They are expected to pay the utmost attention to compliance with the values and principles of this Code both in their own actions and by the employees under their management. Likewise, they must foster an environment in which employees feel free to express their concerns without fear of retaliation and actively participate in the management and resolution of incidents and issues related to compliance with the Code of Ethics.
3. Employees
Employees must commit to the values and principles set out in the Code and they are expected to perform the functions assigned to them by following the established and approved policies, procedures and processes at all times.
Likewise, employees are expected to participate in those training initiatives that are proposed to them or even to propose training actions that may be of general interest to everyone in terms of Regulatory Compliance.
Finally, employees must feel free and confident enough to report concerns, issues or failures in the system, either directly to their superior or through the ethical channel. They must be a source of opinion for Tradinforme with the aim of continuous improvement.
v.- COMMITMENTS AND CONDUCT GUIDELINES
All those involved in compliance with this Code undertake to comply with and respect the current legal regulations at all times in all their areas of action and, in particular, in certain areas that are listed here.
1. Discovery and disclosure of secrets and Protection of Personal Data and computer damage
For Tradinforme confidentiality is an important pillar in its activity.
It is established for all members of Tradinforme , who have access to personal data and other information on the activity, the obligation to comply with the duty of secrecy and the commitment to confidentiality.
Tradinforme will process those personal data that are necessary for the correct provision of its services, respecting the applicable regulations on data protection and, in particular, the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 of April 2016 regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data and by which Directive 95/46 / CE (RGPD) and Organic Law 3 / 2018, of December 5, Protection of Personal Data and guarantee of digital rights (LOPDgdd).
For this, all personnel with access to personal data or other internal information related to the activity must respect and comply with all the technical and organizational measures that have been implemented.
Tradinforme must only process personal data for legitimate purposes and with the informed consent of the owner thereof, except for the legally foreseen exceptions. Likewise, the security measures established for the protection of these data must be complied with, thus avoiding their alteration, loss, treatment or unauthorized access.
The internal procedures and standards established mainly regarding the protection of personal data must be complied with. All confidential information to which you have access must be protected in order to prevent it from being known to people outside of Tradinforme , whether due to intentional action or negligence.
Tradinforme will keep, indefinitely, the maximum reserve and will not disclose or use, directly or through third parties or companies, the information to which it has access. These obligations will survive even when the relationship of the obligor with Tradinforme ends.
On the other hand, all Tradinforme staff undertake not to carry out sabotage or actions that hinder the operation of the company's computer systems or third parties to which they have access (such as platforms of public bodies, banking entities, both national and international ), as well as not to use them to commit illegal acts against privacy or to violate the guidelines of non- discrimination, harassment at work or any other reason beyond the logical use in the workplace.
The company's computer systems will not be used in an abusive way, or for personal purposes or actions that could affect the reputation of Tradinforme.
2. Heritage and socio-economic performance.
Tradinforme defends at all times a responsible action aimed at preserving and protecting its own heritage as a basic element of its activity.
Tradinforme staff must act at all times with transparency in economic management in order to avoid the commission of irregularities such as misappropriation, fraud or that allow insolvency situations.
In its contact with its clients, Tradinforme establishes conditions of responsible behavior aimed at offering transparency and quality of service at all times.
The Board of Shareholders, Administrators and the personnel dedicated to accounting or financial work must at all times respect the appropriate protocols of accountability, permits for the availability of economic means and any other means of economic control.
3. Anti-corruption
Tradinforme fights against corruption in any of its forms.
The organization “Transparency International” defines corruption as “the abuse of power for personal gain”. Corruption can materialize in different ways such as bribery (“offering or receiving any gift, loan, fee, reward or other advantage to or from any person as a way to induce something dishonest or illegal to be done in the conduct of the management of a company ”) or extortion (“ to use directly or indirectly their own access to a position of power or an advantage in the information to unjustifiably demand from others collaboration or money through coercive threats ”).
Tradinforme rejects any practice within it that may be considered corruption, whether in the private or public sphere, as well as any illegal payment.
For this, an Internal Policy on Anti-Corruption has been approved that will be mandatory for all interested parties as a complement to this Code.
4. Intellectual and Industrial Property
Tradinforme employees must respect the intellectual and industrial property rights of their own and of others, which include, among others, patent rights, trademarks, domain names, reproduction rights (including software reproduction rights), design rights, of extraction of databases or specialized technical knowledge.
The use of works, creations or distinctive signs of intellectual or industrial property of third parties without proof that Tradinforme has the corresponding rights and / or licenses is expressly prohibited.
Only duly authorized brands, images and texts related to Tradinforme will be used in marketing and advertising actions.
In their relationship with third parties, Tradinforme employees will scrupulously follow the rules and procedures regarding the protection of intellectual and industrial property to avoid infringing the rights of third parties.
5. Obligations with the Treasury and Social Security
In order to contribute to the support of public expenses as established in article 31 of the Spanish Constitution, Tradinforme undertakes to comply with current legislation in all areas of its activity regarding its obligations to the Treasury and Social Security, rejecting any type of fraud.
In relation to tax obligations, Tradinforme , with the collaboration of its employees, undertakes to:
• Reduce significant tax risks and prevent behaviors that may generate them.
• Avoid the use of opaque structures for tax purposes, understood as those in which, through the filing of instrumental companies through tax havens or territories not cooperating with the tax authorities, are designed with the purpose of preventing knowledge, by the Tax Agency, the final person in charge of the activities or the ultimate owner of the assets or rights involved.
• Collaborate with the Tax Agency in the detection and search for solutions regarding those fraudulent tax practices that may develop in the markets in which Tradinforme has a presence , to eradicate those that already exist and to prevent their extension.
6. Accounting and economic transparency and prevention of money laundering and terrorist financing.
Tradinforme assumes the obligation to offer a faithful image of its economic and financial situation, maintaining transparency in its annual accounts and other accounting documents.
Thus, Tradinforme staff , especially staff dedicated to administrative, accounting and financial tasks, must act with total transparency in the economic management of the company, complying at all times with the obligations related to accountability, media availability permits. economic and any other means of economic control.
Under no circumstances will the economic and financial information be falsified and / or actions aimed at:
• Not keeping commercial accounting, books and tax records.
• Keeping different accounts that, referring to the same activity and financial year, hide or simulate the true situation of the companies.
• Do not enter business, acts, operations or, in general, economic transactions in the mandatory books, or would have entered them with figures other than the true ones.
• Practice fictitious accounting entries in the compulsory books.
On the other hand, in the prevention of irregularities in payments and money laundering and financing of terrorism or smuggling crimes, it is prohibited to receive or transmit goods knowing that they come from a criminal activity, committed by him or by a third person, or carry out any another act to hide or conceal the illicit origin, or to help the person who participated in the infringement to avoid the legal consequences of their actions.
Therefore, it is totally prohibited:
• Accept the payment made knowing the illicit origin of the money.
• Accept payments in cash, bearer checks or foreign currency in unusual conditions or not agreed in contract that result from criminal activity.
• Establish commercial relationships, both nationally and internationally, with companies that do not provide adequate information on their legality.
• Carry out import, export, trade, possession or circulation of prohibited or protected goods.
7. Market Defense
Tradinforme competes in the market fairly, and does not admit that its workers act in a deceptive, fraudulent or malicious way.
To this end, in the development of commercial activities, Tradinforme promotes its services based on objective and transparent standards, avoiding wrong, ambiguous or not very rigorous information that may lead to error. Thus, transparency and truthful, timely and adequate information are promoted.
8. Labor rights
Tradinforme respects the labor rights recognized by law for all its personnel in relation to union rights, dignified working conditions and contractually regulated in accordance with the laws applicable to both national and foreign personnel.
In relation to the hiring of personnel with nationality that does not belong to an EU country, their rights will be respected at all times, but also the obligations regarding checking the appropriate entry permits to the EU or work.
Any form of forced or compulsory labor is totally prohibited. The employment offered by Tradinforme will always be promoted freely and employees will have full freedom to resign according to the applicable regulations without being forced to remain in the company in a forced way or under duress.
Likewise, discriminatory practices in employment and occupation based on race, color, sex, religion, political opinions, national origin, social extraction or physical or mental disability are also totally prohibited.
The selection processes will be carried out based on the ability to perform the job offered without distinction, exclusion or preferences based on other issues.
It is also totally prohibited, and will be sanctioned if detected, any type of harassment in the workplace. For these purposes, all members of Tradinforme are obliged to know and comply with the Code of Conduct on Sexual Harassment and Moral Harassment, which is complementary to this Code.
Tradinforme supports the eradication of child labor that must be considered as a form of violation of Human Rights, thus it has been established as the minimum age for the occupation of a job or carry out some type of activity such as practices in the company have reached the age of 18.
9. Health and Safety at Work
The Constitution of the International Labor Organization (ILO) establishes the principle of protection of workers from diseases and accidents at work.
Tradinforme complies with its obligations regarding the prevention of occupational risks and for this it has resorted to a specialized company such as External Prevention Service to identify the risks associated with the activity and the management of possible contingencies.
Workers are obliged to comply with the rules and measures regarding Occupational Risk Prevention in order to achieve a healthy work environment. In this sense, the presence in the workplace of any person who is under the influence of drugs, alcohol or hallucinogenic substances, as well as ingesting and / or consuming them during the working day, is strictly prohibited.
In the event of detecting new situations of risk to your health or safety, the staff will have to inform the Management, who in turn will notify the Prevention Service.
10. Fundamental rights and public liberty
Article 10 of the Spanish Constitution establishes that “1. The dignity of the person, the inviolable rights that are inherent, the free development of the personality, respect for the law and the rights of others are the foundation of political order and social peace.
The norms relating to fundamental rights and freedoms that the Constitution recognizes will be interpreted in accordance with the Universal Declaration of Human Rights and international treaties and agreements on the same matters ratified by Spain. "
For its part, the Universal Declaration of Human Rights: "All human beings are born free and equal in dignity and rights."
“Human rights are inherent rights of all human beings, without any distinction of nationality, place of residence, sex, national or ethnic origin, color, religion, language, or any other condition. We all have the same human rights without discrimination. These rights are interrelated, interdependent and indivisible. Office of the High Commissioner for Human Rights (OHCHR).
Tradinforme supports and respects the protection of human rights and fundamental freedoms.
Demonstrations or actions of any kind that encourage or promote hatred, hostility, discrimination or violence against people by reason of their membership in the company, for racist, anti-Semitic or other reasons related to ideology, religion or beliefs are totally prohibited. , family situation, the belonging of its members to an ethnic group, race or nation, their national origin, their sex, orientation or sexual identity, for reasons of gender, illness or disability.
11. Commitment to the Protection of the Environment.
Article 45 of the Spanish Constitution establishes that everyone has the right to enjoy a suitable environment for the development of the person, as well as the duty to preserve it.
Tradinforme is committed to maintaining a preventive approach that favors the conservation of the environment.
Employees are obliged to follow existing procedures on the matter and to comply with environmental laws and regulations that affect them in the exercise of their functions in those activities that could pose a high risk to natural resources and the environment.
By correctly managing environmental risks, Tradinforme aims to reduce the environmental impact of its services.
12. Performance before inspection bodies.
All Tradinforme personnel are obliged to collaborate at all times with those inspection bodies that may require information in the framework of a file or inspection on the activity of the company..
The most common inspections will come from agencies of the Tax Agency, Labor, Bank of Spain, Spanish Agency for Data Protection or other supervisory bodies of the sector in whose field Tradinforme provides its services.
Therefore, before an inspection, we must:
• Once we have notice of the visit or arrival of the inspectors, we will make sure that all those involved will be present that day in order to adequately attend to their requirements.
• On the day of the Inspection, we will collaborate at all times with the inspectors.
• Any maneuver that delays, hinders or obstructs the inspection action will be avoided.
• Any delivery of information or decision that is made must have the approval of the Management or the Sole Administrator who will be the only ones authorized to deliver documentation.
VI.- PUBLICITY OF THE CODE
This Code will be sent to all interested parties and will be available through the Tradinforme website.
The Code will be subject to appropriate communication, training and awareness actions for its timely understanding and implementation by all those involved.
VII.- ETHICAL CHANNEL
All recipients of this Code have the obligation to inform their hierarchical superior or the designated Compliance Officer of any non-compliance or malpractice that they may observe in the performance of their professional activities.
In order to promote interaction with all those involved, the use of Tradinforme's Ethical Channel is established as a communication channel, as a communication channel or alerts, suggestions or queries in everything related to the prevention and detection of crime in the company , through the email address:
The Channel is a communication tool, accessible to all employees, clients, suppliers and other third parties, by which to alert or report irregularities, non- compliance and behavior contrary to ethics and legality.
All interested parties, both internal and external, may and must disclose any criminal behavior or action that violates current legislation or internal company regulations.
Through this channel you can report possible irregular behaviors such as, for example:
• Irregular actions related to clients.
• Diversion of resources.
• Bribery and corruption.
• Accounting and auditing aspects.
• Confidentiality or improper use of company or customer information.
• Conflicts of interest.
• Workplace harassment, discrimination or mistreatment.
• Violation of employee rights.
All those people who use this channel in good faith will be protected against any type of discrimination and penalty due to the communications they make. However, it should be emphasized that false or defamatory complaints may be subject to disciplinary sanction or denunciation.
The identity of the whistleblower / communicator will not be disclosed to third parties, nor to the person allegedly involved, except when it is necessary to disclose it to the relevant persons involved in any subsequent investigation or judicial procedure that is opened as a result of the investigation carried out.
VIII.- DISCIPLINARY SYSTEM
In case of detecting a breach of the rules of conduct established in this Code of Ethics, and once the facts have been investigated and evaluated, immediate action will be taken and the appropriate disciplinary measures will be adopted in the workplace and that will be independent of any other legal proceedings that may be directed against the person involved. In the event that there are sufficient indications of the existence of a crime, the facts will also be communicated to the competent authority (prosecution and other judicial bodies).
The Disciplinary Regime is configured by the applicable current labor legislation and, especially, by the Workers' Statute and the collective agreement applicable to their activity and sector, that is, the agreements applicable to Contact Center (Tradinforme SL) and Offices and Law firms (Tradinforme Abogados, SLP).
IX.- COMPLIANCE OFFICER
Tradinforme decides the appointment of a Compliance Officer, whose main function, among others, will be to control the correct development and implementation of the conduct guidelines established in this Code.
The Compliance Officer will ensure that the provisions of the Tradinforme Code of Ethics are respected . Thus, it will deal with the conflicts that may arise in relation to it and will establish action plans to solve them and safeguard the ethical culture.
Those interested can contact the Compliance Officer through the ethical channel itself.
X.- APPROVAL AND ENTRY INTO FORCE
The Code of Ethics is approved by the Shareholders / Partners Meeting and enters into force on the day of its publication and will remain in force until its cancellation is approved.