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Code of Ethics

Code of Ethics and Conduct

The Code of Ethics and Conduct established by GLOMED INVEST SL. represents a clear statement of the values, principles, and regulations that should guide the behavior of all its employees and managers, ensuring ethical and responsible management in all their interactions, both internal and external, with colleagues, customers, suppliers, external partners, shareholders, public and private entities, and the community in general.

This Code seeks to prevent criminal acts and any unlawful behavior by those subject to these regulations in the performance of their duties, establishing appropriate supervision and control procedures to ensure compliance.

The guidelines for conduct included in this Code do not seek to cover all possible situations or circumstances that GLOMED INVEST SL. employees may face, but rather to provide basic guidelines to guide their behavior in the exercise of their professional activities.

All GLOMED INVEST SL employees are invited to contact their superiors or the Compliance Unit if they have any questions about the interpretation of the rules of conduct stipulated in this Code, or to use the Consultation and Reporting Line. This complements the company’s ongoing efforts to disseminate, communicate, and train its employees in these matters.

At GLOMED INVEST SL., a free working environment is guaranteed discrimination. Any form of harassment or abuse, whether physical, sexual, psychological, or verbal, toward employees is strictly prohibited, as is any behavior that may create an intimidating or degrading atmosphere.

Application and values

Compliance with these regulations is mandatory for all administrators, managers, and employees of GLOMED INVEST SL, as well as any entity within the business group to which they belong, regardless of the nature of their employment contract, their position within the organization, or their geographical location. This requirement also extends to professionals who are temporarily assigned to the company to offer their services.

In addition, this Code also applies to third parties who have a regular relationship with GLOMED INVEST SL., including suppliers, collaborators, and commercial agents.

This Code of Ethics and Conduct applies both domestically and internationally, in any country where GLOMED INVEST SL. has a presence or plans to expand. It is implemented both in Spain and abroad, always respecting the legal, cultural, social, and economic particularities of each region. When selecting business and professional partners, consideration will be given to whether they adhere to management and behavioral principles consistent with those set forth in this Code.

This Code is the cornerstone of the Organization and Management Model and the Criminal Risk Prevention Program, as well as their respective implementing regulations. Employees violate their commitment of loyalty to the company if they act in contravention of the guidelines set forth herein. Employees are prohibited from complying with orders that violate the law or this Code. In such situations, employees can and should refer to the Regulatory Compliance Unit through the appropriate channels.

If any irregular conduct is detected during the performance of control, prevention, or internal audit functions, the person who becomes aware of such irregularity must notify the Regulatory Compliance Unit using the means established for this purpose.

Employees are also required to participate in training and refresher programs organized by the Regulatory Compliance Unit, which are essential for the proper understanding and application of this Code of Organization and Management and the Criminal Risk Prevention Program

Core values:

Respect for the law, human rights, and ethical principles.
Dignity and consideration toward people, avoiding any form of harassment or abuse.
Promotion of equal opportunities and professional development without discrimination.
Encouragement of teamwork, based on mutual trust and collaboration.
Transparency and impartiality in decision-making.
The pursuit of excellence through rigor, talent, and passion.
Innovation, encouraging creativity and courage.
Adaptability, showing resilience and practicality in the face of change.
Integrity, always acting with honesty, transparency, and good faith..

Internal conduct and behavior

EQUAL OPPORTUNITIES AND NON-DISCRIMINATION

At GLOMED INVEST SL., we are committed to promoting both the professional and personal growth of all our employees, guaranteeing equal opportunities through equitable policies. All GLOMED INVEST SL. employees will have the same opportunities to advance in their professional careers, regardless of race, gender, beliefs, nationality, language, religion, sexual orientation, or any other personal or social aspect.

PROTECTION OF CONFIDENTIAL INFORMATION

At GLOMED INVEST SL., we value information and knowledge as key assets for our business management, deserving special protection. We have implemented an information security policy designed to maintain the integrity, availability, and confidentiality of our data, thereby reducing the risks associated with its exposure and misuse.

Employees are prohibited from disclosing, divulging, or using confidential information for unauthorized purposes or purposes that are not in the company’s interest, except in cases where it is legally permitted. In addition, measures must be taken to prevent this sensitive information from falling into the hands of competitors.

GLOMED INVEST SL. complies with current data protection legislation, ensuring the privacy of personal information provided by customers, employees, and other individuals, and undertaking to use only the data strictly necessary for the efficient management of the company.

USE AND CARE OF COMPANY ASSETS

Every employee of GLOMED INVEST SL. is responsible for using and protecting the assets and resources provided by the company in an appropriate manner. This includes intellectual property, facilities, equipment, machinery, and financial resources.

Employees must refrain from using these resources for personal or non-professional purposes and are responsible for protecting the assets entrusted to them in connection with their work, ensuring their proper safekeeping.

The use of external programs or files that may compromise the security of GLOMED INVEST SL. or violate intellectual property rights is prohibited. Employees must avoid the use of unauthorized software and activities that may introduce IT risks such as viruses or the misuse of external devices.

CONFLICT OF INTEREST

All employees and collaborators of GLOMED INVEST SL. must prioritize the interests of the company and avoid any personal activity that may generate a conflict of interest. It is imperative that employees act loyally and defend the interests of the company in the performance of their duties, ensuring that their actions do not compromise their integrity or that of GLOMED INVEST SL.

HEALTH AND SAFETY AT WORK

At GLOMED INVEST SL., we promote occupational health and safety policies and take preventive measures to provide a working environment that respects the health and dignity of our employees. We are committed to continuously updating occupational risk prevention measures and strictly complying with applicable regulations in this area in all locations where we operate.

All employees are responsible for strictly complying with occupational health and safety regulations. They can report any violation or non-compliance with measures affecting occupational health and safety through our Consultation and Reporting Line.

They must also use the equipment assigned to them during risky activities responsibly and share knowledge about risk protection practices with their colleagues and subordinates.

PROMOTING PERSONAL AND PROFESSIONAL DEVELOPMENT

At GLOMED INVEST SL., we promote and support a balance between our employees’ personal and professional lives, recognizing the benefits that this balance brings to both the employee and the company. We value a balance between our employees’ professional and personal responsibilities, and therefore encourage measures aimed at reconciling these two aspects.

Conduct and behavior in the market

FAIR COMPETITION AND DEFENSE OF COMPETITION

At GLOMED INVEST SL., we are committed to competing fairly in the markets, respecting free competition for the benefit of consumers and users, and always complying with current legal regulations.

Our employees will refrain from engaging in misleading advertising about our commercial activities and will avoid any behavior that could constitute an abuse or illegal restriction of competition.

FINANCIAL RECORDS

It is the responsibility of employees to ensure that all operations and transactions of economic relevance are clearly and accurately recorded in the accounting records. In particular, employees must refrain from:

Recording transactions in non-accounting media that are not reflected in the official books.
Failing to record transactions or recording them incorrectly.
Recording non-existent expenses, income, assets, or liabilities.
Making accounting entries with incorrect information about their nature.
Using falsified documents.
Deliberately destroying accounting documents before the deadline established by law.

In addition, GLOMED INVEST SL. will ensure full compliance with applicable tax regulations, relying on external advisors who specialize in this area.

CUSTOMER RELATIONS

At GLOMED INVEST SL., we promote a commitment to quality through best practices recognized nationally and internationally. All employees aim to achieve the highest standards of quality and excellence in the provision of services, seeking to establish long-term relationships based on trust and mutual respect with our customers.

In the event of potential conflicts of interest arising in customer relations involving a member of GLOMED INVEST SL., the immediate superior must be informed first. If this does not resolve the conflict, the Consultation and Reporting Line can be used, which will provide all the necessary cooperation, support, and coverage to manage and resolve the conflict situation.

RELATIONSHIPS WITH SUPPLIERS, CONTRACTORS, AND PARTNER COMPANIES

GLOMED INVEST SL. establishes collaborative relationships with its partners in joint ventures based on trust, transparency of information, and the exchange of knowledge and skills, within the limits established by competition law, with the aim of achieving common goals and mutual benefits.

All GLOMED INVEST SL. employees involved in the selection process for contractors, suppliers, and external collaborators must act impartially and objectively, applying quality and cost criteria and avoiding any conflict between their personal interests and those of the company.

The aspects of this Code of Ethics and Conduct that are applicable to contractors, suppliers, and external collaborators shall be included in the collaboration or service provision contracts that are formalized in each case.

RELATIONSHIP WITH GOVERNMENTS AND AUTHORITIES

GLOMED INVEST SL. maintains a position of political neutrality and is committed to faithfully and respectfully complying with all legal obligations in any country or territory where it conducts its operations.

GLOMED INVEST SL. employees shall avoid any behavior that, although not contrary to the law, could damage its reputation before the community, the government, or other bodies, and result in adverse consequences for the company. No employee shall collaborate with third parties in violating the law, nor shall they participate in actions that compromise the principle of legality.

They must act with honesty and integrity in all their interactions or transactions with government authorities and employees, ensuring that all information and certifications submitted, as well as statements made, are truthful, clear, and complete.

Furthermore, employees of GLOMED INVEST SL shall not interfere with requests for information from public officials or with the performance of any other function they carry out in the legitimate exercise of their powers, provided that they are supported by and comply with applicable laws.

ANTI-CORRUPTION MEASURES

Principle of zero tolerance for corruption. GLOMED INVEST SL. opposes influencing the will of persons outside the company to obtain benefits through the use of unethical practices. Likewise, it will not allow other persons or entities to use these practices with its employees.

Bribes.

All employees of GLOMED INVEST SL. must act in accordance with applicable laws and, under no circumstances, resort to or tolerate bribes from third parties to the Company, its employees, or vice versa.

GLOMED INVEST SL prohibits the use of any form of illicit payment, by any means whatsoever, that involves a material or moral advantage for the recipient, whether a public entity, a company, or a private individual, with the aim of obtaining any advantage or favorable treatment in its relations with third parties.

Similarly, employees are prohibited from accepting bribes for their own benefit. Nor may payments be made to political parties, trade unions, or similar entities in terms that are not expressly permitted by the legislation of the country in which they operate.

Gifts, presents, and courtesies.

GLOMED INVEST SL employees, by virtue of their position, may not accept gifts, hospitality, services, or any other kind of favor from any person or entity that could affect their objectivity or influence a commercial, professional, or administrative relationship.

Likewise, employees of GLOMED INVEST SL. may not offer, directly or indirectly, gifts, services, or any other kind of favor to customers, partners, or any other person or entity that maintains or may maintain relations with the company, with the in order to unlawfully influence such relationships.

PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING

In order to prevent and avoid money laundering or terrorist financing operations arising from criminal or illegal activities, GLOMED INVEST SL. employees must pay special attention to cases where there are indications of a lack of integrity on the part of the persons or entities with whom they do business.

PERSONAL DATA PROTECTION

GLOMED INVEST SL. has adopted all necessary and appropriate security measures in accordance with EU Regulation 2016/679 and Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights. It has established all technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access, or theft of the data it processes.

GLOMED INVEST SL. employees will not disclose personal data obtained from customers, suppliers, employees, public administrations, or the general public.

For additional and detailed information on Data Protection, please consult the Legal Notice and Privacy Policy on our website.

RESPECT FOR THE ENVIRONMENT

Preserving and respecting the environment are fundamental pillars of GLOMED INVEST SL., as demonstrated by its compliance with best environmental practices in all its activities. It is committed to conducting its activities in a manner that minimizes negative environmental impacts and achieves a high level of safety in its processes, facilities, and services. Conserving natural resources and promoting energy savings are essential.

INTERNAL CONTROL OF CRIMINAL LIABILITY

Internal control of crime is a priority objective for GLOMED INVEST SL. It is committed to the prevention, detection, and avoidance of any illegal activity carried out within the scope of its responsibilities, in its name or on its behalf and for its benefit, by any of its employees.

REGULATORY COMPLIANCE UNIT

The Compliance Unit of GLOMED INVEST SL. is an autonomous and independent body composed of members representing various areas, appointed by the Board of Directors. Its main functions include implementing, controlling, supervising, evaluating, and improving the crime prevention and detection model, ensuring the principles, values, and guidelines of conduct of the Code of Ethics, and ensuring the proper functioning and management of the consultation and reporting line.

CONSULTATION AND REPORTING LINE

GLOMED INVEST SL employees have a duty to report any illegal behavior, irregularities, or breaches of the Code and Model that they become aware of. Any doubts, questions, or complaints made through the Consultation and Complaint Line contribute to the detection of possible crimes and constitute a way for the Code of Ethics to be fully enforced, serving to continuously improve the preventive system.