Code of ethics and conduct

Introduction

IberSun, S.L. and the subsidiaries under its control (jointly, the "Company" or "IberSun") is a leading company in the development of renewable energies that has a long history in the solar sector.

Our desire is to grow and develop sustainably, conducting our operations and transactions in an honest and integrated way in an environment in which our professionals develop their career. We also aspire to have the respect and recognition of the countries in which we operate.

To this end, a Compliance Program has been implemented in the Company that includes a series of policies and codes, including the present Code of Ethics and Conduct (hereinafter, the "Code of Ethics and Conduct").

The Code of Ethics and Conduct of IberSun is applicable to all administrators, managers, employees, agents, distributors, representatives, collaborators and any person who considers themselves associated with the Company (together, the "Company Personnel") and their main objectives are the following:

  • Highlighting IberSun's commitment to ethics, integrity and compliance with legislation, particularly in matters of conflict of interests, human and worker rights, equality, safety and health, support to the local community, environment, protection of data, information management, asset care and external communication.
  • Establish the behavior guidelines that should guide the Company Personnel, as well as relations with clients, suppliers, agents, distributors and external collaborators in relation to the aforementioned subjects.
  • Contribute to prevent and detect inappropriate behaviors.
  • Provide mechanisms for reporting possible breaches.

This document is not intended to cover all possible situations that may arise in the professional field, but to establish minimum standards of conduct that should guide the Company's staff in their way of acting during the development of their professional activity.

The commitments and guidelines of conduct included in this Code take into account that IberSun supports the guidelines of the United Nations Global Compact, which implies its firm commitment to comply with the ten principles established in the said Pact: protection and non-violation of fundamental human rights, freedom of affiliation and the recognition of the right to collective bargaining, rejection of forced labor, carried out under coercion and child labor, rejection of discrimination in employment, respect and defense of the environment and fight against corruption. In the same way, IberSun complies with the Universal Declaration on Human Rights and its protocols, with the International Agreements approved by said international organization and by the International Labor Organization (ILO).

Standards of Conduct

Conflicts of interest

IberSun undertakes to adopt measures to ensure impartiality in its actions, processes and decision-making, in situations of conflict of interest in which the Personnel of the Company participate and comply with the applicable regulations in the matter.

The Personnel of the Company do not to carry out personal or professional activities, nor maintain direct or indirect financial interests, which conflict with their responsibilities with IberSun.

When any situation that may generate conflict between personal interests and those of the Company may arise, prior to any decision making, a query will be raised to the Compliance Committee that will indicate how to proceed.

Human Rights, workers' rights and equality

From the selection process, IberSun is based on respect and equality of opportunities, always seeking promotion linked to merits, competences and individual capacities, with a compensation according to the functions and responsibilities.

IberSun supports and endorses the principles embodied in the Universal Declaration on Human Rights and Workers' Rights, which is why it is committed to developing a diverse workforce and providing a respectful work environment, regardless of sex, race, sexual orientation, age, disability, religion or ethnic origin of each person.

In its framework of action will not tolerate the following behaviors or attitudes among the Personnel of the Company:

  • Child labor is not tolerated, nor is forced employment in our own operations or in the operations of suppliers and collaborators.
  • Rejection of any manifestation of physical, psychological, moral or abuse of authority, as well as any other conduct that may generate an intimidating or offensive environment.
  • Promotion of equal opportunities between women and men, avoiding any discrimination.
  • Respect for the rights of freedom of association, freedom of association and collective bargaining in the workplace.
  • Promotion of respect, fair and respectful treatment of Company Personnel, ensuring decent working conditions and a salary in accordance with the applicable wage laws, including minimum wages, overtime and legally binding benefits.

Security and health

The work environment must guarantee safe conditions for all Company Personnel. All Company Personnel must know and comply with the rules of health protection and safety at work and ensure the safety of all persons who may be affected in the development of their activity.

Safety procedures should never be compromised to give preference to compliance with operational objectives. Neither will unsafe behaviors that may have consequences on one's own safety or that of third parties be tolerated.

Support to the local community

IberSun develops its business activities in diverse locations, where local needs and impacts are also very variable.

Our intention is to contribute to the improvement of the quality of life and well-being of the countries and communities with which it is related. Therefore, it is committed to maintaining a relationship of closeness and dialogue with them, trying to understand their needs and respecting their cultural integrity.

Environment

Through our business activities, IberSun participates in the fight against climate change, generating clean energy that contributes to a better future for all. Therefore, IberSun considers strategic respect for the environment and regulatory compliance in all its actions. In accordance with the above, IberSun aspires that the Personnel of the Company actively work to reduce the environmental impact of its activity to achieve the best preservation of the natural environment and that it is aware of and complies with the applicable environmental legislation.

Data protection, information management and asset care

  • Assets and electronic devices

    Company Personnel must make appropriate use of the electronic devices, equipment, facilities and resources put at their disposal for the development of activities and functions, and must not be used for other purposes and protect them from damage, loss or theft.

    The use of the Internet is of an employment nature and should not be used for personal purposes. The use of the Internet for illegal, inappropriate purposes is expressly prohibited. Likewise, special care should be taken with the use of any information obtained from the Internet, if it is restricted by the laws that protect intellectual or industrial property, in particular, in relation to computer programs downloaded from the Internet. In case of detecting any security incident, the IT department will be contacted.

    However, in those cases in which exceptionally these resources are used for personal purposes, their use must be adequate and in accordance with the principle of good faith contractual.

  • Privacy and treatment of information

    IberSun complies with current legislation on data protection and establishes the necessary mechanisms to maintain the privacy of information and the protection of data. It also manages and appropriately safeguards the documentation according to its level of relevance.

    IberSun considers information and knowledge as one of its main assets, so they are the subject of special protection. All the information and knowledge that is generated in the scope of the Company, is property of Powwer Nova in the terms referred in the current legislation. All Company Personnel must follow the instructions established for the generation, processing, filing and destruction of documentation related to their work activity.

    Among others, it is prohibited:

    • Provide incorrect or inaccurate information that may mislead the recipient.
    • Reveal the information acquired in a confidential manner.
    • Use the information inappropriately for their own benefit or that of third parties and / or share the confidential information with someone outside the Company, including family and friends, even if they conclude their employment relationship with IberSun.

    If by its functions within the organization it is required to share information with third parties, it must be ensured that a confidentiality agreement is signed. In case of doubt, the necessary clarifications will be requested to the Compliance Committee.

External communication

The Personnel of the Company must take special care with regard to the information that is transmitted abroad on IberSun, regardless of the channel used (press, interviews, social networks, etc.).

It is not allowed to issue messages or communications that damage the image and reputation of the Company. All public statements regarding IberSun must be made in accordance with established channels and approvals, and in coordination with other policies and codes.

DATE OF ADOPTION: January 2019

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