1. Definition, Purpose, and Objectives of the Code of Ethics of FABRIENVAF NUCA S.L.
The Code of Ethics is an internal document designed to set out the principles, criteria, and standards of conduct that must guide all administrators, executives, and employees of FABRIENVAF NUCA, S.L. in the performance of their professional duties. It serves as a fundamental pillar of the company’s Compliance Program and Criminal Risk Prevention Manual, promoting and reflecting a positive corporate culture.
Purpose
The purpose of this Code is to guide the behavior of the company and all its administrators, executives, employees, and collaborators, in order to ensure ethical and responsible professional conduct in their day-to-day activities. It also reflects the company’s commitment to the principles of business ethics and transparency.
Expected Outcomes
The implementation of this Code aims to:
- Provide consistency and coherence to the company’s self-regulatory system.
- Strengthen the sense of belonging among employees, shareholders, clients, suppliers, and users.
- Contribute to the improvement of professional performance in compliance with current legislation, ethical principles, and social responsibility, while reinforcing the company’s image of efficiency and competitiveness (striving for excellence).
The Code of Ethics is binding and contains enforceable provisions such as the whistleblower channel and the assignment of responsibilities. Its binding nature entails obligations, and therefore, violations of this Code or the policies derived from it may result in corresponding penalties, including disciplinary action.
Acting in accordance with the principles of this Code represents the clearest and strongest guarantee of the company’s commitment to value creation for the communities in which FABRIENVAF NUCA, S.L. operates, as well as for its shareholders.
The Code acknowledges the principle of criminal liability of legal persons and serves as the foundation to prevent irregular or unlawful conduct that could result in criminal liability for the organization. It also reflects the company’s due diligence approach to preventing and eradicating misconduct and noncompliance with both this Code and any applicable legal or internal norms.
Such diligence is implemented through procedures established in the Criminal Risk Prevention Manual, which include regular oversight of the risks covered in this Code by the Compliance Committee, ensuring its dissemination and awareness, defining responsibilities, and enabling confidential reporting of irregularities through the whistleblower channel and proper resolution mechanisms.
It is important to note that the behavioral criteria set out in this Code are not intended to address every possible situation or circumstance that employees, managers, administrators, or collaborators may encounter. Rather, the Code provides general conduct guidelines to help orient their professional behavior.
This Code of Ethics was approved by the Board of Directors of FABRIENVAF NUCA, S.L. on November 26, 2019.
2. Scope and Intended Audience.
This Code of Ethics applies to FABRIENVAF NUCA, S.L. and is binding on all its personnel, regardless of their position or function. It governs the daily conduct of employees, executives, and administrators in their interactions with one another, as well as with clients, suppliers, collaborators, and both public and private institutions and partners. The aim is to foster ethical and responsible management in the development of all company activities.
Special emphasis is placed on those employees, executives, or administrators of FABRIENVAF NUCA, S.L. who manage or lead teams. These individuals must ensure that the professionals under their supervision are familiar with and comply with the Code of Ethics. They are expected to lead by example, becoming role models of ethical conduct.
This Code also applies to external advisors, freelancers, and temporary workers whenever they provide services for FABRIENVAF NUCA, S.L.
The Code is binding on FABRIENVAF NUCA, S.L. with regard to its employees, as the expectations expressed in this document constitute legitimate commitments that form part of the mutual obligations between the employer and employee in accordance with the principle of good faith in labor relations.
The company will promote and encourage its suppliers, clients, and external collaborators to adopt behaviors and standards of conduct consistent with those set forth in this Code. In some cases, the company may formally request that they express their commitment to the Code and its guiding principles.
This Code of Ethics is valid both in Spain and abroad, always taking into account the cultural, linguistic, social, and economic differences of the various countries in which the company may conduct business.
3. Awareness, Acceptance, and Compliance.
The Code of Ethics is mandatory for all employees, executives, administrators, and collaborators of FABRIENVAF NUCA, S.L., as well as for any third parties who voluntarily commit to its principles.
The Code will be formally communicated to all members of FABRIENVAF NUCA, S.L., who will be required to attend the training sessions organized for this purpose.
Company administrators and executives will actively participate in training programs, either by attending sessions alongside employees or by leading them, in order to demonstrate the importance of compliance. They will also ensure the dissemination of the company’s values and principles and promote adherence to the conduct guidelines contained in the Code. These individuals will act as role models in both behavior and commitment to compliance.
The Code must be explicitly accepted by all individuals to whom it applies. They must formally commit to its provisions, ensuring that the principles and values it contains govern their professional conduct.
Each member of FABRIENVAF NUCA, S.L. shall confirm that they have received and read the Code, and that they understand and accept its implications. To this end, the company will maintain a record of acknowledgments and agreements from all recipients.
No member of FABRIENVAF NUCA, S.L., regardless of rank or position, is authorized to instruct or request an employee to act in contradiction to the provisions of this Code of Ethics. Likewise, no individual may justify any misconduct based on orders from a superior or on ignorance of the Code.
For new employees, the contents of the Code may be incorporated into their employment contract through individual agreement.
The Code of Ethics forms part of the employer’s management authority and, therefore, becomes an integral part of the employee’s professional obligations. In this way, beyond the specific duties outlined in an employment contract, employees are also bound by the general principle of good faith in the workplace.
4. General Principles of Conduct and Ethical Values of Fabrienvaf Nuca, S.L.
The principles and ethical values of Fabrienvaf Nuca, S.L. form the foundation of the company’s operations and are primarily focused on:
- The engagement and commitment of shareholders.
- Quality and excellence in service to earn customer loyalty.
- The reputation and prestige that must be conveyed to suppliers and partners.
- The promotion and protection of employees.
- Full compliance with the law and regulatory bodies.
- Respect for the community and the environment.
- Transparency in all activities carried out by Fabrienvaf Nuca, S.L.
4.1. General Principles of Conduct.
4.1.1. Professional Conduct: Integrity, Ethics, Honesty, and Good Faith
The professional conduct of employees, executives, administrators, and collaborators of FABRIENVAF NUCA, S.L. must be governed by professionalism, acting diligently, responsibly, and with a focus on quality and excellence.
They must also maintain integrity, meaning loyalty, good faith, and alignment with the company’s interests, values, and principles, as reflected in this Code of Ethics.
All actions and decisions taken by any employee, executive, administrator, or collaborator must be ethical, lawful, and consistent with the company’s values, and individuals must be willing to assume the responsibilities arising from their actions.
Likewise, employees, executives, administrators, and collaborators must avoid any behavior that, even if not illegal, could damage the company’s reputation or negatively affect its interests in the eyes of the community.
4.1.2. Compliance with the Law
Employees, executives, administrators, and collaborators of FABRIENVAF NUCA, S.L. must strictly comply with all applicable laws and regulations in the locations where they operate. They must observe the provisions of this Code of Ethics, the company’s basic procedures, and the customs and best practices of the communities in which they work.
To ensure this compliance, they will receive the necessary training and information. No employee, executive, administrator, or collaborator may intentionally facilitate or participate in violations of the law by third parties, nor engage in any activity that undermines the principle of legality.
They must also fully respect all obligations and commitments entered into by FABRIENVAF NUCA, S.L. in its contractual relationships with third parties.
Moreover, the company undertakes to comply with and integrate into its internal regulations the national or international agreements and conventions relevant to its activities.
All employees must comply with the applicable laws in the countries where they operate, acting in the spirit and intent of the law and maintaining ethical behavior at all times.
4.1.3. Human and Labor Rights and Ethical Values
FABRIENVAF NUCA, S.L. reaffirms its commitment to ethical values, human rights, and labor rights as recognized by national and international legislation. In particular, it is committed to respecting freedom of association and collective bargaining.
4.1.4. Occupational Health and Safety
The company promotes the adoption of occupational health and safety policies and complies with the preventive measures established by applicable legislation. It also encourages its suppliers and collaborators to adopt and implement these standards.
For FABRIENVAF NUCA, S.L., safety is an individual responsibility and a condition of employment. Therefore, unsafe behaviors that may endanger people or facilities are not tolerated.
4.1.5. Environmental Protection
The company conducts its activities with respect for the environment, complying with all applicable environmental regulations and minimizing the environmental impact of its operations. It is committed to reducing waste and conserving natural resources.
To this end, the company has defined and implemented an Environmental Management System, which all employees, executives, administrators, and collaborators must understand and apply, always operating according to sustainability, respect, and environmental best practices.
4.1.6. Transparency and Impartiality in Decision-Making
All decisions made within FABRIENVAF NUCA, S.L. must be based on principles of transparency, objectivity, and fairness, ensuring that actions taken on behalf of the company are free from favoritism, bias, or hidden interests.
4.2.- Employees:
The employees of FABRIENVAF NUCA, S.L. are considered the company’s greatest asset and are treated as such.
4.2.1. Non-Discrimination and Equal Opportunity
FABRIENVAF NUCA, S.L. promotes a working environment free of discrimination based on race, color, nationality, age, sex, or any other personal, physical, or social condition. The company ensures equal opportunities among all professionals and encourages a corporate culture based on merit.
Particular emphasis is placed on ensuring equality between men and women in employment access, training, promotion, and working conditions.
Any form of violence, harassment—whether physical, sexual, psychological, or moral—abuse of authority, or any other behavior that creates an intimidating, hostile, or offensive environment is strictly prohibited.
4.2.2. Professional Development
The selection and promotion of employees at FABRIENVAF NUCA, S.L. are based on competencies, professional performance, and merit-based criteria defined for each role.
All employees are encouraged to actively participate in available training programs and are expected to engage in their own development, keeping their knowledge and skills up to date to contribute value to clients, partners, and the organization.
Managers and supervisors must support the professional growth of their team members, fostering their advancement within the company.
Teamwork and collaboration are viewed as key tools for both personal and professional growth.
4.2.3. Occupational Health and Safety
All employees must be familiar with and adhere to the company’s health and safety standards, and ensure not only their own safety, but also that of their colleagues, clients, suppliers, collaborators, and anyone potentially affected by their activities.
FABRIENVAF NUCA, S.L. provides the resources and training necessary for employees to carry out their duties in a safe and healthy work environment.
The company promotes and maintains a positive working atmosphere.
4.2.4. Use and Protection of Company Assets
FABRIENVAF NUCA, S.L. provides its employees with the tools and resources necessary to perform their duties and is committed to ensuring their protection and proper use.
Employees are expected to use company resources in a responsible, efficient, and appropriate manner, and solely for professional activities in the interest of the company. They are also expected to protect these assets from misuse that could harm the company’s interests.
The company retains ownership and exploitation rights over software, systems, equipment, manuals, projects, studies, reports, and other materials created, developed, or used by employees in the course of their duties or using company infrastructure.
FABRIENVAF NUCA, S.L. strictly prohibits the use of company equipment to install or use illegal software, or to access, download, or distribute unlawful or offensive content.
4.2.5. Information and Knowledge Management
FABRIENVAF NUCA, S.L. considers information and knowledge as essential assets in business management and therefore subjects them to special protection.
As truthfulness is a core value of the company, all employees are expected to communicate information truthfully and to ensure that any data entered into the company’s information systems is accurate and reliable.
All financial transactions must be clearly and precisely recorded in the appropriate systems, and all operations, revenues, and expenses must be documented and traceable.
Employees must maintain the strictest confidentiality regarding any sensitive or proprietary information accessed in the course of their professional duties.
4.2.6. Work-Life Balance
FABRIENVAF NUCA, S.L. respects the personal and family lives of its employees and will promote work-life balance programs and initiatives to help individuals better align personal responsibilities with professional commitments.
4.2.7. Right to Privacy
The company respects the right to privacy of its employees in all forms, particularly in relation to personal, medical, and financial data. Under no circumstances will personal data be processed for purposes other than those legally or contractually established.
The Compliance Committee and other relevant bodies will ensure that any employee communications made under this Code of Ethics comply with data protection laws.
FABRIENVAF NUCA, S.L. also respects employees’ personal communications via the Internet and other means of communication.
4.2.8. Corruption and Bribery – Gifts, Commissions, and Third-Party Compensation
Employees of FABRIENVAF NUCA, S.L. must not, directly or indirectly, offer, give, request, or accept unjustified advantages or benefits intended to secure present or future advantages for the company, themselves, or third parties.
In particular, employees are prohibited from offering or accepting any form of bribe or commission from individuals or entities, including public officials (domestic or foreign), corporate personnel, political parties, authorities, customers, suppliers, or business partners.
Likewise, employees must not accept personal financial compensation from customers—including loans or advances—except in the case of financial institutions that provide such services under lawful and transparent conditions.
Accordingly, the solicitation and acceptance of any form of payment, gift, or commission related to professional activities from clients, intermediaries, suppliers, or third parties is prohibited.
Exceptions may be made only when all the following conditions are met:
- The gift or courtesy has symbolic or negligible economic value.
- It is consistent with customary commercial practices or common business courtesies.
- It is not prohibited by law or by generally accepted business standards.
In the event of any doubt, the matter should be referred to the Compliance Committee for guidance.
4.2.9. Irregular Payments and Money Laundering
FABRIENVAF NUCA, S.L. has established internal policies to prevent and detect irregular payments or money laundering arising from illegal or criminal activities in the course of its operations.
These policies include specific controls over financial transactions—both incoming and outgoing—that involve unusual amounts, cash payments, bearer checks, or transactions with entities that maintain accounts in offshore jurisdictions.
All employees must remain alert to signs of questionable integrity in individuals or entities with whom the company conducts business and must promptly report any suspicious activity.
4.2.10. Corporate Image and Reputation
FABRIENVAF NUCA, S.L. considers its corporate image and reputation to be among its most valuable assets and essential to maintaining the trust of shareholders, clients, employees, suppliers, authorities, and society at large.
Every employee has the duty to uphold and protect the company’s image and reputation through professional, ethical, and responsible behavior.
The company does not finance political parties, their representatives, or candidates in any territory where it operates. Any political affiliation or participation by employees must be carried out strictly in a personal capacity, separate from their role at the company.
4.2.11. Conflict of Interest
Employees of FABRIENVAF NUCA, S.L. must avoid any situation in which personal interests conflict—or may appear to conflict—with the interests of the company.
A conflict of interest exists when an employee’s personal interest, or that of someone closely related to them, may interfere with the company’s best interests. Decisions must always be made with the company’s objectives as the top priority, and must not be influenced by personal, family, or external considerations.
Professional decisions should be based solely on objectivity, fairness, and the defense of the company’s interests, ensuring transparency and integrity in every action.
4.3 Clients.
FABRIENVAF NUCA, S.L. is committed to maintaining a strong quality culture across all its activities, as the foundation of its growth. To this end, it provides its employees, executives, and administrators with the necessary resources to pursue excellence in client service.
The company competes in the market fairly and transparently, rejecting deceptive or fraudulent practices that might result in undue advantages.
All employees, executives, and administrators must act consistently, honestly, and responsibly toward clients, with the goal of achieving the highest standards of service quality, excellence in delivery, and long-term relationships based on trust and mutual respect.
Any information or advice provided to clients must be accurate, sufficient, timely, and appropriate.
FABRIENVAF NUCA, S.L. also fosters innovation and process efficiency to better serve its clients and support their continuous growth.
4.4. Suppliers and Collaborating Companies.
FABRIENVAF NUCA, S.L. considers its suppliers and external collaborators to be essential partners in achieving its service quality objectives. The company seeks to build relationships based on mutual trust and shared benefit.
Employees, executives, and administrators involved in the selection of suppliers and collaborators are required to act with impartiality and objectivity, applying transparent and fair criteria at all times.
The company offers its contractors, suppliers, and external collaborators the opportunity to confidentially contact the Compliance Committee if they believe that any conduct by company personnel may violate the principles set forth in this Code.
Strict diligence must be exercised in the protection of confidential information obtained from suppliers. In turn, suppliers and collaborators must commit to respecting human rights and labor rights within their own organizations.
4.5.- Shareholders.
The core purpose of FABRIENVAF NUCA, S.L. is the ongoing and sustainable creation of value for its shareholders.
To that end, the company will continuously make available the necessary communication and consultation channels to ensure that shareholders receive truthful, relevant, useful, and comprehensive information regarding the company’s progress and performance.
Likewise, FABRIENVAF NUCA, S.L. guarantees that shareholders will have the opportunity to participate in decisions that pertain to them, in accordance with applicable laws and governance standards.
4.6.- Social Enviroment.
FABRIENVAF NUCA, S.L. actively contributes to the development of the communities in which it operates through both its business activities and its broader corporate social responsibility (CSR) strategy.
The company is committed to conducting its operations in a way that fosters social well-being, sustainable development, and responsible engagement with its surroundings, respecting local customs, cultures, and needs.
4.7. Whistleblower Channel.
FABRIENVAF NUCA, S.L. has established a whistleblower channel to promote compliance with legal regulations and the standards of conduct set forth in this Code of Ethics.
This channel serves as a transparent and secure mechanism for reporting behaviors that may constitute violations of the law, irregularities, or breaches of this Code.
The company guarantees the confidentiality and anonymity of all reports submitted through this channel.
Email contact: canaldedenuncias@nucamaxelmilagrito.comnsible engagement with its surroundings, respecting local customs, cultures, and needs.
5. Data Protection Policy
FABRIENVAF NUCA, S.L. complies with all current data protection legislation and is committed to respecting the right to privacy and safeguarding the personal data entrusted to it by clients, employees, executives, administrators, suppliers, external collaborators, and any other individuals.
The principles of confidentiality and responsible data handling guide all actions taken by the organization in this regard. These principles remain in force even after the termination of any relationship with FABRIENVAF NUCA, S.L.
6. Code Compliance, Monitoring, and Disciplinary Measures
The Compliance Committee is the body responsible for ensuring the enforcement and dissemination of this Code of Ethics among all personnel associated with FABRIENVAF NUCA, S.L.
This committee is tasked with receiving reports related to violations of the Code or inquiries regarding its interpretation or application.
The committee may act either on its own initiative or in response to communications from any individual subject to the Code. Its decisions shall be binding.
Violations of this Code may lead to labor-related consequences, in addition to any administrative or criminal liabilities that may arise under applicable law.
7. Publicity, Updates, and Availability of the Code of Ethics
This Code of Ethics entered into force on the date of its approval by the Board of Directors of FABRIENVAF NUCA, S.L., on November 26, 2019, and shall remain valid until formally repealed or replaced.
The Code will be reviewed annually and updated whenever significant changes occur or when the Compliance Committee identifies a need—whether on its own initiative or in response to concerns raised by any employee, executive, or administrator. Suggestions and proposals from any member of the organization will also be taken into account.
Whenever necessary, the company will reevaluate the risk of criminal offenses as referenced in the Criminal Risk Prevention Manual, and update the risk map accordingly.
The final approval of any updates or modifications to this Code will be the responsibility of the Board of Directors of FABRIENVAF NUCA, S.L.