Code of Conduct

Our Vision, Mission and Values

The mission of Grupo Empresarial Enhol (hereinafter “Grupo Enhol” or the “Group”) is to create value for a sustainable future. As a Group, we bear a great responsibility, as all our actions, decisions and investments must be underpinned by one fundamental principle: sustainability. In this way, we contribute to leaving a better environment for future generations.

Our vision is to be a diversified international Group that generates sustainable value across all its areas of activity, always with a view to improving the social and economic environment in which it operates.

Enhol Group Values:

Agility; flexibility and adaptability
Responsibility; mindful of every step we take
Innovation; imagining new ways to make an impact
Solvency; we pass on the baton of change
Entrepreneurship and diversification; an entrepreneurial attitude

The purpose of this Code of Conduct is to set out the values and ethical and operational principles that should guide the behaviour of all companies forming part of the Enhol Group – whether they are directly or indirectly owned by the Enhol Business Group or by third parties – and to establish and uphold a standard of business conduct that is respected by employees, those in positions of responsibility or management, and directors of the Enhol Group.

The company’s ideals include social responsibility, concern for the environment, honesty, excellence, respect for people, customer focus and financial soundness.

This Code of Conduct applies to all members of the Board of Directors, senior management and employees of the Group (hereinafter “members” or “affiliated persons”), as well as to all subsidiaries or associated companies over which the Enhol Business Group exercises control, either directly or indirectly.

We must ensure that our customers, suppliers and partner organisations implement ethical practices in line with our values as a Group.

This Code of Conduct was approved by the Board of Directors of Grupo Empresarial Enhol in April 2024.

The Code of Conduct comes into force upon its approval and will be disseminated through Grupo Enhol’s usual communication channels, including corporate email, the websites of the various companies forming part of the Group, and the intranet, amongst others. The Code of Conduct will be updated periodically in line with regulatory changes, modifications to the Group’s internal structure or improvements identified during reviews. This Code of Conduct will always be kept up to date on the Group’s website and intranet.

All members of the Group (where ‘members’ refers to the members of the Board of Directors, senior management and employees) must act responsibly, professionally and with integrity. They are responsible for familiarising themselves with and complying with the provisions of this Code of Conduct, as well as with applicable internal and external regulations.

All members undertake to report as soon as possible should they at any time become aware of a breach of this Code of Conduct or of internal or external regulations, and to cooperate with any investigations or audits that may need to be carried out.

Those members of the Group whose role involves managing and leading teams of people will have additional responsibilities, including:

Ensuring that their team is familiar with and complies with this Code.
Setting a good example.
Listening to and addressing any questions or concerns that may arise.

This Code of Conduct, together with the Group’s Vision, Mission and Values, is fully integrated into all existing protocols, policies and information channels within the Enhol Group (including the policy on the prevention of harassment and non-discrimination, the internal whistleblowing channel and the Internal Reporting System (SII), amongst others), as well as any that may be introduced in the future.

Grupo Enhol is particularly committed to protecting the most vulnerable groups, promoting equal opportunities for all employees.

The Enhol Group maintains a firm, active and effective commitment to the prevention, detection, rectification and sanctioning of any conduct constituting harassment or violence towards vulnerable groups, including victims of gender-based violence, people with disabilities and transgender people, whilst ensuring full respect for the rights of LGBTI people. To this end, the Group has the necessary policies, measures and protocols in place, implemented in accordance with current legislation and internal agreements reached within the company, promoting a safe, respectful and inclusive working environment at all times.

The Enhol Group guarantees the right of all company staff to a working environment free from hostile or intimidating conduct or behaviour towards them, ensuring both respect for the fundamental principles and values of all employees and their dignity and physical and mental integrity. This is demonstrated by the awareness campaigns aimed at eradicating any form of discriminatory practice within the company, which are directed at the entire workforce regardless of their role.

At the Enhol Group, no discriminatory action or behaviour on the grounds of race, gender, ideology, nationality, religion, age or disability is tolerated.

The Group and its members are committed to diversity in all its forms – functional, cultural and social – and promote a working environment characterised by inclusion and respect.

Training for all its members is a fundamental pillar for fostering the personal and professional growth of employees, those in management positions, and anyone else who forms part of the Group. All members will enjoy equal opportunities for professional development. Internal promotion will be based on objective criteria, including merit, ability and performance of duties.

All members will be treated fairly and with respect, regardless of their position or role, creating a respectful working environment with the aim of eliminating any form of discrimination or harassment.

The Enhol Group has drawn up a protocol for the prevention of and response to cases of harassment and discriminatory acts, and is committed to preventing and addressing such behaviour. At the Enhol Group, we have a zero-tolerance policy towards such acts and we reaffirm our commitment to maintaining a respectful working environment.

The Enhol Group aims to create a flexible working environment, based on objectives and results, underpinned by trust in and the productivity of its staff, which helps employees to balance their family and professional lives.

The Enhol Group is committed to providing a safe and healthy working environment for its staff, as well as for any other individuals from outside the organisation who visit our premises. Creating a safe environment is the responsibility of all members of the Group and must be the primary consideration when making any decision.

The Enhol Group will take the necessary measures to ensure suitable working environments in accordance with applicable regulations and the prevailing environmental or other circumstances at any given time.

The Enhol Group regards the use of information technology as the primary tool for institutional and corporate communication which, in line with its strategy, core values and objectives, can help to strengthen its corporate identity and culture. It is for this reason that the dissemination of false information, or the making of statements or the display of images that may be illegal, indecent, inappropriate, offensive, discriminatory, humiliating or defamatory; that breach the duty of confidentiality or professional secrecy; or that may in any way affect the prestige and reputation of Grupo Enhol, is strictly prohibited.

The internal regulations governing the use of Grupo Enhol’s information systems must be strictly adhered to, with the highest level of security measures applied to IT systems.

Grupo Enhol and its members shall acknowledge receipt of any technological devices provided or made available to them and shall return such devices upon leaving the Company, in accordance with the procedures and deadlines set out in the internal regulations governing the use of Grupo Enhol’s information systems.

The rules governing the use of email, internet access or other similar resources made available to them must be observed; under no circumstances may these be used in an inappropriate or unprofessional manner.

You must comply with the regulations governing the use of email, internet access or other similar resources made available to you; under no circumstances may you use them in an inappropriate or unprofessional manner.

Grupo Enhol is the owner of the property and/or the rights of use and exploitation of the computer programmes and systems, equipment, manuals, videos, projects, studies, reports and works, as well as the rights created, developed, refined or used within the framework of a work-related or professional activity or based on Grupo Enhol’s IT facilities.

The principle of confidentiality must be observed with regard to the characteristics of rights, licences, software, systems and technological knowledge, in general, the ownership or rights of exploitation or use of which belong to Grupo Enhol.

No one to whom this Code of Conduct applies shall under any circumstances exploit, reproduce, replicate or transfer Grupo Enhol’s computer systems and applications for private purposes or for purposes unrelated to the company.

Furthermore, it is prohibited to install or use, on computer equipment provided by the Enhol Group, any software, programmes or applications whose use is unlawful or which may damage, impair, alter, delete, render inaccessible or disrupt the operation of data, computer programmes, electronic documents or computer systems, or harm the reputation or interests of the Enhol Group, its stakeholders or third parties in general; or whose installation has not been previously approved, certified and authorised by the organisation’s IT Department.

The creation of, membership of, participation in or collaboration on social media, forums or blogs on the internet, and any opinions or statements made therein, must be carried out in such a way that their personal nature is made clear.

All persons subject to this Code of Conduct undertake to respect and safeguard the intellectual property and the corresponding rights of use held by Grupo Enhol in relation to courses, projects, programmes and computer systems; devices, manuals and audiovisual material; knowledge, procedures, technology, expertise and, in general, the works and projects developed or conceived within Grupo Enhol, whether as a result of their own work or that of third parties. Consequently, their use shall be permitted solely within the scope of one’s work or profession, and all material on which they are based shall be returned when so required.

The image, name and/or trademarks of Grupo Enhol or any of its subsidiaries, in which Grupo Empresarial Enhol holds a direct or indirect stake, shall only be used for the proper conduct of activities within the Group.

Respect for the intellectual and industrial property rights held by third parties not affiliated with Grupo Enhol shall also be guaranteed. In particular, the use of any content protected by intellectual or industrial property rights belonging to third parties shall require the prior obtaining of the relevant authorisation or licence.

All members of Grupo Enhol shall at all times act with loyalty, diligence and in the best interests of the organisation. In situations where there may be any doubt, the employee must inform their line manager to avoid any suspicion that they have acted against the organisation’s interests.

Anyone who may be directly or indirectly affected by a conflict of interest must refrain from representing Grupo Enhol, as well as from intervening in or influencing decision-making, and must report such a situation to their line manager.

The Enhol Group is firmly committed to free and open competition, and its staff are committed to competing in the markets in good faith, whilst respecting and promoting the rules and principles of free competition.

Transparency of information is a fundamental principle governing its actions.

All members of the Enhol Group undertake to communicate information, both internally and externally, in a truthful, clear, complete and up-to-date manner. Under no circumstances will it disclose erroneous, incomplete or inaccurate information that does not give a true and fair view of the Group.

The Enhol Group is committed, on its own behalf and on behalf of its members, to upholding high standards of conduct both internally and externally.

To this end, it is committed to implementing best practice in the areas of recruitment, staff promotion, remuneration and work-life balance, in line with applicable case law and the values of social diversity and inclusion.

Grupo Enhol, together with its members, must nurture its intra-group relationships, as well as those with third parties, acting in accordance with the highest standards of integrity and respect.

All members of the group are obliged to comply with the ethical principles and standards of responsible conduct set out in this Code of Conduct.

The Enhol Group embraces, leads and promotes a commitment to the quality of its products and services, and operates in accordance with recognised national and international best practices.

All members must nurture relationships with customers, acting with integrity and aiming to achieve the highest levels of quality and excellence in the provision of services, whilst seeking to develop long-term relationships based on trust and mutual respect.

The Group requires its customers to comply with the ethical principles and standards of responsible conduct set out in this Code of Conduct.

The Enhol Group establishes a relationship with its partners based on trust and transparency in collaboration, always in accordance with the regulations in force at any given time and in support of free competition.

The Group requires its partners to comply with the ethical principles and standards of responsible conduct set out in this Code of Conduct.

The Enhol Group considers its contractors, suppliers and partner companies to be essential to achieving its objectives of growth and improving service quality, and seeks to establish relationships with them based on trust, mutual benefit and respect for free competition.

The Group promotes the engagement of third parties that demonstrate good practice in ESG (Environmental, Social and Governance) matters. The selection processes for suppliers, contractors and partners are conducted impartially, objectively and transparently, with criteria relating to quality, cost and sustainability being applied.

The Group requires its suppliers, contractors and partners to comply with the ethical principles and standards of responsible conduct set out in this Code of Conduct.

Members of the Group shall engage and interact with public authorities and institutions in a lawful and respectful manner, in accordance with the principles of cooperation and transparency.

Grupo Enhol is committed to conducting business with integrity, honesty and transparency, complying with applicable anti-corruption regulations in its dealings with both public and private entities, and expressly prohibiting the obtaining of any benefit or commercial advantage through corrupt, unlawful or improper means. Grupo Enhol expresses this firm commitment to zero tolerance of any form of corruption.

The offering and acceptance of bribes in both the public and private sectors are prohibited and subject to sanctions. Accordingly, Grupo Enhol prohibits the use of any form of unlawful payment, by any means whatsoever, which confers a material or moral advantage on the recipient and which is made with the aim of obtaining any advantage or favourable treatment in its dealings with third parties

Nor may contributions be made to political parties, trade unions or similar organisations in any manner not expressly permitted by the legislation of the country in which the Group operates.

Similarly, Grupo Enhol prohibits the making of facilitation payments. These payments involve the provision of money or goods to public officials with the aim of facilitating or expediting routine administrative procedures (for example, obtaining a visa or a licence) without this involving any discretionary act on their part (the procedure is lawful, but the payment speeds up or facilitates its completion).

In order to prevent any contribution from being used to conceal an improper payment, a bribe or any other unacceptable practice, fraud in accounting records and the incurring of any expenditure, payment or transaction not authorised by the Group in accordance with the applicable internal regulations are likewise prohibited.

At Grupo Enhol, we believe that giving appropriate gifts and invitations can help to foster professional relationships, and we trust in the common sense and sound judgement of our staff. Giving gifts and invitations must never compromise our ability to make sound and objective business decisions.

Integrity and our Code require that we:

Do not offer gifts to influence a business decision.
Do not accept gifts if the organisation suspects that someone is attempting to influence our decisions.
Consult a line manager if we are unsure whether certain gifts or invitations are appropriate.
Do not offer gifts if the recipients are public authorities or officials (or persons associated with them), except in cases such as customary courtesy gifts and hospitality.
Gifts and invitations must:
Be consistent with standard business practice.
Be of symbolic value.
Be appropriate.
Be infrequent.
Not be solicited.

The Enhol Group recognises Corporate Social Responsibility as part of its management strategy, a factor in its competitiveness and a fundamental element of its policy on engagement with society. Furthermore, it fulfils its commitment as a socially responsible organisation by striving to maintain a constant and fluid relationship with society.

It is also committed to conducting its business in such a way as to minimise the adverse environmental impacts resulting from its operations and to achieve a high standard of quality in its processes, projects, facilities and services, paying particular attention to the protection of the local environment and to the relationship between its staff, supply chain, customers and other stakeholders and the environment.

To achieve these objectives, the Enhol Group provides the necessary resources to ensure proper protection and promotes awareness, encouraging innovation and digitalisation initiatives that improve processes across all its business lines.

In its dealings with suppliers, contractors and partners, the Enhol Group will communicate these principles and require compliance with the environmental procedures and requirements applicable in each case.

The Enhol Group seeks to align its business activities with its social engagement, striving to build strong and lasting relationships with the local communities where the company operates, thereby demonstrating its positive impact.

Grupo Enhol’s commitment to society takes the form of sponsorship initiatives and partnerships through agreements with organisations representing civil society. The Group will only sponsor or make donations to organisations that are not involved in situations or activities that could compromise its reputation.

Furthermore, the Enhol Group will encourage and promote collaboration between its members and organisations of social interest in the areas where it operates, through corporate volunteering programmes, amongst other initiatives.

All donations or sponsorships must have the necessary authorisations, be properly documented and carried out transparently, so that they cannot be construed as an improper payment or bribe.

Grupo Enhol’s social responsibility and its commitment to society extend to the international stage through its commitment to and respect for human rights.

Grupo Enhol has a Human Rights Policy which sets out the principles and commitments that guide the organisation’s actions in this area. In line with this policy, Grupo Enhol and everyone who forms part of the organisation are committed to respecting internationally recognised human rights, including the rights set out in the International Bill of Human Rights and the fundamental principles and rights at work defined by the International Labour Organisation (ILO).

To ensure the effectiveness and compliance with this Code of Conduct, the Enhol Group will establish a monitoring and oversight body comprising representatives from various areas of the Group.

This body will be responsible for ensuring compliance with and the implementation of this Code, as well as for carrying out whatever communication, awareness-raising and training activities are necessary to disseminate the content of this Code of Conduct.

This Code of Conduct is a living document that may be updated periodically as a result of regulatory changes, changes to the Group’s structure or improvements arising from subsequent reviews.

The Internal Reporting System (or whistleblowing channel) is a tool designed to facilitate the submission of any enquiries regarding the scope and applicability of this Code of Conduct, via the ‘Ethics and Whistleblowing Channel’ sub-channel within the CORESOL tool, as well as to report, securely and confidentially, any potential breaches of the guidelines and conduct set out in this Code of Conduct, and of any other applicable internal or external regulations. This Enquiry and Whistleblowing Line is the appropriate channel for reporting, amongst other things, possible criminal or corrupt conduct, or breaches of competition law, towards which the Enhol Group maintains a zero-tolerance policy.

Through the CORESOL tool, you may also report any potential breaches or irregularities within the company, as described in Law 2/2023 of 20 February governing the protection of whistleblowers and the fight against corruption, and more specifically the following:

• Conduct relating to fraud, corruption, public procurement, money laundering, losses to the Treasury or the Social Security system, taxation and/or the financing of terrorism.
• Conduct relating to information security, data protection, product safety, public health, consumer protection, breaches of state aid rules, and/or securities markets.
• Conduct contrary to human rights, or damage to the environment.
• Other possible serious or very serious criminal or administrative offences.

The principles underpinning this channel are: Confidentiality and guaranteed anonymity / Data protection / Good faith / Diligence / Omnichannel approach / Security / Impartial investigation process / Protection against retaliation / Prevention and proactive measures to avert future breaches.

The Regulatory Control and Monitoring Body is responsible for the operation of the Internal Reporting System (or whistleblowing channel), as well as for analysing the reports and enquiries submitted through it; to this end, it may request the cooperation of other departments, divisions or members of the Enhol Group, who shall be obliged to comply with its request.

This whistleblowing channel is accessible via the following link, which is available to all members of the Enhol Group as well as contractors, subcontractors, suppliers, former employees, volunteers, interns, collaborators, and individuals whose employment, professional or business relationship with the Enhol Group has not yet commenced, in cases where information regarding breaches has been obtained during the selection process or pre-contractual negotiations:

Whistleblowing Channel: Co-Resol 🡪 https://co-resol.bcnresol.com/es/webclick

The whistleblowing channel indicated above can be used via either of these two options (the recommended option being the app, which provides an instant response):

1. App Co-Resol (recommended option):

The steps to follow are:

1. Download the co-resol app and accept notifications. It is free and available on the App Store and Google Play.
2. Tap the “Click here” button, then enter the code ENHOL and select the relevant sub-channel button.
3. Write your message, being as specific as possible, or send a voice note. You can attach both images and documents.
4. Identify yourself or select the option to remain anonymous (as you prefer). In either case, you must accept the Privacy Policy.
5. Once you have completed these steps, a message will appear on the screen confirming receipt of your click.
6. Communication regarding the follow-up to the reported incident will take place via a secure chat (which you can access via the chat button on the app’s home screen) until the case is closed.

Via the website:

The steps to follow are:

1. Access co-resol via: https://co-resol.bcnresol.com/webclick
2. Click the “Click here” button and then enter the code ENHOL, selecting the button for the relevant sub-channel.
3. Write your message, being as specific as possible, or send a voice note. You can attach both images and documents.
4. Identify yourself or select the option to remain anonymous (as you prefer). In either case, you must accept the Privacy Policy.
5. In this case, you will receive a unique identification code and password, which you must keep safe to continue communicating, via a secure chat, about the status of your complaint.
6. Whenever you wish to check for new messages in the chat or provide further information, you must go to the homepage at https://canalco-resol.com, click the ‘Access previous session’ button and enter the ENHOL code, as well as the ID and PIN you have saved.

Stage One: Identification of the problem

Any Group member, supplier or partner who becomes aware of, or has knowledge of, any irregular conduct or any breach or violation of the rules set out in the Code of Conduct must report such conduct immediately to their line manager or, preferably, via the CORESOL tool.

Stage Two: Reporting

It is recommended that, when reporting misconduct via CORESOL (https://canalco-resol.com), the report should be as descriptive and detailed as possible, including references to dates, incidents, facts and witnesses.

Reports submitted via the Whistleblowing Channel may be made either by name or anonymously, and the absolute confidentiality of the entire process will be guaranteed, as will the protection of the whistleblower’s identity to the extent permitted by law.

Should the complaint be reported via your line manager, they will be responsible for notifying the Regulatory Control and Monitoring Body to initiate the case file/investigation.

Stage Three: Action and investigation

Upon receiving notification of the complaint, the Code of Conduct Committee shall initiate an investigation procedure, during which the following measures may be taken:

Appointment of an investigator from within or outside the Group (hereinafter, the “Investigator”) to lead the investigation and draw up an investigation report.
Conducting face-to-face interviews with those affected by the misconduct.
Requesting reports or documents necessary to initiate the procedure from company departments.
Requesting expert evidence (e.g. IT-related) from professionals within or outside the company.
Providing regular updates to the company’s senior management on the progress of the investigation.

The Regulatory Control and Monitoring Body shall at all times ensure the confidentiality of the investigation process and its contents.

All departments of the company must cooperate with the Investigator, who may request from them testimony, cooperation, documentation and technical support relating to their professional activities within the Group.

Phase Four: Conclusions

The Regulatory Control and Monitoring Body shall draw up a final report setting out the decisions and recommendations to be adopted should conduct in breach of the Code of Conduct be observed, and/or the proposed sanction, where applicable, which it shall submit to the Management Committee for the relevant decision to be taken.

To determine the sanction, the Regulatory Control and Monitoring Body will consult the People and Culture Department, as well as the company’s external advisers (where necessary), to apply disciplinary measures in accordance with internal procedures, current collective agreements and applicable employment legislation.

If no breach is identified, the investigation file will be closed and archived, and the Management Committee will be informed of the actions taken.

The Enhol Group will communicate and disseminate the contents of this Code of Conduct to all its members, as well as to suppliers and partners. All those who join the Group must accept the values, principles and standards of conduct set out herein.

Ethical and compliance issues may be included in training programmes, performance appraisal processes and/or the assessment of potential candidates or third parties.

Any breach of the principles contained in this Code of Conduct will be investigated in accordance with internal procedures, applicable collective agreements and statutory regulations. Where a breach is identified, the Group’s People and Culture Department will determine the application of disciplinary measures in accordance with the system of offences and sanctions set out in the collective agreement of the company to which the employee belongs, or in the applicable labour legislation, and if the conduct is deemed to be contrary to the principles of good faith in contractual relations.

No one, regardless of their level or position, is authorised to ask a member of the Group to contravene the provisions of this Code of Conduct. No member may justify improper conduct by citing an order from a superior or ignorance of this Code of Conduct.

Members must report any breach or violation of the standards of conduct set out in this document to their line manager, the Code of Conduct Committee or via CORESOL. Although line managers are in place, it is recommended that the CORESOL tool be used as the primary means of reporting irregularities and making enquiries to the Code of Conduct Committee.