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 with a long history in the solar sector.

We seek to grow and develop sustainably, conducting our operations and transactions in an honest and integrated manner and in an environment that fosters the careers of our staff. 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 at IberSun that includes a series of policies and codes, including the present Code of Ethics and Conduct (hereinafter, “the Code of Ethics and Conduct”).

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

  • Highlighting IberSun’s commitment to ethics, integrity and compliance with legislation, particularly in matters of conflict of interest, human and workers’ rights, equality, safety and health, support for the local community, the environment, data protection, information management, asset care and external communication.
  • Establish the rules of conduct that should guide Company Personnel, as well as their relations with clients, suppliers, agents, distributors and external collaborators.
  • Contribute to preventing and detecting inappropriate behaviors.
  • Provide mechanisms for reporting possible breaches.

This document is not intended to cover all possible situations that may arise in the professional arena, but rather, to establish minimum standards of conduct that should guide Company Personnel in their actions while performing their professional activities.

The commitments and guidelines of conduct included in this Code take into account that IberSun supports the guidelines of the United Nations Global Compact, implying a firm commitment to comply with the ten principles established in said Pact: protection and non-violation of basic human rights; freedom of association and the recognition of the right to collective bargaining; rejection of forced labor, compulsory labor and child labor; rejection of discrimination in employment; respect for and defense of the environment; and fight against corruption. IberSun also complies with the Universal Declaration on Human Rights and its protocols and with the international agreements of the United Nations and 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 involving Company Personnel and to comply with the applicable regulations on this matter.

Company Personnel may not to carry out personal or professional activities, nor maintain direct or indirect financial interests, hat conflict with their responsibilities with IberSun.

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

Human Rights, workers' rights and equality

Beginning with the selection process, IberSun upholds respect and equality of opportunities, always seeking promotion based on merit, competences and individual capacities, with compensation according to functions and responsibilities.

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

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

  • 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 abuse or abuse of authority, or 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 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 wage, 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 health protection and safety rules at work and ensure the safety of all persons who may be affected in performing their activities.

Safety procedures should never be compromised to give preference to compliance with operational objectives. Nor will unsafe behaviors be tolerated that may have consequences for one’s own safety or that of third parties.

Support for the local community

IberSun does business in diverse locations, and local needs and impacts are variable.

Our intention is to contribute to the improvement of the quality of life and well-being of the countries and communities where we work. Therefore, we are committed to maintaining a relationship of closeness and dialogue with them, seeking always to understand their needs and respect 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 everyone. Therefore, IberSun is guided by respect for the environment and regulatory compliance in all its actions. In accordance with the above, Company Personnel should actively work to reduce the environmental impact of their activity to achieve the greatest possible preservation of the natural environment and to be aware of and comply with 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 to carry out their activities and functions, avoid using them for other purposes and protect them against damage, loss or theft.

    The use of the Internet is provided for employment purposes and should not be used for personal use. The use of the Internet for illegal or inappropriate purposes is expressly prohibited. Likewise, special care should be taken with the use of any information obtained from the Internet if restricted by intellectual or industrial property rights legislation, in particular in relation to computer programs downloaded from the Internet. If any security incident is detected, the IT department will be contacted.

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

  • Privacy and treatment of information

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

    IberSun considers information and knowledge to be one of its main assets, hence they are subject to special protection. All the information and knowledge that is generated in the scope of the Company is property of Powwer Nova in the terms established 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.

    The following actions are prohibited, among others:

    • Providing incorrect or inaccurate information that may mislead the recipient.
    • Revealing information acquired in a confidential manner.
    • Inappropriate use of information for one’s own benefit or that of third parties and/or sharing confidential information with someone outside the Company, including family and friends, even after the conclusion of the employment relationship with IberSun.

    If due to their functions within the organization an individual is required to share information with third parties, a confidentiality agreement must be signed. In case of questions, the necessary clarifications will be requested from the Compliance Committee.

External communication

Company Personnel must take special care with regard to information transmitted abroad regarding IberSun, regardless of the channel used (press, interviews, social media, etc.).

It is prohibited 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.