TIRME has a Code of Ethics.

The prime objective is to work with all TIRME’s employees and stakeholders in order to create a framework for co-existence and self-responsibility.

1. All members of the company are required to comply with the principles of legality, transparency, veracity, trust and good faith when carrying out their functions.

2. Company staff must not commit any illegal actions related to the execution and compliance of the activities their position involves.

3. All members of the company shall have equal conditions and opportunities without regard to race or ethnicity, religion, ideology, nationality, gender, sexual orientation/identity, age, disability, diversity, political affiliation, trade union membership, illness, serological status, genetic predisposition to disease, language, socio-economic status, or any other personal or social circumstances.

4. Freedom of conscience and the religious and moral convictions, integrity and privacy of all persons shall be respected.

5. All persons shall be treated fairly and with dignity and respect, including staff belonging to other companies who are working temporarily at TIRME’s facilities.

6. No form of intimidation, direct or indirect discrimination, harassment of any type, unlawful or degrading treatment of any person by any colleague and/or superior at all levels, abuse, coercion or any other type of unprofessional actions shall be tolerated. Particular efforts shall be taken to safeguard the integrity and rights of any minors visiting the company’s facilities.

7. Under no circumstances shall any form of aggression against personal dignity be tolerated. This includes sexual aggression, violent actions and/or physical or verbal threats, aggressive, derogatory and/or inappropriate conduct.

8. Likewise, conduct against sexual freedom and moral integrity at work shall not be tolerated, in particular sexual harassment and harassment on the grounds of sex.

9. All persons shall make all possible efforts to comply with the responsibilities assigned to them. Continued and voluntary reduction in performance at work shall not be tolerated.

10. Acts of indiscipline, understood as the conscious and wilful failure to comply with the obligations of the contract, as well as acts of direct disobedience of orders given by line managers related to their functions and tasks in the company, shall not be tolerated.

11. Employees must not work under the influence of substances that may affect their organism, preventing them from carrying out their tasks in the correct manner and compromising their safety. Likewise, the consumption of alcohol is not allowed during working hours.

12. Smoking and eating is not permitted, except in the specifically designated areas.

13. Employees who are unable to attend work for any reason must inform their line manager immediately. The reason for this absence must be later justified by means of an official document. Furthermore, any instances of tardiness must be immediately reported to the line manager, specifying the cause.

14. Uniforms must not be worn for any other activities other than those corresponding to carrying out tasks at TIRME.

15. TIRME employees must at all times take due care of the infrastructures and equipment used whilst carrying out their work on the company premises, as well as maintaining proper order and cleanliness.

16. Measures shall be taken to ensure the responsible and efficient use of natural resources, adopting a preventive approach to environmental issues and avoiding all actions that may damage or harm the environment, complying at all times with the environmental legislation in force.

17. All staff must take responsibility for their own actions to the best of their ability in order to ensure that occupational safety objectives are met. All members of the organisation are responsible for safeguarding the integrity of others and for maintaining a safe working environment. It is forbidden to carry out, provoke or collaborate in any behaviour, which individually or collectively could endanger employees’ personal integrity and/or that of their fellow workers. All members of staff must report any situations of danger to their line manager, as well as the possible inefficiency or unsuitability of individual or collective personal protective equipment that guarantees occupational safety.

18. Employees many only negotiate agreements on behalf of the company when they have been expressly authorised to do so. Contracts and agreements may only be formalised in accordance with the models or clauses authorised by TIRME.

19. Employees shall abstain from using any types of material in their work that have not been previously authorised by the owners thereof and that may imply a breach of industrial and intellectual property rights.

Employees shall use the company’s industrial and intellectual property rights solely for the purpose of their activity.

20. No member of the organisation, when carrying out their duties and/or acting on behalf of the organisation, may misrepresent or omit relevant information in their dealings with third parties.

21. Each person is responsible for the information generated and handled in relation to the functions associated with their position and shall always act in accordance with the principle of confidentiality, which must be maintained and abided by even when their professional relationship with TIRME comes to an end. In particular, they must safeguard personal or family data, including their own and those of all other persons that have professional dealings with the company. It is strictly forbidden to use such data for any other purpose than that associated with their position and/or the pre-established objectives.

22. TIRME employees must make prudent use of the company’s assets and ensure that they are not lost or damaged. Likewise, they must undertake to ensure the confidentiality, integrity and availability of company information.

23. IT facilities and/or electronic devices that are the property of the company (Internet, e-mail, telephone, photocopier, etc.) must be used solely for company activities. They may not be used for non-business purposes, illicit purposes, purposes that may damage the image or interests (of the company, the service, the staff or third parties) or that may affect the correct functioning of IT resources. All TIRME personnel are required to use these resources in a responsible, professional, ethical and legal manner. Controls are in place to monitor their correct use.

24. It is forbidden to access third party applications or IT hardware without prior documented authorisation from said parties.

25. No person may disseminate information or make copies of company software or documents for their personal use or that of other persons.

26. Accepting any type of gifts, invitations, favours or other forms of compensation from customers or suppliers is considered a breach of professional ethics, unless they are mere courtesy gifts of token value.

27. It is forbidden for any employee to make payments or offer unjustified gifts or benefits, which could be considered improper, disproportionate or illegal in accordance with regulations, to any person or entity, public or private. Initiatives in the context of social action (donations, specific contributions and/or sponsorships) must comply with the guidelines set out in Social Action procedure PR00-AD-06 Social Action. Any doubts regarding this policy should be addressed to our ethics channel.

28. Likewise, it is forbidden to use friendship or kinship with public officers to obtain favourable treatment, whereby they act or fail to act in a breach of the law, causing them to abuse or misuse their position, improperly obtaining or retaining business, or securing an undue advantage (e.g. granting of a licence, relevant information on tenders or bids, fixing favourable prices, etc.).

29. Corporate gifts may be given that have received prior authorisation from designated staff members, for the purpose of raising TIRME’s brand image.

30. All due efforts must be made to prevent any conflict of personal or family interests with those of TIRME. Should such conflicts arise, they must be reported to Criminal Compliance via the ethics channel.

31. All necessary due diligence measures must be applied prior to establishing any commercial relationships. Employees shall abstain from engaging with customers, advisors and business partners in the event of doubts regarding the lawful conduct of their business or the lawful origin of their financial assets. Likewise, they shall cooperate actively with the competent authorities in the prevention of money laundering and financing of terrorism.

32. Professional conduct is urged at all times, complying with the obligations acquired and guaranteeing the payment of debts to suppliers and all other third parties. It is forbidden to dispose of, transfer or conceal any property owned by the company for the purpose of evading compliance with its liabilities to creditors.

33. All company staff must comply with the measures stipulated in the Criminal Risk Prevention Manual, cooperating with their line managers and collaborators in order to ensure the correct compliance therewith.

34. All members of the company are required to report any suspicion or evidence of a crime committed by fellow workers or third person and also to comply with this code. To this end, a direct and confidential channel has been set up with the Compliance Officer via the email address at canaletico@tirme.com, which has been activated for this purpose.

35. Any company employee who misleads, obstructs or fails to cooperate with investigations into possible breaches of this Code of Ethics shall be subject to disciplinary action.

36. The Compliance Body, which is responsible for drawing up this Code of Ethics, reserves the right to issue any regulations of implementation that may be necessary for the development of its provisions and undertakes to ensure that it is constantly updated, adapting it to the social and legal situation at any given time.

Matters to be reported via the Ethics Channel

All persons are required to:

report in good faith and on the basis of reasonable grounds, all those circumstances that may imply the existence of a criminal risk for the organisation, as well as breaches or weaknesses of the compliance management system.

report any suspicion or evidence of a crime committed by a fellow worker or third person and to comply with the terms and conditions of this code.

disclose any behaviour or criminal action or that may contravene the legislation in force or Tirme S.A.’s corporate principles.

Communication procedure

For this purpose, there is a direct, confidential and anonymous communication channel (if you choose to do so) with the Compliance Officer and the legal advisor (managers).

You can access the TIRME Ethical Channel through the following link, through which you will access the report form

This account is accessible both on the TIRME intranet and on the website, in the latter case, by accessing the link that you will find in the "Help you" section of the "Access to the ethical channel" section.

At the time you make a complaint, you will be assigned keys to which only you will have access, being your responsibility to protect the secrecy of these and remember them.

The minimum information to be provided via the channel is as follows:

Whistleblower’s identity (full name, ID No., (Foreigner Identification Number (NIE) or Passport number), email address and telephone number).

Date and place the incident occurred.

Brief description of the query or incident reported. Identity of the offender/person reported (if applicable).

Where appropriate, documentation to support the report/ investigation that may follow

Processing of reports

Reception and assessment

Once the communication received by the managers has been recorded, they must resolve the query or determine whether an investigation is required within a maximum of 7 days. The complainant must be informed within a maximum period of 7 days of the response to the query made or the decision adopted regarding the complaint made.

Opening of proceedings

Should proceedings be opened, either ex officio or at the request of the interested party, all the organisation’s mechanisms shall be set in motion in order to clarify the facts, and all employees are obliged to collaborate with the managers, whenever so required.

Investigation procedure

The managers, together with the Support Unit where necessary, will be the bodies in charge of the investigation, being able to outsource part of it when the facts require it, always complying with a series of basic principles such as the duty of confidentiality, security and anonymity (where appropriate).

In accordance with current legislation and with the aim that the investigation does not take longer than strictly necessary, the manager within a maximum period of 3 months must resolve the investigation procedure.

During the course of the procedure, the persons under investigation are offered all the guarantees and rights established by law.

Hearing of the accused

TIRME guarantees at all times the rights of the accused persons to defend themselves from any accusation that is directed against them with the maximum legal guarantees. The accused will have a period of 10 working days, counting from the moment the Compliance Officer informs him of his status as denounced, to make allegations and provide any exculpatory evidence he deems appropriate.

Procedure for the adoption of measures

If, as a result of the investigation, the reality of the facts denounced is proven and the person responsible for them can be determined, the appropriate measures will be adopted with respect to the denounced.

However, if as a result of the investigation the veracity of the facts is proven, but it is not possible to determine who is responsible for them, the Compliance Officer will inform the Department / Management affected of this circumstance, proceeding to the registration and filing of the file.

The complainant will incur in the commission of a serious labor violation if in the result of the investigation it is proven that the complainant, knowingly, has informed the Compliance Officer false, misleading facts and / or has acted in bad faith.

Time limits and conservation of documents

There will be a record book of the infractions received and the internal investigations that have given rise within the platform used as an internal information system, guaranteeing the confidentiality requirements provided for in this law. Personal data relating to the information received and internal investigations will only be kept for the period that is necessary and proportionate for the purposes of complying with this law, being strictly prohibited the conservation of data for a period exceeding ten years.

Whistleblowers’ guarantees

All those who transmit their notifications will have the following guarantees:

• Data processing in accordance with the GDPR;

• Identity protected with maximum confidentiality, security and anonymity (if applicable);

• Use of the information provided in a complaint only for the legitimate purposes in relation to the investigation that will be initiated;

• Prohibition of acts constituting retaliation, including threats of retaliation and attempts at retaliation against persons who submit a communication under the provisions of this law, for a period of 2 years. After the expiry of the two-year period, a person whose rights have been infringed by reason of their communication or disclosure may apply for protection from the competent authority.

• Persons who report or disclose breaches will be able to access the relevant support measures independently of legal aid.

Notwithstanding the foregoing, the data of the person who informs and the rest of the participants may be communicated to the courts or tribunals, the Public Prosecutor's Office, the State Security Forces and Bodies and the rest of the competent authorities when necessary for the processing of judicial proceedings that, where appropriate, they proceed as a result of the investigations carried out on the occasion of the communications made. In the same way, when the financial interests of the European Union are affected, the European Public Prosecutor's Office must be informed.

-The infringement of this code will entail the adoption of disciplinary measures regulated in the TIRME Collective Agreement in force - Disciplinary Regime.

-This mandatory code can also be obtained through the intranet. www.tirme.net and the website www.tirme.com