Code of ethics and compliance

1. Object

At FERSE JOYEROS we are aware of the need to attend to our social responsibilities with our collaborators, clients and suppliers. We have the firm intention of working for the excellence of our organization and its relationships with all operators in general.

Willingness to serve, proactive, efficient and effective action, focused on excellence, is the basis for everyone's professional responsibility, based on integrity and individual and corporate responsibility.

For this, we have provided ourselves with an ethical code that aims to be a guide to behavior for all those who are within the scope of our organization, in order to reflect our alignment with the culture of compliance.

We work from all ends of the organization to detect, suppress and prevent situations that are contrary to the rules, including criminal ones, presiding over our actions, an ethical and honest behavior above any other value.

2. Scope of application

Our code of ethics presides over the actions and relationships of partners, administrators, managers, employees, in general for all personnel related for one reason or another with FERSE JOYEROS.

In addition, we are committed to transferring the ethical conduct guidelines that govern our organization to all those who interact with us in one way or another.

3. Principles and Values

Always and at all times our behavior must be upright, responsible and appropriate to basic rights and strict regulatory compliance, whether we are part of FERSE JOYEROS, or all those who act in its field, especially suppliers and external collaborators.

4. Guiding principles of conduct and essential standards of behavior.

1. Respect for Human Rights

At FERSE JOYEROS we firmly believe and commit ourselves to full respect for Human Rights and public freedoms, as well as basic ethical practices, included in the Universal Declaration of Human Rights, adopted and proclaimed by the United Nations General Assembly on 10 December 1948, Convention for the Protection of Human Rights and Fundamental Freedoms (Council of Europe, Rome on November 4, 1950) and the Tripartite Declaration of the International Labor Organization (ILO).

We promise not to collaborate with third parties in the violation of any Human Rights norm, nor to participate in any action that compromises respect for the principle of legality.

2. Respect for essential standards

In our actions we promise to always comply with current legislation and adopt internal policies to avoid any breach.

In addition, we pay special attention to strict compliance with:

1. The general provisions (laws, regulations, circulars of regulatory and supervisory bodies) that regulate the activity of the organization in any country.

2. The regulations, standards, protocols and internal procedures that are implemented in the organization; and especially the present code of ethics.

3. The principles and deontological rules that are applicable to them, as well as the uses and good practices of the countries in which they carry out their activity.

4. The obligations and commitments assumed by the organization in its contractual relationships with third parties.

5. The norms contained in the Spanish penal code and in particular those that affect the legal person in accordance with its article 31 bis.

5. Basic framework of conduct.

1. Respect for the Basic Rights of People

We work to offer an environment of professional respect, mutual collaboration and the promotion of equity that governs our relationships, and for this reason we work to promote non-discrimination and non-violence among all those who are in the scope of the organization and even with third parties.

1. Respect and professional development

At FERSE JOYEROS we are committed to training as a form of professional promotion. Equal opportunities, respect for diversity and equality are pillars of our professional relationships with our collaborators.

2. Safety and health at work

We care about implementing health and safety policies at work, basic for the professional development of all members of FERSE JOYEROS.

3. Privacy

Personal data and people's privacy are one of the main concerns of FERSE JOYEROS, we follow the appropriate protocols to protect such privacy and we work daily to improve our system and train the members of our organization for their protection.

2. Respect for Heritage, property, the market and free competition.

1. General, estate, fraud, property and foreclosures.

We are committed to protecting and respecting intellectual and industrial property, and to applying policies aimed at promoting free competition and the market; to ensure the rights of consumers, to protect private property, as well as to facilitate compliance with administrative and judicial decisions.

2. The market, advertising, consumers and free competition.

We consider our suppliers and collaborators an indispensable part for the achievement of our objectives of growth and improvement of the quality of service, and excellence in our activities. Our objective is to establish relationships based on trust and mutual benefit and for this we promote compliance with the contractual conditions and obligations between the parties. Also ensuring independence in contracting, as well as truthfulness in advertising products and services. To promote ethics in our relationships, we ask our suppliers to sign this Code.

3. General interests, taxation, social security, money laundering and means of payment.

1. General interests.

At FERSE JOYEROS we are committed to society through, among others, its sustainable development, contributing to the maintenance of social status, for which we ensure the payment of our tax and social security obligations, providing the public administration with real information, both financial and fiscal, as well as that related to the field of social security. Likewise, we allocate the resources, as well as the grants to the purpose to which they were assigned.

2. Taxation and social security.

In the fight against money laundering, we have implemented strict protocols consisting of limiting payments and collections in cash, the identification of whoever contracts with FERSE JOYEROS, the accreditation of ownership of bank accounts, the assurance of the identity of the buyer-seller or supplier client as issuer or receiver of the invoice, as well as the pertinent communication to Sepblack of those suspicious operations.

4. Public Safety

1. Environment

Our commitment to the environment is the maximum expression of respect for the future of our future generations, for this reason we implement the policies and environmental management systems appropriate to our activity.

2. Public health and drug trafficking.

We care about avoiding any activity that compromises people's health in the broadest sense. We ensure that tasks are not carried out under the influence of alcohol or other legal or illegal substances that could affect the level of safety for the activity carried out.

5. Against ethics, transparency, corruption, conflicts of interest, financing of political parties, bribery and influence peddling.

1. Transparency.

It is a principle of FERSE JOYEROS to duly transmit the real image of the company, of its activities in the broadest sense. The information that FERSE JOYEROS receives by third parties, whether they are public or private individuals or legal entities, will always be complete, truthful and understandable, and in no case misleading. The manipulation, falsification or fraud in this information is absolutely prohibited.

2. Corruption and bribery, bribery and influence peddling.

Contrary to influencing the will of individuals, natural or legal, to obtain any type of benefit, through practices that deviate from business ethics, we do not give, receive, offer or accept, directly or indirectly, gifts, gifts or compensation of any kind that are prone to improperly obtaining any type of advantage or favorable or privileged conditions other than mere acts of courtesy and in any case under the supervision of the compliance officer.

3. Conflict of interest

When the interests of FERSE JOYEROS and any of those affected by this code collide directly or indirectly, whether due to professional, personal, family or any other type of interest, they will not intervene in decision-making on the matter.

6. Internal framework of conduct.

Determined to show our honesty of its internal structures and our very existence as an economic operator, we endow ourselves with an internal framework of conduct.

1. Internal conflicts of interest.

We avoid collisions of private interests with those of FERSE JOYEROS, especially if this affects decision-making. We extend the decision not to receive gifts directly or indirectly, be these in whatever format they are not considered mere courtesy.

2. Inside information and confidentiality.

Confidentiality as part of the contractual good faith in the relations of FERSE JOYEROS with its environment, supposes the maintenance of professional secrecy, of the information that is available, be it commercial, economic, strategic, use or use of operational processes, systems of work and any other internal procedure, which affects people, companies, clients-suppliers and who undertake to preserve all those who act in our field.

3. Protection of assets.

We facilitate and make good use in accordance with the laws of all the resources and means necessary for the development of the professional activities of FERSE JOYEROS and always for the benefit and in accordance with the business objective.

4. The use of the brand and image of FERSE JOYEROS.

The use of the image and brand of FERSE JOYEROS must always be done respecting the good image of the company, as well as the content of this ethical code.

5. Relations with clients and suppliers.

The dealings with the client or supplier must always be exquisite, but not ostentatious or bulky, nor will it be overbearing, nor in any way discriminatory.

The internal regulations of FERSE JOYEROS guarantee, in relation to the contracting and selection of suppliers, transparency, equal treatment and maximum objectivity, as well as regulatory compliance and subscription to this ethical code.

The extreme rigor in the treatment of personal data related to clients is one of the maximum commitments of FERSE JOYEROS, which will only be justified by legal relationships.

6. Relations with partners.

We provide the maximum information with absolute objectivity and transparency to our partners, for proper decision-making and direction. Likewise, it is from the member board itself that the organization undertakes to disseminate this code as the central axis of good practices and business ethics.

7. Acceptance, responsibilities and breaches of the ethical code.

All those affected by this code must comply with and disseminate its rules and principles; comply with the regulatory framework of laws, regulations, ordinances and rules in general that affect their specific activity; properly advise us and ask for advice regarding regulatory compliance and this code; participate in training activities; inform through the channels for the purpose of any possible regulatory breach or of the conducts contained in this Code; participate in the controls carried out to identify and correct deficiencies or failures in the detection of regulatory risks or bad practices of all kinds.

The administrative and management bodies of FERSE JOYEROS must set an example with their own behavior, of the maximum integrity and honor that is required of them as reference persons for the others affected by this code; transmit the culture of regulatory compliance and honesty in all its actions; support the knowledge of good practices, business ethics and social responsibility, as well as ensure that all persons affected by this code properly understand its content and comply with and enforce its standards and content.

Infractions, breaches, violations of the ethical code by any of those affected may lead to the imposition of sanctions with adoption, if appropriate, of the corresponding legal actions, all in accordance with the CODE OF CONDUCT AND SANCTIONING PROCEDURE of FERSE JOYEROS , all without prejudice to the criminal responsibilities that are legally enforceable.

8. Origin, validity and approval.

The Code of Ethics enters into force on the day of its publication and its validity will be indefinite, its reviews and updates will be periodic and approved by the administrative body at the proposal of the committee.