INTRODUCTION

This document sets out the set of rules and general principles of corporate governance and professional conduct that are applicable to all the professionals who make up UNIFORMES GARYS, S.L.U. and which are valid for establishing the guiding parameters of the corporate culture of our organisation (hereinafter, the ‘Code of Conduct’).

We are a company that manufactures workwear mainly for the service sector, presenting annual catalogues that can be focused on the hotel and catering, health, school, beauty centres... We seek to work with the best suppliers of raw materials in order to, together with the excellent human team that makes up Uniformes Gary's, obtain the highest quality in all our products.

Our Code of Conduct reflects the firm commitment of our firm, to comply with the values and professional principles, which are the basis of a culture of effectiveness, efficiency and effectiveness that makes possible the performance of our activity, framed in honesty, responsibility, respect, tolerance, transparency, accountability, commitment and service.

All members of UNIFORMES GARYS, S.L.U. are responsible for complying with and enforcing this Code. It defines a set of ethical and conduct principles that guarantee a professional and transparent practice in accordance with the principles of loyalty, transparency, impartiality, compliance and sustainability of the management model.

This Code of Conduct is also complemented and perfected by the policies and other internal regulations that develop it, as well as the applicable legislation.

 

CODE OF ETHICS

 

ARTICLE 1.- MISSION, VISION AND VALUES

UNIFORMES GARYS, S.L.U. has established people, innovation and corporate responsibility as its business pillars. The reference framework for the exercise of corporate responsibility is based on the following premises:

1.1 MISSION

Our mission is to design and manufacture professional workwear, offering a great service and a wide range of products for the most demanding workers.

Our public are workers who want to be comfortable and stylish, with absolute quality, for which we use the best raw materials on the market, all with the best possible service.

1.2 VISION

Only those who are close to their customers will discover their needs. At Gary's we put all our resources, efforts and enthusiasm into making them a reality.

At Gary's we aim to be the main reference in professional fashion, both nationally and internationally, providing differentiation in design, comfort, protection and durability to all workers who wear our garments.

1.3 VALUES

The company moves towards the future preserving the values of its identity. Excellence in the workplace is the essence of Uniformes Gary's, S.L.U., through these values that drive it:

• Unconditional and continuous commitment to innovation, design and quality.
• Excellence and passion in the provision of services.
• Integrity and professionalism of its employees and suppliers.
• Closeness to our extraordinary team of people committed to the company.

 

ARTICLE 2.- STANDARDS OF BEHAVIOUR

The specific rules of behaviour with respect to each of the groups and persons with whom UNIFORMES GARYS, S.L.U. relates and which have been included in this Code of Conduct, must be inspired by and applied in accordance with the strictest compliance with the legal system, which will inform its application in all cases, and will be mainly oriented towards:

• Quality and excellence in service in order to obtain the loyalty of our clients;
• The reputation and prestige that we must transmit to our business partners;
• The promotion and protection of our employees;
• Compliance with the strictest legality;
• Respect for and commitment to the community and the environment;
• The transparency of our activities with respect to the organised markets in which we participate.

2.1 CUSTOMER RELATIONS

Honesty and professional responsibility.

Any relationship with our clients must comply with a high commitment to honesty and professional responsibility, in addition to respecting the regulations applicable to the relationship with our clients.

Therefore, the commitments acquired with clients must be respected, announcing with due notice any change, modification, alteration or variation in verbal and written agreements, promoting transparency in our organisation's relations and being upright in all professional actions with our clients.

2.2 CONTRACTS AND PROMOTIONAL ACTIVITY WITH CLIENTS

Promotional activity and contracts with customers of UNIFORMES GARYS, S.L.U. must be clear and direct, in accordance with current regulations, without resorting to elusive practices or in any way, incorrect and complete, so that our customers have all the relevant information for decision making.

UNIFORMES GARYS S.L.U. signs a specific contract, agreement or document for each commitment. This contract, agreement or document must clearly state, in line with the applicable regulations.

The relationship between UNIFORMES GARYS S.L.U. and the client must be based on transparency. This relationship can be facilitated by the initial and mutual subscription of basic guidelines that ensure the success of the project and that must be included in the contract. Joint and constructive work will be encouraged, so that both the client and the consultancy company can maximise the benefits of the collaboration. UNIFORMES GARYS, S.L.U. undertakes to keep the client informed about the evolution of the project/service entrusted, as well as all those resolutions that may be transcendental in relation to the same.

UNIFORMES GARYS S.L.U. undertakes not to use misleading or false advertising tools. The marketing activity must be carried out with the provision of all relevant information to our customers for proper decision making.

UNIFORMES GARYS,S.L.U. will not accept any work in which it does not consider itself professionally competent.

2.3 CONFIDENTIALITY AND PRIVACY

The information of our clients of a sensitive nature must be treated with absolute reserve and confidentiality, and may only be provided to its legitimate owners or under official request, always with the due legal guarantees.

Business dealings with customers must be conducted, where appropriate, in an environment that can guarantee the privacy and confidentiality of the conversations, negotiations and documentation used.

2.4 CONFLICTS OF INTEREST

Any economic, family, friendship or any other kind of relationship between our professionals and clients may alter the independence in decision making and could represent a potential risk of disloyal action due to the conflict between private interests and those of UNIFORMES GARYS, S.L.U.

In particular, a conflict of interest shall be understood to exist when the interests of the company and the personal interest of the professional of UNIFORMES GARYS, S.L.U., as defined above, or of any spouse, ascendant, spouse of the ascendant, descendant, spouse of the descendant, sibling, spouse of the sibling or companies with respect to which the professional of THE ORGANISATION is in any of the situations contemplated in article 4 of the Stock Market Act (hereinafter, ‘related persons’) collide, directly or indirectly. Therefore, behaviour that compromises the independence of UNIFORMES GARYS, S.L.U. or its clients in decision-making must not be accepted in general.

2.5 GIFTS, PRESENTS AND FAVOURS

UNIFORMES GARYS, S.L.U. shall not give or accept any type of gift or present that may be interpreted as exceeding normal commercial or courtesy practices. In particular, any form of gifts, presents or favours to clients that may influence the independence in decision-making by the latter, or that may induce them to guarantee any type of favour to UNIFORMES GARYS, S.L.U. or its employees and directors, is forbidden.

2.6 COMPLAINT HANDLING

Any complaint will be welcomed by our organisation, because it will help us to find the direction that leads to excellence and professionalism in our service and our products.

Therefore, the professionals at UNIFORMES GARYS, S.L.U. undertake to attend to, respond to, channel and, where appropriate, resolve any claim or complaint from our customers.

2.7 BUSINESS OPPORTUNITIES

No professional of UNIFORMES GARYS, S.L.U. may use the name of UNIFORMES GARYS, S.L.U. or invoke their professional category to carry out operations on their own behalf or on behalf of related persons. In the same way he/she may not carry out, for his/her own benefit or that of related persons, investments or any operations linked to the assets of UNIFORMES GARYS, S.L.U., of which he/she has had knowledge during his/her professional activity, when the investment or operation has been offered to UNIFORMES GARYS, S.L.U. or he/she has an interest in it.

2.8 RELATIONSHIP WITH OTHER COMPANIES

UNIFORMES GARYS, S.L.U. must maintain reciprocal loyalty, mutual professional respect and relations of companionship, refraining from discrediting colleagues, competing companies and the profession in general. It must also disseminate an honest image with a sense of professionalism and transparency.

UNIFORMES GARYS, S.L.U. respects free competition and demonstrates a legal and cordial attitude towards its competitors. It is forbidden to damage, directly or indirectly, the professional reputation of another consultant, either in front of your own company or in front of a third party company.

When projects or services initiated (or carried out to date) by another company or professional in the sector are to be transferred or continued, this shall be done with professional rigour and objectivity. All available information must be provided to said company, respecting professional secrecy and the rules relating to intellectual property and data protection, and collaborating as necessary to guarantee the continuity of the service to the client, with the latter always maintaining the utmost respect for the previous consultancy company.

ARTICLE 3.- HUMAN RESOURCES

3.1. STAFF RECRUITMENT AND PROFESSIONAL PROMOTION

UNIFORMES GARYS, S.L.U. avoids any form of discrimination with respect to its own employees. In the management and development of people, as well as in the selection and professional promotion phase, the decisions taken are based on the adequacy of the expected profiles, the profiles of the professionals and on considerations linked to merit.

Access to functions and positions is also established on the basis of competencies and skills; in addition, wherever compatible with overall work efficiency, flexible work organisation is encouraged to facilitate the reconciliation of work and family life.

3.2 TRAINING

UNIFORMES GARYS, S.L.U. makes training tools available to all employees with the aim of assessing their specific skills and developing their professional value.

Training responds to the objectively established needs of the organisation and takes into account the professional development of people.

3.3 GENDER EQUALITY

The professionals of UNIFORMES GARYS, S.L.U. shall respect the right to equal treatment and opportunities between women and men. In general, they will actively promote the absence of any direct or indirect discrimination based on sex, and the defence and effective application of the principle of equality between men and women in the workplace, making progress in the establishment of measures that favour the reconciliation of work and family life.

The principle of equal treatment and opportunities between women and men shall be guaranteed, both in access to employment and in professional training, professional promotion and working conditions.

UNIFORMES GARYS, S.L.U. shall adopt the appropriate measures and decisions in the event of any action that constitutes or causes discrimination on the grounds of sex.

3.4 OCCUPATIONAL HEALTH AND SAFETY

UNIFORMES GARYS, S.L.U. declares its firm commitment to maintain and develop the Risk Prevention system in place, taking the protection of workers as its main objective and promoting the integration of Prevention at all levels of the Organisation.

It will adopt the necessary measures to eliminate or reduce occupational risks, guaranteeing compliance with legal requirements, promoting the consultation and participation of workers, and raising awareness and sensitising all employees to the prevention of occupational risks.

3.5 MORAL INTEGRITY

UNIFORMES GARYS, S.L.U. undertakes to protect the moral integrity of its professionals, guaranteeing the right to working conditions that respect the dignity of the person. For this reason, it protects workers against acts of psychological violence and against any attitude or behaviour that is discriminatory or harmful to the person, their convictions or preferences.

The necessary measures will be adopted to prevent and, where appropriate, correct sexual harassment, mobbing and any other form of violence or discrimination, avoiding all UNIFORMES GARYS, S.L.U. employees from behaving or speaking in a way that may damage personal sensitivity.

ARTICLE 4.- RELATIONS WITH PUBLIC BODIES

4.1 LEGALITY AND INTEGRITY IN OUR RELATIONS WITH PUBLIC BODIES

We relate to administrations, public institutions and other authorities in a lawful, ethical and respectful manner, in line with international provisions for the prevention of corruption and bribery. Likewise, as employees or collaborators of UNIFORMES GARYS,S.L.U., we may not offer, promise, grant, request, receive or accept, directly or indirectly, gifts, presents or handouts, benefits, advantages, favours or compensation, in cash or in kind, whatever their nature, or from any type of authority or official that may give UNIFORMES GARYS,S.L.U. a privileged situation or a competitive advantage over third parties. At UNIFORMES GARYS,S.L.U. we comply with our tax and Social Security obligations. We also ensure that the aid requested or received from public administrations is used appropriately and that their application is transparent, thus avoiding falsifying the conditions for obtaining them or using them for purposes other than those for which they were granted. We undertake to collaborate with the public administrations in any inspection procedure to which the company may be subject.

4.2. POLITICAL PARTIES

UNIFORMES GARYS, S.L.U. will abstain from carrying out any prohibited activity in relation to the financing of political parties or sponsorship of events whose sole purpose is political activity. UNIFORMES GARYS, S.L.U. shall likewise refrain from carrying out any type of direct or indirect lobbying of a political nature.

4.3 COMPETITION LAW AND REGULATORY BODIES

UNIFORMES GARYS, S.L.U. complies and undertakes to comply with any local, national or international competition law regulations and will collaborate with the authorities that regulate the market.

ARTICLE 5.- RELATIONSHIP WITH SUPPLIERS

We relate to our suppliers - both product manufacturers and other suppliers of goods and services - in a lawful, ethical and respectful manner, and we work closely with them to ensure their correct compliance with this code and the UNIFORMES GARYS,S.L.U. Supplier Code of Conduct, to which they are subject. The selection of our suppliers is governed by criteria of objectivity and transparency, reconciling our interest in obtaining the best conditions with the convenience of maintaining stable relationships with ethical and responsible suppliers. In this selection, we pay special attention to the standards and processes of approval, tendering, inspection and verification that our suppliers are obliged to comply with. We strive to ensure that all suppliers working with UNIFORMES GARYS, S.L.U. undertake to respect the human and labour rights of all their contracted employees, as well as to involve and transmit these principles to their business partners. All relations with suppliers are formalised by means of the corresponding collaboration agreements and contracts with UNIFORMES GARY`S, S.L.U.

ARTICLE 6.- INTELLECTUAL PROPERTY PROTECTION

At GARYS we are committed to respecting, protecting and defending our own and others' industrial and intellectual property. This includes distinctive signs, such as trademarks, trade names, industrial designs, copyrights, domain names, utility models, inventions and computer programs, among others.

We are responsible for the originality of our own designs and ensure that our suppliers guarantee the originality of the designs they make available to us. To this end, we take the necessary measures and controls to ensure the lawful use of these rights. Within the framework of our marketing and advertising campaigns, we use only those brands, distinctive signs, images, graphics, texts, illustrations and any other material duly authorised by the Communication and Marketing Department, in accordance with internal rules and procedures and the principles of this code.

ARTICLE 7.- QUALITY

The main objective of our Quality Policy is to determine the customer's requirements and their satisfaction in order to translate them into a continuous improvement of our products, by means of an optimal management of our human and technical resources, always oriented towards the fulfilment of the customer's needs and expectations.

For all these reasons, our Quality Policy is based on three basic pillars:

• A commitment to continuously improve the effectiveness of our quality management system.
• Achieving the satisfaction of the needs and expectations of all interested parties by continually renewing our work and management system.
• To develop and maintain a group effort, placing emphasis on increasing the capacity of UNIFORMES GARY'S,S.L.U. to increase its competitiveness in the market through quality improvement.

To this end, we are committed to:

1. Comply with the requirements specified by our customers and all interested parties and those applicable to us and, in particular, with current legislation and regulations.
2. Detect our errors, avoiding their appearance, and if they appear, solve them immediately, in order to obtain a level of excellence in our work.
3. Report any problems we detect, suggesting and implementing improvements.
4. To ensure the constant improvement of the administrative-financial system of our company.
5. Implementing technical and human resources to improve the technical and safety conditions of our workplaces.
6. Advising our customers from the company's Production Department.

IMPLEMENTATION

This Code of Conduct of UNIFORMES GARY, S.L.U. shall be applicable to all the professionals of the company, including the persons listed below:

• All management personnel.
• To all employees.
• To all interim or temporary staff providing services of any kind or work activity.

The professionals of UNIFORMES GARYS, S.L.U. must, according to their functions and responsibilities:

• Be familiar with, disseminate and comply with this Code, and formalise in writing their irrevocable commitment to comply with its provisions.
• Collaborate in the implementation of the Code and the policies and regulations that develop it.
• Attend and participate in all training sessions to which they are summoned for the proper understanding of this Code and other internal regulations that develop and complement it.
• Consult with the compliance officer/management team Responsible for any doubts that may arise regarding the content of the Code.
• Bring to the attention of the person in charge any situation that may be considered to constitute a breach of this Code and the internal regulations that develop and complement it.

Any reference to compliance with this Code shall also imply the obligation to comply with the applicable legislation and internal regulations and their professionals, even if such reference is not expressly contained in any section of this Code of Conduct.

COMPLAINTS CHANNEL

UNIFORMES GARYS,S.L.U. is responsible for establishing, for each party involved, channels for complaints through which to send the appropriate communications. These channels will ensure confidentiality in the treatment of information.

In aspects that may affect employees, such as situations of discrimination, harassment, mobbing or safety at work, among others, specific channels shall be established for the communication and treatment of any improper conduct that may occur in these areas. The compliance officer will send reports on violations of the Code of Conduct, detected following indications from those involved or following auditing activities, and any suggestions deemed necessary:

• in the most significant cases, to the Governing Body.
• in other cases, to the Management of UNIFORMES GARY'S.

No one, regardless of level or position, is authorised to request that a professional commit an illegal act or an act that contravenes the provisions of this Code of Conduct.

DISSEMINATION, TRAINING AND COMMUNICATION

9.1 The management team is responsible for disseminating and communicating the contents of this Code among the Company's professionals and other collaborators. Specifically, a copy of this Code shall be given to all the Company's professionals. Likewise, a copy of the Code will be given to professionals who join UNIFORMES GARYS in the future, when they start their activity in the Company.

9.2 Likewise, it will promote knowledge of the Code of Conduct and associated regulations through a specific training plan, in coordination with the training and Human Resources areas. In all dissemination, communication and training actions, the existence of the ethical channel for complaints and queries and the means of access established for its use shall be recalled, as well as the obligation to report any irregularities that may be detected.

SUPERVISION, EVALUATION AND UPDATING

The management team of UNIFORMES GARYS, S.L.U. is responsible for supervising the operation and effectiveness of the Company's Code of Conduct. To this end, it may rely on external advisors to verify effective compliance with this Code and the internal regulations that develop and complement it. The person in charge will be responsible for interpreting the rules contained in the Code of Conduct of UNIFORMES GARYS, S.L.U., having to harmonise its interpretation with policies, protocols and other internal regulations of the Company.