• ETHICAL
    CODE

OBJECTIVE

In response to the current regulatory environment, MONTEPINO LOGÍSTICA, S.L. (hereafter, “MONTEPINO”) has decided to create this Ethical Code to maintain and reinforce the highest ethical standards for the performance of company activity and the activity of its affiliated companies and its management company (Valfondo Gestión, S.L., hereafter the "Management Company").

This document is intended to serve as a guide and consultation document for activity performed by all administrators, directors, employees and collaborators from said companies, inspiring their daily decision-making and activities.

The Ethical Code constitutes a high-level normative instrument for the internal normative structure of the group and influences the internal policies, protocols and processes in which it features.



SCOPE OF APPLICATION

This Ethical Code, as well as the internal policies, protocols and processes it influences, applies to all MONTEPINO employees, directors and administrators, the companies to which MONTEPINO serves as a parent company and its Management Company, regardless of position and geographical location.


WHO WE ARE

MONTEPINO is the leader of a group of companies specialising in the promotion of tailor-made buildings built for the client, known as "turn-key" solutions. MONTEPINO is now the leading logistics developer in Spain.

The group primarily focuses on the promotion, acquisition and use of leases for real-estate properties for the logistics sector.


1 Compliance with the law

Legal compliance is an essential pre-requisite to this Ethical Code.

All employees and directors of MONTEPINO, its affiliated companies and its Management Company must comply with the law when carrying out their activity.

They must also respect all internal company regulations.




2 Employees and directors

Employees and directors of MONTEPINO, its affiliated companies and its Management Company shall maintain a working atmosphere conducive to the full development of all professionals. Trust, cordiality and respect for the dignity of all individuals are therefore paramount.

MONTEPINO promotes non-discrimination based on the race, colour, nationality, social background, age, gender, marital status, sexual orientation, ideology, political opinions, religion or any other personal, physical or social aspects of its professionals, as well as equal opportunities for all.

MONTEPINO promotes equal treatment towards men and women in particular, with regard to access to employment, training, professional promotions and working conditions, as well as access to and supply of the goods and services of MONTEPINO, its affiliated companies and its Management Company. One of MONTEPINO's fundamental principles consists of providing all its workers with the same opportunities with regard to access to work and professional promotions.

MONTEPINO rejects any form of violence; physical, sexual, psychological, moral or other forms of harassment; abuse of authority in the workplace and any other conduct which creates an intimidating or offensive environment for the personal rights of its professionals. Specifically, MONTEPINO promotes measures to prevent sexual harassment and gender-based harassment whenever these are considered necessary.

Employees, directors and collaborators commit to avoiding and, when necessary, reporting any form of conduct which could be considered harassment or intimidation.


3 Confidentiality
Personal information. MONTEPINO, its affiliated companies and its Management Company commit to respecting the private and confidential nature of the personal information provided by its employees within the framework of a working relationship, as well as preserving its integrity and confidentiality in accordance with the data protection regulations in force.

Personal data. MONTEPINO, its affiliated companies and its Management Company commit to not disclosing the personal data of its employees, providers or collaborators unless it has the express consent of the affected parties or the disclosure is covered by the regulations in force, such as during court or administrative injunctions. Under no circumstances may employees' personal data be processed other than for legal purposes or those established in their contract.

Confidential information. The employees of said companies who, as a result of their activities, have access to companies' confidential information, commit to keeping this information secret.

In particular, employees of MONTEPINO's Management Company and its affiliated companies are obligated to maintain all confidential or sensitive information they may have access to regarding companies or entities worked with in the past under the strictest confidence and secrecy.

These commitments remain in force following the termination of their professional relationship with MONTEPINO, its affiliated companies and/or its Management Company.

In the event of the termination of the working or professional relationship, all sensitive or confidential information shall be returned by the employee, including all storage devices this information may be stored on.

Confidential documents. Employees of MONTEPINO, its affiliated companies and its Management Company shall store confidential documents in suitable locations which guarantee that they remain confidential.

4 Suitable use of computer media
Computer media and resources. MONTEPINO, its affiliated companies and its Management Company provide its employees and collaborators the media and resources needed for the performance of their activity, as well as the mechanisms for the adequate safeguarding of the same.

The employees and collaborators of said companies commit to using all media owned by MONTEPINO, its affiliated companies and its Management Company in a responsible manner and to using them only for professional purposes.

Moreover, all employees of MONTEPINO, its affiliated companies and its Management Company shall respect the specific corporate regulations and procedures relating to resources and media.

Suitable use of computer media. There is no expectation for privacy in the use of the computer media and resources made available to employees for the fulfilment of their duties. MONTEPINO may therefore exercise its right to revise the usage and information contained in the same.

Employees of MONTEPINO, its affiliated companies and its Management Company must be aware that use of the media and resources made available to them presupposes acceptance of these terms.

Intellectual and industrial property. Employees of MONTEPINO, its affiliated companies and its Management Company must be aware that the company is the owner of the property and the intellectual or industrial property rights applicable to the programs, IT systems, equipment and other resources. Employees and collaborators therefore commit not to exploit the company's IT systems and applications, nor to use them for purposes other than those established in this Code or the relevant regulations in force.

Moreover, employees shall not install or use programs or applications on resources provided by the company which infringe intellectual property rights or any other third-party rights, or which may be susceptible to harming said resources or jeopardising MONTEPINO's interests or the interests of third parties linked to the company.




5 Accounting and invoicing

MONTEPINO and its affiliated companies guarantee the accuracy and transparency of these companies' financial information, in accordance with the accounting principles established in national and international regulations and with some of these companies receiving external accounting and tax compliance services.

Moreover, the employees and directors of MONTEPINO and its affiliated companies, and MONTEPINO's Management Company in particular, commit to respecting MONTEPINO's internal regulations with regard to invoicing, payments and reimbursements.




6 Commitment to the environment

We are committed to taking preventative, active steps to reduce the possible environmental impacts that may occur as a result of our activity and promote the following areas as our main focus points:

• Reducing our use of resources and production of emissions and waste.

• Increasing and promoting reuse and recycling.




7 Conflicts of interest

Directors, employees and collaborators of MONTEPINO, its affiliated companies and its Management Company must protect the company's interests,, as well as looking out for and promoting its positive reputation, avoiding acting against its interests.

Furthermore, the directors, employees and collaborators of said companies shall not carry out any activities or transactions in which their personal interests prevail over the interests of the company.

To avoid any possible conflicts of interests, directors, employees and collaborators of said companies who, within the framework of a certain activity or transaction, find themselves faced with a real or potential situation involving a conflict of interests, must immediately report this situation to the Compliance Officer, who shall inform them how to proceed.




8 Prevention of corruption and other irregular or unlawful conduct

The sending or acceptance of gifts is limited and those which are intended as bribery or to influence the person receiving them into making decisions which compromise their impartiality and good judgement are prohibited.

Under no circumstances is the sending of gifts, presents, personal benefits or economic compensation to public officials and employees permitted, whether national or foreign, nor to political party leaders, public service employees or candidates for these positions.



9 Compliance with the Ethical Code

Compliance with the contents of this Ethical Code is mandatory for all administrators, directors, employees and collaborators of MONTEPINO, its affiliated companies and its Management Company.

To this effect, a Compliance Officer has been appointed, whose duties include regularly verifying effective compliance with this Code.

Conduct which does not comply with the main contents of this Ethical Code, or with the other internal regulations in force in the company, may lead MONTEPINO, its affiliated companies and/or its Management Company to take the corresponding disciplinary action against their respective employees, and, if necessary, to apply the relevant penalty, in accordance with the severity of the breach and within the applicable legal framework as per the Statute for Workers' Rights and similar Agreements that apply.

To this effect, the Compliance Officer shall coordinate with the departments responsible for Human Resources duties in their respective areas to establish the actions to be taken with respect to employees of MONTEPINO, its affiliated companies and its Management Company, respecting, in all cases, the principle of proportionality and preserving the concerned party's rights of defence.

Moreover, the administrators, directors, employees and collaborators of said companies commit to identifying and reporting any inappropriate or irregular conduct to the Compliance Officer, and/or any conduct which is susceptible to infringing this Code or internal company regulations, regardless of whether these benefit or harm the companies.

To this effect, the Compliance Officer has provided a reporting channel for all directors, employees and collaborators via the following email address:

This email address is being protected from spambots. You need JavaScript enabled to view it.

Reports must not be anonymous and must contain the details of the events which have occurred. The identity of the reporter shall never be shared with the person they have reported and there shall be no repercussions of any kind for those making reports.

MONTEPINO, its affiliated companies and its Management Company commit to processing this data in the strictest compliance with legislation regarding the protection of personal data.




ANY QUESTIONS?

Remember, if you have any questions regarding the contents or application of this Ethical Code, you may get in touch with the Compliance Officer directly by sending questions to the following email address:

This email address is being protected from spambots. You need JavaScript enabled to view it.