This Code of Conduct is addressed to the administrators, managers, professionals and employees of the companies that make up the Itercon Group, regardless of the contractual modality that regulates their legal relationship, the position or position they occupy or the place in the Let them do their job.

The Itercon Group shall promote that all controlled companies integrated therein (in accordance with the definition of the group provided for in articles 18 TRLSC and 42 of the Commercial Code) and the main collaborators with whom it relates adopt a conduct in accordance with the ethical principles of this Code. However, the Itercon Group is not considered to be the guarantor of the conduct of its employees, nor does it assume any responsibility for its hypothetical unlawful or criminal action, as long as they constitute independent businessmen outside the Group, as defined in the following section.

1.     Composition and operational scope

The Itercon Group is a poly-corporate company in which several companies domiciled in Spain and in three other countries (Germany, Colombia and Romania) are integrated.

The Itercon Group is dedicated to the sector of real estate investments and the promotion and construction of all types of works, as well as the realization of complementary services, such as the execution of gardening and irrigation works, nursery operation and cultivation of ornamental plants, environmental and landscape impact studies, design and construction of treatment plants, waste treatment, conservation and protection of the natural and environmental environment and other activities related to the use and management of natural resources.

The parent company has as its main corporate purpose the realization of the activities of the promotion and construction of all types of buildings, as well as their exploitation thereof, by means of any appropriate contractual figure for this purpose. As a group head company, its corporate purpose also includes the management and management of participations in other entities of all types, whether or not they have legal personality. In addition, it is also dedicated to the provision of technical, financial, business accounting, legal and business strategy advisory services to investee companies, as well as the sale, subscription and administration of securities on its own.

All these activities can be carried out directly or through the participation of the parent company in other companies with an identical or similar purpose.

2. Administration and management of the Group

In view of the hierarchical disposition of the Group, the companies that comprise it are subject to the management unit of the parent company in the essential aspects of the common business strategy. Given the composition of the share capital of the subsidiaries, wholly owned, for the most part, no compensation measures are planned for external partners, which do not exist.

Without prejudice to this unitary address within the Group, the management and representation of each of the companies is entrusted to its own administrative body, which has a differentiated structure in each case.

The Itercon Group expresses its firm commitment not to carry out practices that may be considered as threatening the rights of workers, depending on the employment contract and current legislation on labor matters and also in relation to the principle of good faith.

The Itercon Group assumes the commitment that the workers of the company exercise their activity in healthy conditions, for which the necessary material resources and financial resources will be maintained, in accordance with the company's integrated policy and integrated system in Occupational safety (OHSAS 18001), quality (ISO 9001) and the environment (ISO 14001).

The Itercon Group undertakes to maintain and protect with the measures at its disposal, a work environment where the personal integrity and sexual freedom of all its employees and employees are respected, in the terms expressed in its Protocol of Action against Harassment.

Under said Protocol, The Itercon Group rejects any type of workplace harassment, meaning any behavior, verbal, nonverbal or physical, unwanted, of a sexual nature with the purpose or effect of violating the dignity of a person, in particular when creating a intimidating, hostile, degrading, humiliating or offensive environment. Similarly, reject any type of moral harassment or bullying, understood as the hostile or offensive treatment, by one person or group, either by word or actions, with respect to another, undermining their person systematically and for a time, in order to disrupt the exercise of their work , affect your reputation and finally cause the abandonment of the job.

The Itercon Group declares these practices as intolerable and unacceptable and will not allow situations of workplace harassment to occur within. The administrators and the rest of the managerial personnel will be especially attentive to the complaints that can be received by any worker or worker in relation to situations of labor harassment.

Workers may disobey any instruction of the management personnel whose compliance implies the commission of criminal conduct or contrary to the values ​​and principles included in this Code of Conduct and in the remaining documents related thereto.

In addition, the Itercon Group is committed to carrying out internal promotion programs for which the selection criteria will be meritocracy and professional training.

The Itercon Group is certified in ISO 14001, showing its commitment to the environment, which defines the objectives and goals in this field, the policies and procedures for its achievement, the systems to control its application, the training activities of the staff, distribution of responsibilities and improvement tools. In compliance with said Plan, all Group personnel are affected by the principle of environmental protection, and must ensure the rational use of natural resources in order to protect, defend and restore the environment.

The Itercon Group expresses its firm commitment not to carry out practices that could be harmful to the Environment in contravention of the general norms for its protection. Therefore, it undertakes to scrupulously respect these standards and, especially, those related to emissions, discharges, radiations, extractions or excavations, terrifications, noise, vibrations, injections or deposits, in the atmosphere, soil, subsoil or land, ground or sea waters, including the high seas, as well as water catchments.

In addition, the Itercon Group undertakes to adopt in its projects a preventive approach that favors the Environment and to use technologies that respect it, within the possibilities allowed by the financial conditions and viability of each project, always choosing the most innocuous option. among the possible ones, in accordance with points 7 and 9 of the United Nations Global Compact June 2000, which has been signed by the Group Management.

A)    Principles of action in relation to suppliers, contractors and other businessmen with whom you have business relationships

All personnel are affected by the principles of good faith, clarity and transparency in relationships with third parties. Therefore, you must not knowingly provide incorrect, inaccurate or inaccurate information that may mislead those who receive it, always ensuring that no action of yours can be construed as misleading.

Likewise, all the ethical values ​​of the Itercon Group will be extended to all suppliers, contractors and other businessmen with whom commercial relationships are maintained and, especially, those related to the prohibition of establishing commercial and / or other relationships with organizations. who benefit from child labor, forced labor and / or human trafficking).

On the other hand, the Itercon Group will ensure that this Code is respected by third parties with whom contractual or collaborative relationships are established, in the fulfillment of the obligations derived from such contracts and in the performance of joint business activities. For this purpose, it will inform said businessmen of the existence of this Code and of the development texts that are of interest for the relationship established with them and will ensure that it is attached as attached documentation in the different contracts that are concluded in the framework of said relationship. Failing that, it will verify that these entrepreneurs have equivalent codes or compliance programs.

Where appropriate, the Itercon Group reserves the possibility of claiming compensation or compensation to these employees for the damages they may suffer as a result of breach of the rules established in this Code and the texts that develop it and have become part of contractual relationships with them.

B)    Policy regarding corruption and money laundering

The Itercon Group expresses its firm commitment not to carry out practices that may be considered corrupt in the development of its relations with the authorities.

No fund or Group may be used to pay, lend or bribe, or make another type of illegal payment in order to influence or compromise the proceeding of the recipient. The Group opposes any act of corruption or bribery of either public officials or individuals and does not tolerate practices whose purpose is to do business through improper means.

Therefore, it is prohibited for any administrator or employee of the Group to make gifts or deliver money or other goods to public officials or labor personnel of the public administrations, which can be interpreted as an attempt to bribe or as a means of obtaining a favor treatment illegal character. Excluded from the previous rule are the protocol services of reduced value and which will be recorded in a Registry of services.

Likewise, the Itercon Group undertakes not to carry out any act related to the possession, use or transfer of assets or rights whose criminal origin is known or suspected, nor to carry out any practice of concealment and concealment of such assets or of assistance to the people who have participated in the criminal activity from which they come.

The performance of the administrators and managers of each of the companies integrated in the Itercon Group, as well as that of all those who perform in it some kind of representative function, must at all times respect the ethical values ​​and the principles of action which are described in this Code. Their decisions must be respectful of the Law and of the duties of the administrators of the capital companies, always prioritizing the interest of the Group and that of the companies included therein, over their own private or extra-corporate interests.

Consequently, the realization by the administrators, proxies or any other persons who carry out a representative activity of the Group, of active or omisive behaviors that violate the Law or contravene such duties is considered unfair.

In particular, any of the following actions or activities will be considered unfair:

a) The excess of the powers attributed to them.

b) Failure to comply with the duty of secrecy regarding the information, data, reports or antecedents to which they have had access in the performance of their duties, unless this is necessary to inform the "Monitoring and Control Commission" of the commission of any crime by any of the administrators, directors or employees of any of the companies that are part of the Group, under the terms established in section XII of this Code of Conduct.

c) The prioritization of self-interest over the interest of the Group or that of its companies, in the event that both may be in conflict. If a possible conflict situation is detected, it must be reported to the management body of the affected company and, where appropriate, refrain from taking part in the deliberation and voting of the corresponding agreements or decisions, in the event that they arrive. to occur.

d) The use of company assets, including confidential company information, for private purposes.

e) Taking advantage of the company's business opportunities for its own benefit.

f) Obtaining benefits or remuneration associated with the performance of their position, from third parties outside the Group.

g) The development of activities for their own account or for others that involve effective competition, whether current or potential, with the Group company to which they belong.

Every member of the Itercon Group must cknow and meet the behavioral guidelines established in this Code and in the Compliance Program in which it is integrated, as well as the policies and procedures that develop and complement them. In addition, you must to collaborate for dissemination and implementation.

Every member of the Itercon Group must report to the Surveillance and Control Commission of any violation, alleged or actual, of applicable laws or regulations or of the provisions of this Code of Conduct and of the Compliance Program Under no circumstance will the fact of providing this type of information serve as a basis for adopting any retaliatory measures against the employee from whom it comes.

The Code designs the behavior model to be followed by all members of the Itercon Group in carrying out the activities entrusted as such, but does not resolve all the situations that may arise. Therefore, when a different or new situation arises, which may directly or indirectly affect the Group or any of the companies that comprise it and cannot be resolved in accordance with the principles established in this Code, it may be possible make an enquiry on the matter to the Monitoring and Control Commission, being able to use the Ethical Channel for this purpose.

The Itercon Group will establish a Monitoring and Control Committee for the application and monitoring of this Code of Conduct and the Compliance Program of which it is part.

The Commission will be composed of a representative of the Department of Occupational Safety, Quality, Environment, a member of the Department of Human Resources and a member of the legal department.

The operating regime of this Commission and its relations with the other organs of the Group are established in the Compliance Program.