Code of Ethics

Table of Contents:

1. Introduction
2. Scope of Application
3. Declaration of Ethical Principles
4. CSR and Commitment to the Community and the Environment
5. Ethical Management and Compliance Committee of the Group
6. Reporting Irregularities
7. Approval and Entry into Force

1. Introduction

Grupo Deiser is comprised of the companies Deiser Desarrollo e Integración de Sistemas, S.L., Deiser Apps, S.L., and Deiser Consulting and Solutions, S.L.

Grupo Deiser aims for its conduct and that of its associated individuals to comply with and adhere to not only current legislation but also the ethical principles and values that have always characterized good corporate conduct. Thus, following the general procedures established for this purpose, we have developed this Code of Ethics that elaborates and specifies the Purpose and Values of Grupo Deiser, serving as a guide for the actions of all individuals who are part of the company, in the face of their daily work in a changing BANI and VUCA environment.

Additionally, this Code of Ethics has been developed incorporating the recommendations of good governance and accepted principles of responsibility by the Society, while respecting the principles of corporate organization.

This set of guidelines, mandatory to comply with, represents our commitment to the highest ethical standards, and it includes the rules and principles that should guide our behavior on a daily basis.

Likewise, stakeholders with whom we have a relationship must be informed of the terms of the Code of Ethics, as compliance with it is a prerequisite for entering into any business relationship.

Failure to comply with the law, this code, or any other applicable policy or procedure may result in the corresponding disciplinary action, including termination of employment, always following current legislation. To report any inappropriate conduct, anyone can inform the Group's Ethical Management and Compliance Committee of any identified risks through the Anonymous Reporting Channel established by the Company.

This Code of Ethics is approved by the Management and is available in our document management tool (Confluence -> People Space).

2. Scope of Application

This "Code of Ethics" applies to all professionals who are part of Grupo Deiser, regardless of:

• Their type of contract.
• Their geographical location.
• Their position in the organization.
• The functions or tasks they perform within the organization.

Similarly, these guidelines must be binding not only in relation to our own staff but also to partners, external personnel, suppliers, distributors, or any other company that maintains any kind of business relationship with our company or works on behalf of the organization.

Therefore, individuals who are part of Grupo Deiser must express their commitment to complying with the fundamental values, guiding principles, and conduct standards of this Code of Ethics, which will set the path for our good practices. For this reason, it is mandatory for all professionals to sign the document "Code of Ethics Delivery" provided by the company at the time of joining.

3. Declaration of Ethical Principles

Fundamental Values

Autonomy + Responsibility: We promote trust and autonomy in individuals. Thanks to this, there is a strong sense of individual responsibility. Each person owns their work, and every day we strive to improve, unafraid of making mistakes, contributing creative ideas and solutions aligned with our mission and objectives.

People + Relationships: People and our relationship with them are the foundation upon which we build our business model and work philosophy. That's why every person in Grupo Deiser strives every day to create and maintain trusting relationships with everyone around them, whether they are customers, candidates, suppliers, or staff.

Integrity + Transparency: Yes, objectives are important, but the way we achieve them is even more crucial. Doing the right thing not only makes us feel good, we believe it's the only way. The pathway to transparency is communication, which is why at Grupo Deiser, we ensure that information regarding results, objectives, and relevant decisions, whether they are successes or setbacks, reaches everyone.

Ethical Guiding Principles

Compliance with Legality: No person or organization is above the law. Therefore, in our day-to-day operations, we commit to carrying out our work in accordance with current legislation, both in Spain and in other geographical areas where we may conduct our present or future activities.

Our human team, as well as the organizations linked to Grupo Deiser, must have Zero Tolerance for any illegal practices, adopting maximum effort and commitment to compliance with current legal frameworks implicitly and explicitly, implementing all necessary mechanisms to understand and inform about the applicable rules, regulations, and obligations in each case, ensuring their compliance.

Likewise, transparency of information is a basic principle that governs our actions, always disseminating truthful and relevant information to our stakeholders. However, always safeguarding confidential information as a primary aspect of our management duties.

Commitment to Human and Labor Rights: Grupo Deiser and all individuals who are part of it or any organization with any connection to it, will have as a premise the knowledge, respect, protection, and promotion of the rights established in the United Nations Global Compact, the norms on the responsibilities of commercial enterprises in the field of human rights of the United Nations, the social policy of the International Labour Organization, as well as the documents or texts that may supplement or complement the aforementioned, avoiding benefiting from situations that may violate them in any way.

Specifically, Grupo Deiser declares its total rejection of child labor and forced or compulsory labor. Similarly, it undertakes to respect freedom of association and collective bargaining, freedom of expression, labor agreements, and the national rights of those countries where it provides its services or may carry out its activities, committing to value existing differences as an enriching element.

In particular, the prevention of occupational hazards is a cornerstone of our work, so Grupo Deiser undertakes to provide all necessary means to eliminate or reduce the risks associated with the professional performance of our human capital.

Our behavior must always stem from absolute respect and dignity towards the other members of the company, as well as stakeholders, partners, and clients.

Performance of an Integral and Quality Professional Conduct: Grupo Deiser has a well-known brand in its sector, due to a long-standing experience of 25 years, seeking to carry out each project with rigor, meeting the objectives to which we have committed, aiming for excellence and customer satisfaction.

Therefore, every person who is part of the company must maintain the prestige and good name of Grupo Deiser, ensuring its reputation.

4. CSR and Commitment to the Community and the Environment

Grupo Deiser is firmly committed to protecting and respecting the environment. This leads us to carry out our activities, always seeking to minimize negative environmental impacts, prevent pollution, and reduce energy consumption. In this way, our work is mostly conducted in a RemoteFirst mode, thus avoiding unnecessary travel and consuming less energy. Similarly, we have our own offices in a coworking space in Madrid, in order to carry out our core business in the most sustainable way possible, with shared areas, insulating windows, efficient climate control, LED lights, and always striving to properly classify waste.

Likewise, in order to have a greater impact on society, Grupo Deiser has begun to engage with the Teaming platform, in order to strengthen a bond with those organizations seeking to address social causes of various kinds.

People who are part of Grupo Deiser are expected to act proactively and actively participate in the actions carried out, showing a clear commitment to the community, especially in social action and respect for social, economic, and cultural environments.

5. Ethical Management and Compliance Committee of the Group

This committee will be composed of the individuals who hold the Head positions of each area, along with the Management (CEO). Specifically, the teams are:

• Business Development Team.
• Finance Team.
• Licenses Team.
• Marketing Team.
• People Team.
• Product Team.
• Systems Team.
• Solutions Team.
• Support Team.
• Sales Team.

Decisions will be made consensually, after prior discussion and negotiation, leading to all involved individuals understanding and agreeing with the decision. If unanimity is unattainable, after the corresponding period of debate, a decision may be made by majority.

The competencies of the Ethical Management and Compliance Committee will include:

• Promote the dissemination, knowledge, and compliance with this Code of Ethics.
• Interpret the Code of Ethics regarding the application of disciplinary measures.
• Monitor and regulate its proper application.
• Address queries or doubts that may arise regarding its content, interpretation, application, or compliance.
• Modify or update the Code of Ethics, in order to prevent possible future infractions, as well as to ensure that it remains a valid, effective, and current tool to govern our good practices.

Guidelines for Behavior to Follow

Relationship with Partners

Value Creation: Grupo Deiser will establish a relationship with partners where knowledge, skills, and experience are shared to achieve synergies that lead to mutual benefit for all parties involved.

Primary Interest: Similarly, the primordial focus will be on integrity and transparency of the provided information, with Grupo Deiser's interests as the main axis.

Relationship with Clients

Honesty and Professional Responsibility: Grupo Deiser's goal is to offer high-quality service to our clients by providing value, exceeding their expectations.

This implies, regarding each project, technical rigor and responsibility at every step, meeting proposed objectives and deadlines, as well as any other commitments made, showing dedication in our work.

Therefore, all proposals that, due to their formulation or objectives, should not be undertaken, whether due to their toxic nature, inability to achieve the expected results, or being unfeasible, will be disregarded.

All actions will be based on establishing and promoting long-lasting and transparent relationships that promote customer loyalty, thus strengthening our brand, associating it with service quality in all aspects.

Customer loyalty is a key element for Grupo Deiser, which requires effort from all company members.

Contracts and Promotional Activity with Clients: in order to achieve maximum transparency regarding contracts and promotional activity with our clients, we will ensure that all actions aimed at these purposes are clear and direct, always respecting current regulations, avoiding the use of any evasive or incorrect practices, so that our clients have all relevant information and precise data for decision-making.

Likewise, Grupo Deiser will not employ any kind of deceptive or false advertising campaign, method, or instrument.

Confidentiality and Privacy: Grupo Deiser undertakes to manage sensitive data of our clients at all times, in a completely private and confidential manner and for purely commercial purposes, adopting the necessary technical and organizational measures to guarantee data security and prevent its alteration, loss, treatment, or unauthorized access, considering the type and nature of the stored data and the risks to which they are exposed, all in compliance with the legislation on the protection of personal data. Therefore, the disclosure of confidential information and/or its use for personal purposes violates this code, without prejudice to it also being constitutive of a crime, and must report any reasonable suspicion of disclosure of confidential information through the company's "Whistleblower hotline."

In any case, the Company will inform our clients, at the time of collecting any kind of information, of the purposes and uses of the processing that will be made of their personal data.

Conflicts of Interest: individuals who are part of Grupo Deiser will always seek to act in accordance with our values, especially with integrity and transparency in their actions, informing about any possible conflict of interest to the Ethical Management and Compliance Committee, refraining from intervening in cases where a conflict may arise.

There will be considered a conflict of interest in cases where professional interest on one side, and Grupo Deiser's interest on the other, may directly or indirectly collide. There will be considered a personal professional interest when the matter in question affects oneself or an associated person, i.e.:

• The person who is the spouse or partner of the person who is part of the company, and persons up to the 2nd degree of consanguinity with both or their partners.
• Entities in which the professional or related person, by himself/herself or through an intermediary, or acting together with other persons, holds or may hold, directly or indirectly, control.
• Companies or entities in which the professional or any of the related persons, by himself or through an intermediary, holds a position of administration or management.
• Persons who have some other economic link or ties of friendship or of any other nature with someone from our human team, which may alter objectivity in decision-making.

Gifts, Presents, and Favors: the human team of Grupo Deiser may not give or accept any kind of gifts or presents in relation to their professional activity with the company. Exceptionally, these will be allowed when the gift is of a symbolic economic value, responds to an exceptional courtesy gesture in the relationship (within a possible usual commercial deference), and the gift itself is not prohibited by law or by commonly accepted business practices.

Likewise, individuals who are part of the company may not offer or grant, nor request or accept unjustified favors or gains whose ultimate objective is to obtain a benefit for the company, for themselves, or for a third party.

Nor may they receive money from clients on a personal basis, not even as a loan or advance.

In case there are reasonable doubts about the honesty of the proposal, the offer must be declined.

Complaint Management: as part of our culture of constant feedback, any complaint will be welcomed and appreciated by Grupo Deiser, as it will help us make improvements, as part of our journey towards excellence with our services and products.

Therefore, the human team of Grupo Deiser undertakes to address, respond, refer, and, if necessary, resolve, any complaint or grievance from our clients, in a timely manner and with reasoned response.

Business Opportunities: No person from the Grupo Deiser team may use the company's name to carry out operations on their own behalf or through related persons. Similarly, no person who is part of the company may, for their own benefit or for related persons, carry out, investments or other operations linked to Grupo Deiser's assets, of which they have become aware through their professional performance, when such investment or operation has been offered to Grupo Deiser or it has an interest in it.

Relationship with Suppliers andor Collaborators

Selection of Suppliers or Collaborators: The BANI/VUCA environment we face, with unexpected changes and the constant need to adapt to the vicissitudes of the environment, makes the relationship with our suppliers fundamental to the success of our value proposition. Therefore, our suppliers are seen as business collaborators.

The selection and evaluation of these collaborators will always be based on criteria of objectivity and impartiality, such as those related to cost, after-sales service, references and reputation, compliance, offered characteristics, payment terms, etc.

Relationship with Suppliers: relationships with our suppliers are configured based on strict quality control, which starts from mutual compliance and long-lasting and stable relationships.

Independence: The purchase of goods and/or services will always be made with complete decision independence, based on criteria of objectivity. Mainly attending to quality, prices, and references. Any economic, family, or other type of connection between any person should take into account what is provided in the previous section regarding the possible existence of conflicts of interest.

Gifts, Presents, and Favors: precautions should be taken to avoid this type of practice.

People Area

Hiring: Throughout the recruitment and selection processes, decisions will be based solely on the suitability of candidates in relation to the job offer in terms of merit (experience, education, languages, certifications, etc.) and competency (hard and soft skills), as well as cultural fit with the company. Once this level is reached, among the final candidates, priority will be given to those recommended by our human capital.

Based on our Remote First culture, we prioritize promoting a flexible mode where individuals can choose whether to attend in person, hybrid, or remotely, as long as it is compatible with the efficiency of the position. This aims to promote flexible work organization, allowing for work-life balance.

Training and Professional Development: Regarding professional development processes and career plans, decisions will be based on the adequacy of profiles based on personal merits.

Access to higher-level roles and responsibilities is established based on competencies and capabilities, but also based on each individual's interests. The goal is for individuals to gradually take on new tasks based on their performance and motivations, whether with a vertical or horizontal development focus, always considering organizational needs and possibilities.

Grupo Deiser also provides its human team with informative and training tools to facilitate their professional growth, always in line with strategic objectives.

Equal Opportunity and Non-Discrimination: Grupo Deiser and its human team will respect the right to equal treatment and opportunities in all actions.

Therefore, any form of discrimination, whether direct or indirect, based on sex, sexual orientation and identity, gender expression, sexual characteristics, religion, cultural aspects, or any other grounds, will be actively rejected.

Thus, the defense and effective application of the principle of equality in the workplace will be promoted, promoting the establishment of measures that favor work-life balance.

Grupo Deiser will ensure real and effective equality, without discrimination, both in access to employment and training, as well as in professional promotion and working conditions.

Equality Plan: Grupo Deiser will adopt the appropriate measures and decisions regarding any action that constitutes or causes discrimination based on sex. For this purpose, a specific Equality Plan has been created.

Right to Privacy: The company is committed to safeguarding the privacy of all its human team in all its manifestations, especially regarding personal data. Therefore, Grupo Deiser undertakes to request and use only the data necessary to carry out labor-related procedures or as required by current regulations.

Similarly, Grupo Deiser will not disclose any personal data of any member of its team without explicit consent, except in cases of legal obligation or compliance with judicial or administrative resolutions, and will treat them exclusively for the purposes provided for legally and contractually.

Safety, Occupational Health, and Digital Disconnection: Grupo Deiser advocates maintaining and developing a stable Risk Prevention system to ensure the protection of workers, promoting the integration of Prevention at all corporate levels. To this end, Grupo Deiser will adopt the necessary measures to eliminate or reduce risks, ensuring compliance with applicable legal requirements, as well as raising awareness and sensitizing all employees to risk prevention.

Likewise, in order to achieve good occupational health, Grupo Deiser will actively engage in achieving effective digital disconnection with all its staff, in order to ensure respect for legally established rest, permits, and vacations, as well as for their privacy and personal and family conciliation.

Moral Integrity: Grupo Deiser undertakes to ensure the moral integrity of its professionals, guaranteeing the right to working conditions that respect the dignity of individuals.

Therefore, it will be a priority to protect its human capital from any act of psychological violence or any discriminatory or harmful behavior towards any person. Measures will be taken to prevent or, where appropriate, correct acts of sexual harassment, mobbing, or any other form of violence or discrimination.

Protocol for Preventing LGBTI People Harassment: Grupo Deiser will adopt the necessary measures and resources to achieve real and effective equality for LGBTI people, through a protocol for addressing harassment or violence against this group.

Relationship with Public Institutions, Political Parties, and Unions

Legality and Integrity in our Relationships: Individuals who are part of Grupo Deiser will base their relationships with public bodies on the principles of legality, cooperation, and transparency, rejecting any unfair proposals or those received through improper means or forms.

Likewise, the company condemns any direct or indirect economic contribution to political parties or unions (or to any of their representatives or candidates), federations, coalitions, or electoral groups or influence groups associated with a political party; as well as to organizations, associations, or foundations associated with the aforementioned.

Gifts, Presents, and Favors: Grupo Deiser categorically rejects any form of facilitation payment, gifts, or favors, whether business-related or personal, to any of our professionals, as this may lead to situations of corruption, commission, and bribery.

Competition Law: In the development of our activity, Grupo Deiser will act in the markets in which it operates respecting legality, in good faith, and based on the principle of free competition. Thus, any action that could be susceptible to being conceived as unfair competition or that implies an abuse of dominant position will be avoided.

Likewise, regarding campaigns to be carried out, Grupo Deiser will refrain from carrying out any advertising with content that could be considered misleading or that could lead to misunderstandings regarding the characteristics of our services or products.

6. Reporting Irregularities

Employees who have reasonable suspicions of any irregularity or acts contrary to the law or the rules outlined in this Code of Ethics must report them through the Anonymous Reporting Channel provided by the Company.

This report will be evaluated based on criteria of truthfulness and moderation, and this tool cannot be used for purposes other than complying with the rules of the Code of Ethics.

The identity of the person reporting a suspected action will be considered confidential information and therefore will not be disclosed to the accused without their consent, ensuring the confidentiality of the informant's identity and avoiding any type of retaliation against them as a result of the report. Likewise, Grupo Deiser undertakes not to take any form of direct or indirect reprisal against the professional who has reported the information, although their data may be provided to administrative and/or judicial authorities, if required for a possible subsequent investigation.

The processing of reports made through the People area will be communicated directly to the group's Ethics and Compliance Management Committee. If the report affects a person who is part of the Ethics and Compliance Management Committee, they will not be allowed to participate in its processing.

During any investigation, the rights to privacy, defense, and presumption of innocence of the persons under investigation will be guaranteed.

7. Approval and Entry into Force

The management of Grupo Deiser is responsible for approving and promoting policies that promote the ethical behavior of the company, as well as compliance with this Code of Ethics, supported by the group's Ethics and Compliance Management Committee.

This Code of Ethics is currently in force and provides guidelines for daily activities, but does not cover all possible cases or situations. Therefore, the conduct of the human team must be based on the principles outlined in this code and that govern the good practices of Grupo Deiser.

It comes into force from March 8, 2024.