1. Regulatory compliance: We consider absolute respect for the proper development of the business and the stability of society to respect the rules, whether national —regional, provincial or local— or international.
2. Equity: We believe in equal opportunities and, as a result, we offer the same opportunities for participation and collaboration in the Company to all our workers and suppliers.
3. “Tone from the top”: Company management is committed to being an example and serving as a model for workers, in everything related to regulatory compliance at all levels.

1. Customer service: All of the company's staff are highly qualified and whose customer orientation reinforces our service philosophy; our motto is always to offer a solution in a timely manner. Working with AdeA is synonymous with trust and responsibility. Confidence that projects are carried out according to a pre-established schedule and responsibility, since they are carried out with the judgment and efficiency that the client requires of us. Without a doubt, AdeA is indicative of solvency, service and quality.
2. Trust and transparency: The excellent logistics chain created with our partners and suppliers, as well as the requirement imposed on the use of materials, together with absolute confidentiality and transparency in the use of information, underpin the trust of our customers.
3. Financial Policy: Our financial management is audited annually by a company of great international prestige included in the group known as the “Big Four”, which reliably confirms that the transactions carried out, as well as the reflected financial statements respond to reality and are fully covered by current legislation. AdeA performs personalized and detailed billing by company, by business unit, cost center, departments and work area, offering each client the maximum rigor and detail of the criteria and document movements invoiced.
4. Human Resources: Human resource management is an essential chapter of AdEA's activity that must provide total legal reliability, while providing the necessary flexibility to adapt to the continuously changing requirements of our company and our clients. The management of Human Resources at AdeA is mainly developed in the field of managing people. We select our staff according to the criteria that define each department and project, always focusing on a final need, which is none other than satisfying our client. In addition, we develop a continuous training plan that helps to meet the technical requirements and capabilities required by our client, investing a large part of our effort in the definition and exhaustive compliance of the parameters of each of the projects in order to avoid possible risks in the work and professional environment of all our employees.
5. Quality Assurance: As an unavoidable requirement for the need for continuous improvement, at AdEA we have implemented an SGI (Integrated Management System) which, in addition to allowing us to have greater control over our internal processes in order to improve the immediate response with our customers, allows us to be much more scrupulous in complying with current legislation and regulations. AdeA therefore meets the requirements of the UNE-EN-ISO 9001:2015, 14001:2015 and ISO/IEC 27001:2013 Standards. Aware that quality, safety and respect for the environment must be based on the activities carried out in the different workplaces and requires collaboration and commitment on the part of all, at AdeA we participate as a single team. A global team with responsibility that starts with the individual and extends to all departments involved in the service delivery cycle. Finally, as a complement to the Quality, Environment and Safety Policy, and to achieve its development, the Management sets annual continuous improvement objectives, which are always consistent with established policies.
6. Respect: We promote respect for public institutions, clear, argumentative and harmonious dialogue, avoiding anti-social or radical personal expressions or behavior.
7. Accessibility and non-discrimination: The Company promotes the participation of all those who meet internal and institutional requirements, and discrimination based on sex, religion or ideology is absolutely prohibited.

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Following the entry into force of the reform implemented in Organic Law 10/1995, of November 23, of the Criminal Code and the enactment of Circular 1/2016 of the State Attorney General's Office, the Company intends to highlight in this document those criminal behaviors that must be avoided in any situation by its components, as they are considered a risk for the directors and employees themselves, as well as for the Company.

This statement should not lead to the conclusion that the Company will not pay attention to other crimes not included in the above-mentioned Circular 1/2016 of the State Attorney General's Office or to those others regulated in the Criminal Code or the legislation that develops it.

To this end, the Company will carry out a continuous review of this Code, the policies or the processes that will develop it in the future. In this way, an attentive and proactive attitude will be maintained aimed at monitoring and reacting to evidence of any violation of national norms or international standards that regulate aspects related to the intended crimes.

In this way, the Company wants to show its willingness, not only to comply with current national or international regulations but also with all those principles, standards and soft laws related to corporate social responsibility that may be related to the Company's activity.

1. The Company will treat employee data with the maximum guarantees, taking all necessary measures to prevent them from receiving computer attacks that may cause improper access and subsequent fraudulent use of said data. Likewise, the Company is against and prohibits the use of computer equipment for personal use, to access other equipment or to make statements that may negatively affect the privacy of third parties. The Company may use those legal mechanisms it deems appropriate to, without violating any fundamental rights of employees or managers, control the flow of data on computers owned by the Company.
2. The Company is against and does not tolerate actions that could lead to fraud. To this end, the necessary controls will be applied to prevent any employee or person related to the Company from committing fraud or fraud, bribery or corruption.
3. In line with the above, the Company formally and expressly undertakes to follow all accounting or commercial regulations in force, or that may be approved in the future, in order to avoid possible punishable insolvencies or fraud that may negatively affect third parties.
4. The Company is aware of the importance of computer equipment for the development of its activities. Therefore, the Company will ensure that the computer equipment is used for the appropriate purposes, preventing them from being used to the detriment of third parties or the Company itself.
5. The Company will take special care to ensure that during its activity, the rights of third parties relating to intellectual or industrial property are not violated. For this purpose, none of the above-mentioned subjects should appropriate or misuse duly protected marks, drawings, distinctive signs or works of any kind.
6. The Company is absolutely against the use of corruption to achieve its ends. Consequently, it prohibits its employees from paying money or giving gifts to individuals or officials who in any way, directly or indirectly, have to decide on any issue related to the Company.
7. The Company is fully committed to society. Therefore, it complies with its fiscal and tax obligations knowing that these contributions apply to different causes or needs and contribute decisively to their development. In this regard, the Company scrupulously follows the legal and administrative regulations issued for this purpose and follows, although it has no obligation, the guidelines set out in the code of good tax practices.
8. Supporting discriminatory treatment, based on race or nationality, is not compatible with the principle of non-discrimination contemplated in the Universal Declaration of Human Rights, the European Convention on Human Rights and the two International Covenants signed by Spain (International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights). Consequently, the Company aligns itself with the advances made by the European Parliament as well as the precepts contained in Directive 2000/43/EC, relating to the application of the principle of equal treatment. Therefore, the Company dedicates its greatest efforts to ensuring that workers who are employed and come from third countries can enjoy the same rights as national or European citizens with regard to wages, dismissal, security and working conditions and the right of affiliation.
9. The Company is very sensitive to the environment. For this reason, all necessary measures are taken to prevent actions that may negatively affect the ecosystem that surrounds us in the proper development of their activity.
10. As stated before, the Company is against any action that could lead to a fraudulent act and is in favor of full compliance with regulations at all levels. Therefore, neither active nor passive bribery is allowed, so no individual or official will be asked or insinuated to pay, gift or provide any service in exchange for the stoppage or activation of any administrative procedure.
11. Influence peddling is closely related to fraud and bribery. Consequently, the Company expressly prohibits taking advantage of any relationship with friends or acquaintances to access other individuals, public or private, in order to obtain or achieve economic purposes or to provide services.
12. The Company is against any type of violence or criminal act, therefore, it does not allow or collaborate in money laundering or terrorist financing and will ipso facto report any action that is discovered in connection with such criminal activities.
13. Decision-making in the Company will be carried out in a clear manner and following the policies, processes and contracting manuals established for this purpose.
    13.1. In line with the above, the Company's suppliers will be appointed or chosen following the criteria established in the corresponding purchasing manual, and a person must be appointed to carry out specific monitoring of the fulfillment of the assigned contract.
    13.2. No employee of the Company may contract with people with whom they have a relationship of kinship or friendship, unless the conditions established in the supplier hiring manual are strictly met.
    In any case, the Regulatory Compliance Committee will be notified of the existence of such a link as soon as it is known.
    No employee is allowed to be, at the same time, a supplier to the Company.
    13.3. Possible conflicts of interest between employees and the Company will be avoided, and should they occur, they must be immediately notified to the Regulatory Compliance Committee.
14. The Company promotes a work space that guarantees adequate and beneficial working conditions for employees and managers. The Company grants the greatest protection to workers' rights and will be relentless in the face of any violation of these rights, in the face of possible discrimination against workers or in the face of workplace harassment. Consequently, the Company is against expressing ideas that may undermine or damage the reputation of other employees or managers, or that may hurt the sensitivity of any of them or third parties.
15. The Company will take maximum care of any personal data in its possession in order to avoid possible disclosure or fraudulent use.

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To resolve issues or doubts related to the interpretation of this Code, to the policies or processes that are implemented and to propose those improvement measures that are considered appropriate, a Regulatory Compliance Committee will meet when necessary.

This Regulatory Compliance Committee will be appointed and will report as often as required to the Management Body. Such a report should not be understood as subordination, since it is the Company's will that the above-mentioned Committee carry out its activities with maximum independence and the least interference so that its activity obtains the desired scope.

The main obligations of the Regulatory Compliance Committee are:

1. promote knowledge and dissemination of the Code among managers, employees, customers and suppliers;
2. monitor the execution and respect of the Code by managers, employees, customers and suppliers;
3. protect managers and employees against possible pressures, threats or conflicts of interest;
4. manage the complaints channel;
5. propose the timely update of the Code;
6. follow and update established policies and processes;
7. determine the scope and number of training courses;
8. evaluate the knowledge of managers and employees of the values and principles set out in this Code, as well as of the policies and processes implemented.

The Regulatory Compliance Committee will issue immediate reports on the actions taken in relation to the modification of the policies and processes applied, as well as on the violations detected in relation to the Code or any of the applicable regulations, reporting directly to the Management Body on the reactive measures taken for this purpose.

In other cases, you will proceed to report monthly about your activity in the Management Body that is held by providing the corresponding summary report.

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All employees must comply with mandatory laws, prescriptions and internal regulations in their work environment, and must guide their actions in accordance with the values of the Company and this Code.

In a special way, the Code must be applied and complied with by the Company's Managers, who have a special obligation to transmit it by example to all their subordinates.

Failure to comply with the values and principles contained in this Code may be a cause of sanction and/or dismissal as established by the collective agreements signed, after the start, development and completion of the internal process prepared for this purpose.

In the event that there are indications that any director or employee of the Company fails to comply with any of the obligations specified in this document, they must be reported through the reporting channel provided for this purpose to the Regulatory Compliance Committee.

The complaint may be submitted in writing or personally or orally to the Regulatory Compliance Committee.
In this regard, the really important thing is to report or denounce those behaviors that violate the principles or values meant in this Code. In this way, the Company intends that behaviors contrary to laws, regulations, provisions or the Code are notified as soon as possible in order to eradicate them as quickly as possible.

For the purpose of verifying the existence of the violation of the Code, an absolutely confidential and ad hoc procedure has been established, which will be the subject of corresponding development and due publicity among managers and employees and will be processed and finalized, unless there are justified causes, within a maximum period of one month.

To ensure that the reporting channel is not used maliciously, fraudulently, or with the intention of harming third parties, the filing of false or bad faith complaints is prohibited. In this case, the disciplinary measures provided for this purpose will be adopted, with the Company keeping the possibility of initiating any civil and criminal actions.