INTRODUCTION

A code of ethics is a set of guidelines that aim to establish acceptable conduct for members of a group of obligated subjects. In this sense, a code of ethics establishes the fundamental values of the organization that assumes it and projects outwards its commitment to the world around it.
Since its establishment, NUMINTEC COMUNICACIONES, SL has always been guided by a series of ethical values aimed at offering the best customer service, but without forgetting the good governance commitments that must define any Good Corporate Governance system. Now, the Company has decided to formalize these values that it has already assumed as its own through the approval by the Board of Directors of this Code of Ethics.

CHAPTER I. PURPOSE AND SCOPE OF APPLICATION

ARTICLE 1. PURPOSE

1. In accordance with the provisions of the Agreement of the Board of Directors of NUMINTEC COMUNICACIONES, SL (hereinafter, NUMINTEC or the Company) dated xx of xx, 2022, NUMINTEC intends that its conduct and that of the people linked to it be held accountable and accommodates, in addition to current legislation and its Corporate Governance System, generally accepted ethical and social responsibility principles. For this reason, it has a Code of Ethics that is part of the Company’s corporate governance system.
2. This Code of Ethics responds to NUMINTEC’s commitment to the principles of Business ethics and transparency in all areas of action, included in the Mission, Vision and Values of NUMINTEC and serves as a guide for the actions of the Society’s professionals in a global environment. , complex and changing.
3. The Code of Ethics is valid both in Spain and abroad, always taking into account the cultural, social and economic differences of the various countries in which NUMINTEC may operate.
4. This Code of Ethics responds to NUMINTEC’s commitment to the principles of business ethics and transparency in all areas of action, included in the Mission, Vision and Values of NUMINTEC and serves as a guide for the actions of the Society’s professionals in a global environment, complex and changing.
5. This Code of Ethics responds to NUMINTEC’s commitment to the principles of business ethics and transparency in all areas of action, included in the Mission, Vision and Values of NUMINTEC and serves as a guide for the actions of the Society’s professionals in a global environment, complex and changing.
6. This Code of Ethics responds to NUMINTEC’s commitment to the principles of business ethics and transparency in all areas of action, included in the Mission, Vision and Values of NUMINTEC and serves as a guide for the actions of the Society’s professionals in a global environment, complex and changing.

ARTICLE 2. SCOPE OF APPLICATION

The principles contained in the Code of Ethics are applicable to all NUMINTEC professionals, regardless of their hierarchical level or geographical or functional location.

1. For the purposes of the Code of Ethics, NUMINTEC professionals are considered to be partners, members of the General Board, those of the Administrative body, managers and employees, as well as those other people whose activity is expressly subject to the Code of Ethics.
2. Compliance with the Code of Ethics is understood without prejudice to strict compliance with the Company’s Corporate Governance System and, in particular, the Regulatory Compliance System.
3. Such codes of ethics or conduct will be inspired by the Mission, Vision and Values of NUMINTEC and will include the principles included in the Code of Ethics.
4. In those companies and entities in which NUMINTEC, without having a majority participation, is responsible for the management, the professionals who represent NUMINTEC will promote compliance with the provisions of the Mission, Vision and Values of the Company, in the principles established in this Code of Ethics and the standards of conduct established in the Code of Conduct.
5. Those NUMINTEC professionals who, in the performance of their duties, manage or direct teams of people must also ensure that the professionals directly under their charge know and comply with the Code of Ethics and lead by example, being role models for conduct in the company. Society.
6. NUMINTEC requires that all affiliated or investee companies and main suppliers and partners adopt conduct in accordance with the general principles of this Code.

ARTICLE 3. MISSION, VISION AND VALUES

Mission
We are a global cloud communications services company focused on offering value-added solutions to our clients.

Vision
To be an innovative company and become a benchmark in cloud communications services for the company.

Values
Constant innovation
Adaptation to change
High specialization
Teamwork
Customer orientation
Professional ethics
Sustainability

CHAPTER II.- PRINCIPLES OF THE CODE OF ETHICS

SECTION 1.- FUNDAMENTAL PRINCIPLES

ARTICLE 4. COMPLIANCE WITH LEGALITY AND THE CORPORATE GOVERNANCE SYSTEM

1. NUMINTEC professionals will strictly comply with the current legislation in the place where they carry out their activity, taking into account the spirit and purpose of the regulations.
2. In addition to complying with the rules of the Corporate Governance System and the basic procedures that regulate the activity of NUMINTEC, they will observe the provisions of the Code of Ethics and the Regulatory Compliance System.
3. They will also fully respect the obligations and commitments assumed by NUMINTEC in its contractual relationships with third parties, as well as the customs and good practices of the countries in which they carry out their activity.
4. NUMINTEC managers must be particularly familiar with the laws and regulations, including internal ones, that affect their respective areas of activity and must ensure that the professionals who depend on them receive adequate information and training that allows them to understand and comply with legal obligations. and regulations applicable to their job function, including internal ones.

ARTICLE 5. ETHICAL INTEGRITY

1. The guiding criteria to which the conduct of NUMINTEC professionals will conform will be professionalism, integrity, self-control and impartiality in their actions and decisions.
2. It is the obligation of all NUMINTEC professionals to inform the Compliance Unit about the initiation, evolution and result of any judicial, criminal or administrative procedure, of a sanctioning nature, in which a professional is an investigated, accused or accused party and which may affect them. in the exercise of their functions as a NUMINTEC professional or harm the image or interests of the Company.
3. If you are informed of the initiation of a procedure of these characteristics, you will act in accordance with the Internal Investigation Regulations.

ARTICLE 6. RESPECT FOR HUMAN AND LABOR RIGHTS

1. NUMINTEC expresses its commitment and connection with human and labor rights recognized in national and international legislation and with the principles on which the United Nations Global Compact, the Standards on the responsibilities of transnational companies and other commercial companies in the sphere of human rights of the United Nations, the OECD Guidelines for Multinational Enterprises, the Tripartite Declaration of Principles on Multinational Enterprises and the Social Policy of the International Labor Organization, as well as documents or texts that may replace or complement to those previously referred to.
2. In particular, NUMINTEC expresses its total rejection of child labor and forced or compulsory labor and slavery.

ARTICLE 7. PRINCIPLES OF NON-DISCRIMINATION

1. NUMINTEC promotes non-discrimination based on race, color, nationality, social origin, age, sex, marital status, sexual orientation, ideology, political opinions, religion or any other personal, physical or social condition of its professionals, as well as equality. of opportunities between them.
2. In particular, NUMINTEC will promote equal treatment between men and women with regard to access to employment, training, promotion of professionals and working conditions, as well as access to and supply of goods and services.
3. NUMINTEC rejects any manifestation of violence, physical, sexual, psychological, moral or other harassment, abuse of authority at work and any other conduct that creates an intimidating or offensive environment for the personal rights of its professionals. Specifically, NUMINTEC will promote measures to prevent sexual harassment and harassment based on sex, when considered necessary.

SECTION 2.- RIGHTS AND OBLIGATIONS OF NUMINTEC PROFESSIONALS
ARTICLE 8. EQUAL OPPORTUNITIES

1. All employees will enjoy equal opportunities for the development of their professional career regardless of their age, sex, marital status, race, nationality and beliefs. NUMINTEC is committed to establishing an effective equal opportunity policy so that its employees develop their professional activity based on the principle of merit. Promotion decisions will always be based on objective circumstances and assessments.
2. NUMINTEC is also committed to maintaining an investment policy for the learning and personal and professional training of its employees.
3. NUMINTEC employees will respect the equal opportunities policy in their professional field and will support the personal and professional learning of their colleagues.

ARTICLE 9. RECONCILIATION OF FAMILY LIFE WITH WORK ACTIVITY

NUMINTEC respects the personal and family life of its professionals and will promote conciliation programs that facilitate the best balance between this and their work responsibilities.

ARTICLE 10. RESPECT FOR PRIVACY AND CONFIDENTIALITY OF EMPLOYEE INFORMATION

1. NUMINTEC undertakes to request and use exclusively those employee data that are necessary for the effective management of its businesses or whose documentation is required by applicable regulations.
2. NUMINTEC will take all necessary measures to preserve the confidentiality of the personal data at its disposal and to guarantee that confidentiality in their transmission, when necessary for business reasons, complies with current legislation.
3. Employees who, in the performance of their professional activity, have access to information from other employees will respect and promote the confidentiality of this information and will make responsible and professional use of it and will undertake in writing to maintain the confidentiality of this data.
4. The Compliance Officer will comply with the requirements provided for in the personal data protection legislation regarding communications sent to them by professionals or other people in the NUMINTEC environment.

ARTICLE 11. SAFETY AND HEALTH AT WORK

1. NUMINTEC will provide its employees with a safe and stable environment, keep occupational risk prevention measures up to date and will scrupulously respect the regulations applicable in this matter in all places where it carries out its business activities.
2. All employees are responsible for observing strict compliance with health and safety standards in order to protect themselves and other employees or third parties.
3. NUMINTEC will promote that the suppliers with which it operates comply with its standards and programs regarding occupational health and safety.

ARTICLE 12. GIFTS AND GIFTS

NUMINTEC professionals may not give or accept gifts or presents in the development of their professional activity. Exceptionally, the delivery and acceptance of gifts and gifts will be permitted when the following circumstances occur simultaneously:

• are of irrelevant or symbolic economic value;
• respond to signs of courtesy or usual business attention; and
• are not prohibited by law or generally accepted business practices.

ARTICLE 13. FINANCIAL CONTROL

1. NUMINTEC is committed to the fight against tax evasion, fraud and money laundering.
2. The administrative management procedures include protocols against tax evasion, fraud and money laundering, with control actions being carried out on their implementation.
3. Annually the company’s accounts are audited by an external company to give the highest degree of transparency to NUMINTEC’s actions.

ARTICLE 14. CONFLICTS OF INTEREST

1. Professional decisions must be based on the best defense of the interests of NUMINTEC, so that they are not influenced by personal or family relationships, or by any other particular interests of NUMINTEC professionals.

ARTICLE 15. FRAUDULENT PRACTICES OR MISLEADING PROMISES

1. In relations with any interest group such as clients, suppliers, public administration or society in general, no false statements or promises will be made whose fulfillment cannot be guaranteed.
2. NUMINTEC will apply a policy of zero tolerance against any practice of corruption, bribery or payment facilitation in all its active and passive forms, whether through acts or omissions or through the creation or maintenance of favorable or irregular situations.

SECTION 3.- INFORMATION PROCESSING
ARTICLE 16. INFORMATION FOR INTERNAL USE, CONFIDENTIAL AND RESERVED

Non-public information that is the property of NUMINTEC will, in general, be considered information for internal use, unless it has been classified as confidential or reserved, and in any case it will be subject to professional secrecy, without its content being provided. to third parties, unless it is in the normal exercise of their work, profession or functions and provided that those to whom the information is communicated are subject, legally or contractually, to an obligation of confidentiality and have confirmed to the Company that they have of the means necessary to safeguard it

SECTION 4.- ENVIRONMENT
ARTICLE 17. RESPECT FOR THE ENVIRONMENT

NUMINTEC has a system for identifying and ensuring compliance with current environmental legislation.
For NUMINTEC, maintaining the environmental management system is a commitment to sustainable development and environmental protection. Special attention is paid to preventing pollution and minimizing the environmental impact of the activities carried out by NUMINTEC.

SECTION 5.- RELATIONSHIPS WITH INTEREST GROUPS
ARTICLE 18. CUSTOMERS

1. NUMINTEC, applying in all cases standards of transparency, information and protection, is committed to offering a quality of services and products equal to or superior to the legally established requirements and quality standards, competing in the market and carrying out marketing and sales activities. based on the merits of its products and services.
2. NUMINTEC will guarantee the confidentiality of its clients’ data, committing to not reveal it to third parties, except with the client’s consent or due to legal obligation or in compliance with judicial or administrative resolutions.

ARTICLE 19. SUPPLIERS

1. NUMINTEC will adapt the supplier selection processes to criteria of objectivity and impartiality and will avoid any conflict of interest or favoritism in its selection.
2. NUMINTEC professionals who access personal data from suppliers must maintain the confidentiality of such data and comply with the provisions of the legislation on the protection of personal data, to the extent applicable.

ARTICLE 20. PARTNERS

NUMINTEC expresses its purpose of continuous and sustained creation of value for its partners and will permanently put at their disposal those communication and consultation channels that allow them to have adequate, useful and complete information on the evolution of the Company.

ARTICLE 21. MEDIA AND INFORMATION TRANSPARENCY

1. NUMINTEC’s communication with the areas in which it carries out its work (also through the media) is characterized by respect for the right to information.
2. Under no circumstances is it permitted to disseminate false or biased news or comments.
3. All communication activities respect laws, rules, practices of professional conduct and are carried out with clarity, transparency and timeliness, safeguarding, among others, price-sensitive information and industrial secrets.

ARTICLE 22. FAIR COMPETITION AND DEFENSE OF COMPETITION

1. NUMINTEC defends the principle of fair competition, refraining from collusive, predatory behavior and abuse of its position of power.
2. NUMINTEC, within the continuous improvement of the company’s Corporate Governance System, assumes a clear, manifest and firm commitment to compliance with antitrust regulations.
3. NUMINTEC assumes the commitment to promote regulatory compliance in relation to the defense of competition.
4. NUMINTEC assumes the commitment that the defense of competition is a cultural element integrated within the company, becoming a central element in decision-making and relationships with third parties.
5. NUMINTEC undertakes, among other measures, to carry out controls and procedures aimed at preventing and avoiding the commission of crimes related to fraud and corruption, promoting the defense of competition, this being not only a legal obligation, but, a central element of the culture of this company and its responsibility towards its clients, suppliers, and consumers in general.

ARTICLE 23. COMPANY

1. NUMINTEC expresses its firm commitment to the generally accepted principles of corporate social responsibility as an integrating framework for its programs and actions with professionals, clients, suppliers, shareholders and all interest groups with which it interacts.
2. In this sense, NUMINTEC, faithful to the business objective of generating wealth and well-being for society, adopts a responsible business ethic that allows it to harmonize the creation of value for its shareholders with sustainable development that considers as its main objectives the protection of the environment, the social cohesion, the development of a favorable framework for labor relations and constant communication with the different groups related to the Company in order to meet their needs and expectations.
3. NUMINTEC expresses its firm commitment to the principles of the Anti-Fraud and Corruption Protocol and, in particular, to not carrying out practices that may be considered irregular in the development of its relationships with clients, suppliers, competitors, authorities, etc. , including those related to money laundering. For these purposes, professionals will receive adequate training on the legislation applicable in those countries in which NUMINTEC carries out its activities.

CHAPTER III. OTHER PROVISIONS

ARTICLE 24. ACCEPTANCE

1. NUMINTEC professionals expressly accept the standards of action established in the Code of Ethics and the Code of Conduct.
2. Professionals who join or become part of NUMINTEC in the future will expressly accept the principles and standards of action established in the Code of Ethics and the Code of Conduct.
3. The Code of Ethics and the Code of Conduct will be annexed to the employment contracts of all NUMINTEC professionals, especially informing about the Disciplinary Regime.

ARTICLE 25. APPROVAL AND MODIFICATION

1. The Code of Ethics will be reviewed and updated periodically, based on the annual report of the Compliance Officer, as well as the suggestions and proposals made by NUMINTEC professionals. The Administrative Body, the Human Resources Area Management and the Compliance Unit may formulate proposals for improvement or promote the adaptation of the Code of Ethics as a whole.
2. The modification of this Code of Ethics will in all cases correspond to the Administrative body.
3. The Code of Ethics was approved at the meeting of the Company’s Board of Directors held on January 2, 2023.