INTRODUCTION
This Code of Ethics, hereinafter referred to as the “Code”, is a mandatory guide to ensure ethical and appropriate behavior in the professional development of its management and administrative bodies, personnel and third parties, in accordance with the established laws and regulations. It is the reflection of how the management expects not only the entity but each of its members to behave, compiling the values, principles and ethical guidelines and conduct that make up the organizational culture of Bonpilates, S.L., hereinafter “Bonpilates”.
Bonpilates may request its suppliers, customers, collaborating companies and counterparties to formalize their commitment to compliance with the Code or with the rules it establishes. Its application may be extended to any person or organization linked to Bonpilates when Bonpilates deems it appropriate.
Unethical behavior, outside this Code, may have serious consequences for Bonpilates, such as judicial or administrative sanctions, material or financial losses and reputational damage, compromising, consequently, the relationship of trust between Bonpilates and its parties involved, that is, partners, employees, customers, suppliers and all those individuals whose interests are influenced by the direct or indirect effects of the activities carried out by Bonpilates.
This Code was approved on March 26, 2021 at the General Meeting of Shareholders.
CRITERIA OF CONDUCT
In relations with partners
Bonpilates develops its activity in accordance with the social interest and with standards of transparency and correctness of the business management, so that it is guaranteed:
(i) The effectiveness in management and the validity of the control of objectives and activities in the corporate field.
(ii) The reliability and correctness of the accounting records that allow the issuance of balance sheets and results with total transparency and in compliance with current regulations.
(iii) Compliance with tax and social security regulations, avoiding risks and inefficiencies in the execution of business decisions.
(iv) Safeguarding corporate assets.
In relations with authorities and officials.
Bonpilates and its collaborators relate to public authorities and institutions in a lawful and ethical manner, respecting at all times the international provisions for the prevention of corruption and bribery.
No employee may offer, promise, grant, request or accept, directly or indirectly, illicit payments or other advantages, favors or compensation, whatever their nature, to or from any authorities or officials. The only exceptions are gifts and hospitality of small value that are proportionate and reasonable according to local practice, given for a legitimate, socially acceptable and sporadic interest, so as not to cast doubt on the good faith of the collaborator or Bonpilates. Cash gifts are expressly forbidden.
Bonpilates collaborators will refrain from making payments, whatever its form, to facilitate or expedite procedures or proceedings before any judicial body, public administration or official body.
In employee relations
Bonpilates maintains and promotes respect for the human and labor rights recognized in the legislation in force at all times and is committed to applying the regulations on employment conditions, health and safety in the workplace.
Bonpilates promotes non-discrimination based on race, color, nationality, social origin, age, sex, marital status, sexual orientation, ideology, political opinions, religion or any other personal, physical or social condition of its professionals.
The personnel evaluation is done respecting the principle of equal opportunity for all concerned, respecting at all times the private sphere and the opinions of the candidates and avoiding favoritism in the selection and hiring phases.
No form of illegal hiring is accepted.
All employees are obliged to comply with applicable labor standards and to act, in their working relationships with other employees, in a respectful, dignified and fair manner, not allowing any form of violence, harassment or abuse at work or discrimination based on race, religion, age, nationality, gender or any other condition.
Access to functions and positions is established taking into account competencies and capabilities, avoiding forms of nepotism, and prioritizing the overall efficiency of the work.
At Bonpilates, priority is given to the protection of its own financial, patrimonial and human resources and to the protection of its employees.
In customer relations.
Bonpilates is committed to compete in the markets in a legal way guaranteeing standards of quality and healthiness in its products and services and striving to promote consumer education and the fight against misleading practices.
Bonpilates’ communications to its customers are made without pressure and not using misleading or false advertising tools and the treatment with them is made under criteria of respect and courtesy.
Bonpilates deals with suggestions and complaints made by customers using appropriate communication systems and taking care to inform customers of the time, which in any case will be short, necessary to provide a response.
In relations with suppliers.
Bonpilates staff and its collaborators relate with suppliers of goods and services in a fair, ethical and respectful way.
Purchasing and procurement procedures are based on the search for the greatest competitive advantage, but guaranteeing equal opportunities among suppliers. The key criteria for the selection of suppliers are based on objectivity and transparency, reconciling Bonpilates’ interest in obtaining the best conditions with the convenience of maintaining stable relationships with ethical and responsible suppliers.
The maximum transparency and efficiency of the purchasing process is ensured, in accordance with the adopted ethical standards and principles.
Neither Bonpilates personnel nor any collaborator may offer, grant, request or accept, directly or indirectly, any gift, favor or compensation, whatever its nature, that may influence the decision making process related to the performance of the functions derived from their position.
In relations with the Company
Bonpilates is firmly committed to the principles that govern a policy of crime prevention, anti-fraud, anti-money laundering, anti-corruption and anti-bribery.
Bonpilates and its collaborators develop environmental policies that minimize the environmental impact at each stage of the production process, minimizing waste and pollution, conserving natural resources and promoting energy saving.
Confidentiality of information and protection of personal data.
Bonpilates staff may not use for their own benefit or communicate to third parties, any data, information or documents obtained during the course of their professional activity that, unless otherwise indicated, should be considered confidential and may only be used for the purpose for which it was obtained.
Also, no duplicates of the information may be made or stored in information systems that are not owned by Bonpilates and shall be obliged to return it at the time of termination of their employment relationship with it.
In the collection of personal data from customers, employees, contractors or any person or entity with which it has a contractual relationship or otherwise, Bonpilates staff is committed to its use in accordance with the purpose for which they were obtained, respecting the internal procedures to ensure the different levels of security required.
ETHICAL MAILBOX AND COMPLIANCE
Bonpilates, with the sole purpose of promoting compliance with the law and the rules of conduct set forth in this Code, has enabled an “ethical mailbox” at the following email address: compliance-officer@bonpilates.com.
Complaints will be received and processed by the Compliance Department, which will treat the identity of the person reporting the anomaly as confidential information. Likewise, any data provided will be included in a personal data file. In the investigation processes Bonpilates guarantees the rights to privacy, defense and presumption of innocence of the persons under investigation.
Compliance is responsible for the dissemination of the contents of this Code and the evaluation and issuance of an annual report on its degree of compliance, which will be reviewed and updated periodically, taking into account the periodic Compliance report, as well as the suggestions and proposals made by employees, collaborators and third parties.
