Your company, WIWINK has a commitment to Customers, partners and employees. The Code of Ethics WIWINK is intended to collect the corporate principles, values and conduct guidelines that should guide the behavior of all the managers, employees and directors of the Company, as well as prevent criminal behavior and establish monitoring and the control mechanisms necessary to ensure compliance.

Employees also have a commitment to the company, not only in the workplace, but also elsewhere. They represent the company and, for this reason, must assimilate and comply with this Code of Ethics, regardless of their position in the company.

The Board of Directors will be responsible for compliance with this Code of Ethics and will resolve any doubts that may arise about its content and application.

All employees must communicate any possible breach of the Code of Ethics to the following email address: [email protected].

Communication cannot be anonymous, WIWINK employs mechanisms that preserve the identity of individuals, and guarantees that employees will not be adversely affected when they communicate potential breaches.

We respect the personal and family life of our professionals and will make every effort to facilitate the best balance between their professional and personal lives.

We reject any type of violence, physical, sexual or psychological harassment, bullying or abuse of authority at work and any conduct that creates an intimidating or offensive environment for the rights of our professionals.

We defend equal treatment between men and women, both of whom have the same rights to training, promotion and working conditions.

We strive to preserve the environment, minimizing pollution with the efficient elimination of resources and promoting energy savings.

We comply with workplace health and safety regulations to prevent and minimize occupational risks, informing our superior of any facility or object in our work environment that may pose a risk. We do not allow alcohol or drugs to be consumed in the work environment.

Under no circumstances do we endorse child labor or forced labor. We do not discriminate on the basis of race, color, nationality, social origin, age, sex, marital status, sexual orientation, political ideology, religion or any other personal, physical or social condition.

We preserve the confidentiality of the information of our employees and third parties. We obtain and retain this data exclusively for the operation of professional relationships.

We will always act honestly. We consider it dishonest to provide incorrect information, organize it incorrectly, or try to confuse those who receive it.

We respect the confidentiality of the rights, licenses, programs, systems and technological knowledge, in general, the ownership, exploitation rights or use of which belong to the Company.

Professionals will not exploit, reproduce, or replicate information, systems or applications for purposes that do not pertain to us.

We do not allow any payment or charge to be offered or received in cash, in kind or in any other manner with the intent to obtain business or any other advantage.

We run an objective selection program, focusing exclusively on the academic, personal and professional merits of candidates. Professionals will be made aware of any evaluations to which they are subject.

In their dealings with Spanish or foreign public administrations, managers and employees, and any external person providing services to WIWINK must act in such a way that they do not induce a public official, authority or individual to violate their duties of impartiality or any legal precept.

• It is absolutely prohibited to offer any public official, authority, or individual, directly or indirectly, any type of gift, remuneration of any other kind or undue advantage, in order for them to violate their obligations in order to favor WIWINK.
• It is prohibited to act in any manner intended to unlawfully influence the conduct of a public official or authority to adopt or not to adopt a decision that could favor WIWINK.
• It is prohibited to receive, request, or accept a benefit of any unjustified nature, in order to favor the person who has granted it or from whom the benefit or advantage is expected against third parties in breach of one’s obligations.
• These prohibitions also extend to persons closely linked by family ties or friendship to the public official, authority or individual.

The Code of Ethics comes into force on September 7, 2021, the date of its approval by the Board of Directors and it will be in force as long as no amendment, update, revision or repeal is approved.