Anti-Bribery Policy

"Bribery is a widespread phenomenon that raises serious social, moral, economic, and political concerns. It undermines good governance, hinders development, and distorts competition. It erodes justice, increases the cost of doing business, introduces uncertainties in commercial transactions, raises the cost of goods and services, and diminishes their quality, potentially leading to loss of life and property. It destroys trust in institutions and interferes with the proper and efficient functioning of markets."

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Our goal is to convey an unequivocal message of opposition to bribery in all its forms and to reflect IDOVEN 1903, S.L.’s commitment to complying with the UNE-ISO 37001:2016 Anti-Bribery Management Systems standards. We develop the principles outlined in our Code of Ethics and extend their application not only to all company employees but also to our business partners.

Our Core Principles of Conduct

IDOVEN 1903, S.L. rejects all forms of bribery, whether public or private, and promotes a preventive culture based on "zero tolerance" for any breach of this policy. To prevent such situations, IDOVEN 1903, S.L. commits to:

• Not tolerating, accepting, or offering any form of bribery to gain any benefit or advantage through unethical or unlawful practices.
• Not financing or showing support or any other form of backing, directly or indirectly, to any political party.
• Not using donations to conceal improper payments to authorities, public officials, or entities external to the company.
• Identifying and assessing cases where there are indications of a lack of integrity in individuals or entities with whom business is or will be conducted, ensuring that IDOVEN 1903, S.L.establishes commercial relationships only with qualified individuals and entities of good reputation and governance.
• Accurately recording all company actions, operations, and transactions in its records.
• Implementing internal training and promoting awareness on the prevention and fight against bribery to foster a corporate culture of ethics and honesty.
• Establishing specific procedures and controls to prevent, detect, and address any conduct that could constitute an act of bribery or a conflict of interest.

If employees have information, concerns, or doubts about potential irregular conduct or possible illegal acts contrary to the anti-bribery management system, they must immediately report them through IDOVEN 1903, S.L.’s Ethical Channel. Employees may also convey their concerns or questions in this area to their supervisor or IDOVEN 1903, S.L.’s Anti-Bribery Body, which will act in accordance with applicable regulations.

IDOVEN 1903, S.L. will not tolerate retaliation against individuals who, in good faith, report possible violations of this policy. Full anonymity and confidentiality guarantees will be applied, along with the corresponding legal protections for investigated persons.

Employees who violate these provisions will be subject to appropriate disciplinary measures, including, where applicable, termination of their employment or contract, as well as other possible legal actions or sanctions. Likewise, IDOVEN 1903, S.L. reserves the right to take appropriate measures regarding business partners who violate this policy.

IDOVEN 1903, S.L.’s Board of Directors approved the Anti-Bribery Policy on November 19, 2024. The Anti-Bribery Body will periodically review the content of this policy to ensure it reflects current recommendations and best practices.