Code of Ethics and Professional Conduct

Contents

• Message from the Managing Director
• Purpose
• Scope of application
• Mission and vision
• Corporate values
• Standards of conduct
   
  • Basic principles of conduct
    • Respect for the law
    • Ethical integrity
    • Respect for human rights
  • General standards of conduct
    • Strengthening the company’s reputation
  • Relationship with and between persons
    • Work environment
    • Equal opportunities and non-discrimination
    • Diversity
    • Professional development and training
    • Health and safety at work
    • Collective rights
    • Personal data protection
    • Use and protection of Salinera Española’s assets and resources
    • Confidentiality
  • Relationship with suppliers and contractors
  • Relationship with the community
    • Environmental protection
    • Corruption
    • Gifts and gratuities
• Monitoring and control
   
  • Code of Ethics and Professional Committee and Whistleblowing Channel
  • Disciplinary sanctions

Message from the Managing Director

One of the basic pillars upon which Salinera Española must base its strategy as a responsible and sustainable company is to respect and ensure respect for the values and principles that comprise this Code of Ethics and Professional Conduct. Society in general increasingly demands greater responsibility from companies, and Salinera Española must carry out all its operations from an ethical and responsible perspective. The task of maintaining trust in Salinera Española amongst our stakeholders depends on all our staff, and I am convinced that conducting ourselves with integrity, responsibility and respect will help us achieve this.

The objective of this Code of Ethics and Professional Conduct is to ensure that the entire Salinera Española workforce is fully aware of the values and general principles that should serve as a guide to govern their work and professional activity. It is therefore essential that all staff members read it, understand it and share it.

I thank you in advance for your commitment to upholding our principles and encourage you all to make yourselves familiar with and apply this Code in your daily business, convinced it will help us feel proud of the company we work for and help contribute to our desire to be a benchmark company within our community in terms of responsibility.

Cristino Elías

Purpose

The Salinera Española Code of Ethics and Professional Conduct contains the fundamental principles that should serve as a guide to all members of the Board of Directors, top management and company employees.

This Code ensures the collective application of Salinera Española’s commitments, the effective compliance with human and employment rights and the integration of the entire collective of individuals, with all their complexity and diversity, into the corporate culture.

The Salinera Española Code of Ethics and Professional Conduct seeks to develop the models and guidelines for professional, ethical and socially-responsible conduct that should guide everyone who is part of Salinera Española in the pursuit of their business activity and also prevent criminal acts and any illicit conduct being committed, plus set out mechanisms for the monitoring and control necessary to guarantee compliance.

Scope of application

The scope of application of this Code covers all persons who form part of Salinera Española:

• Members of the Board of Directors.
• Management.
• The entire workforce.

Mission and vision

Mission: to produce different types of salt, able to satisfy the quality specifications and requirements of the most discerning markets and clients.

Vision: to be a benchmark company in terms of the quality, innovation and sustainability of our products.

Corporate values

This Code constitutes one of the principal elements within the management of Salinera Española’s Corporate Social Responsibility, and it serves as the channel for the development of its corporate values, which for Salinera Española are:

Integrity

Those who form part of Salinera Española assume the responsibility of acting with integrity through honest, decent and ethical behaviour that generates trust in our company based on transparency in management and in all communication we have with our stakeholders.

Innovation

Salinera Española is a company committed to continuous improvement and technological innovation.

Vocation of service

We are a company fully focussed on our clientele, seeking to offer quality services that guarantee their satisfaction as well as building honest and earnest relationships with them, working with friendliness and respect.

Respect for the environment

For Salinera Española, respect for and commitment to the environment are a priority, reducing the environmental impact our actions have and contributing to the preservation and conservation of biodiversity.

People

Salinera Española’s biggest asset is its employees and for this reason we are committed to ensuring appropriate and stable working relationships within a context of equal opportunities.

Salinera Española’s corporate values form the foundations on which this Code is based and set out the general procedural guidelines that should be observed by all Salinera Española staff in carrying out their professional duties.

Standards of conduct

Basic principles of conduct

Respect for the law

Everyone who works at Salinera Española will, when carrying out their professional activities, maintain strict compliance with current legal regulations.

Ethical integrity

Personal integrity and professional ethics are highly valued assets for Salinera Española and therefore everyone should carry out their activity with objectivity and professionalism.

Respect for human rights

The actions of Salinera Española and of all persons who form part of it shall scrupulously respect the Human Rights and Public Freedoms included in the Universal Declaration of Human Rights.

General standards of conduct

Strengthening the company’s reputation

Each and every one of the individuals who form part of Salinera Española will participate in the task of enhancing the good name of Salinera Española, and the responsibility of ensuring its sound reputation falls to everyone.

Relationship with and between persons

Work environment

Salinera Española strives to create working environments where trust and respect for the dignity of all persons prevail, alongside cordiality and teamwork. Salinera Española expressly prohibits any abuse of authority, and also any other conduct that may generate an intimidating or hostile work environment.

Everyone who is part of Salinera Española will contribute to maintaining a pleasant, rewarding and safe working atmosphere that encourages people to give the best of themselves.

Equal opportunities and non-discrimination

Salinera Española guarantees equal opportunities and is committed to putting measures in place to help all staff in their professional and personal development. Similarly, it does not permit any form of discrimination on the grounds of gender, race, sexual orientation, religious beliefs, public opinions, nationality, social origin, disability or any other circumstance that may be a source of discrimination.

Diversity

Salinera Española works to integrate the diversity and complexity of its human resources, whilst also guaranteeing the collective application of the same internal policy.

Professional development and training

Salinera Española is committed to putting in place all measures necessary to contribute to the learning, training and upgrading of knowledge and skills of all persons who form part of the company, to facilitate their employability and professional progress. For their part, Salinera Española employees commit to participating in training programmes as required and will make every effort to garner maximum benefit from them.

Health and safety at work

Salinera Española considers the health and safety at work of its staff as a basic precondition to achieving a comfortable and safe work environment, with the constant improvement in working conditions being a priority objective.

For this reason, the entire staff of Salinera Española will at all times observe the preventative measures applicable in matters of health and safety at work, scrupulously complying with current legislation in force.

Collective rights

Persons who form part of Salinera Española will respect the internationally-recognised trade union, freedom of association and collective bargaining rights, and also the activities that are carried out by the employees’ representative organisations, in accordance with the functions and competences legally attributed to them, with whom a relationship based on mutual respect will be maintained in order to promote open, transparent and constructive dialogue that permits the consolidation of the goals of social peace and employment stability.

Personal data protection

All personal data will be processed in an especially restrictive manner and only that necessary will be collected. Non-public information will be considered private and confidential, therefore the necessary mechanisms will be applied to preserve its integrity, availability and confidentiality.

Only personnel who are authorised due to their work position shall have access to this data to the extent required and in accordance with applicable legal provisions.

Use and protection of Salinera Española’s assets and resources

Salinera Española makes available to the workforce all resources necessary to carry out their professional activity and provides the means necessary for their adequate protection and safeguarding.

Each employee at Salinera Española is responsible for the correct use and protection of the assets and resources provided by the company. These include Salinera Española’s intellectual property, facilities, equipment and financial resources.

All computer and communications equipment and systems that Salinera Española makes available for use by its employees must be used exclusively to carry out their work activity.

Confidentiality

In general, all persons subject to this Code shall maintain professional secrecy with respect to all non-public data and information they become aware of during the course of their professional activity, and minimise risks that may arise from its disclosure and improper use both internally and externally.

Relationship with suppliers and contractors

All processes for the selection of suppliers and contractors are carried out with total impartiality and objectivity.

In these processes, everyone who forms part of Salinera Española should apply the necessary quality, opportunity and cost criteria, always acting in the interests of Salinera Española. They will also promote awareness of this Code amongst these suppliers and contractors in order to better apply the principles contained herein.

Relationship with the community

Environmental protection

Salinera Española is a company that is strongly committed to protecting and respecting the environment and similarly all staff members must protect and respect the environment and reduce negative environmental impact, work with maximum energy efficiency and adhere to preserving biodiversity.

Corruption

Salinera Española understands corruption as being the use of non-ethical practices to obtain some form of benefit. Under no circumstances may people who form part of Salinera Española resort to unethical practices to influence the will of persons outside Salinera Española to gain some advantage for the company or for themselves. They must also remain alert to ensuring that instances where other persons or organisations make use of these practices in their relationship with the company do not occur.

Gifts and gratuities

All Salinera Española staff, aside from customs and social practices, may not make, offer or receive, directly or indirectly, any cash payment in kind or any other benefit that, owing to its value, nature or circumstance, may conceivably alter the course of the commercial, administrative or professional activities in which they are involved.

Monitoring and control

Persons subject to this Code are bound to be familiar with its content and the values it is based on, and also to comply with it.

Code of Ethics and Professional Conduct Committee and Whistleblowing Channel

Salinera Española will create the Code of Ethics and Conduct Committee as a body for management, consultation and answering queries on its content.

This Committee will be formed of the Managing Director and heads of the Sales, Financial and Human Resources departments.

Salinera Española takes a very positive view of management staff and employees who report illegal conduct. Whistleblowing, as well as serving to uncover possible irregularities, constitutes an essential tool for ensuring the Code is fully effective and for continuously improving our health and safety at work policy and quality standards. No employee should believe they are acting in the interests of the company by concealing a fact or incident that violates the law or the Code of Ethics and Professional Conduct.

The members of the Committee shall have competence to receive information and complaints related to breaches of the Code guaranteeing the confidentiality of all persons that use the established procedure to send their report using this link. Similarly, the complaints that are processed will be handled by the Code of Ethics and Professional Conduct Committee through an exhaustive analysis of any breaches of the Code and with respect for the persons allegedly involved in them.

Disciplinary sanctions

The Salinera Española management will take the legal or disciplinary measures it deems appropriate, in accordance with current legislation, to prevent non-compliance with this Code of Ethics and Professional Conduct and will ensure that no inappropriate actions occur to those who report the violation.

The decision to apply sanctions, and also to decide the pertinent sanction, shall fall to the Managing Director of Salinera Española, upon receipt of a report from the Code of Ethics and Professional Conduct Committee.