The Code of Conduct includes the values, standards and principles that guide our ethical behavior in the development of our activity and our social commitment.

• It sets out the reference standards for the entities and people that are part of Sener, as well as clients, suppliers, collaborators and institutions we work with.
• It governs the way we act in unconventional situations. It equips us with the ability to manage a conflict of interest that needs to be resolved, or problems that put our reputation at risk, or go against our principles and values.
• It follows conduct guidelines that contribute to the development of people, integration, equal opportunities, occupational safety, environmental protection and sustainable social development.

At Sener, we understand that sustainability is not just a responsibility, but also an opportunity for society to grow. Which is why we are committed to promoting sustainable practices throughout our supply chain, which means working with our suppliers to ensure that they share our values and principles in terms of social and environmental responsibility. It is against this backdrop that we have prepared this Sener Supplier Code of Conduct, which summarises the expected behaviours and mandatory standards for this group of stakeholders.

For over 60 years, Sener has developed a corporate culture based on solid corporate values. The Compliance Policy document contains the keys to the configuration, organization and main components of the Group’s Compliance System.

It is a system designed to manage compliance with external legislation and the company’s internal standards alike. These standards are integrated into all the Group’s business and support processes.

At Sener, we are committed to preventing corruption. Each and every one of us at Sener must show exemplary ethical behavior, and this is reflected in the Sener Group’s Anti-Corruption Policy, which sets out our principle of zero tolerance when it comes to any form of corruption.

There is no place for offering, giving or accepting benefits that may be understood as bribes. Mandatory guidelines for directors, managers, executives, professionals and collaborators of the Group, in all subsidiaries and international subsidiaries.

The Gifts and Hospitality Policy establishes rules to ensure that the giving or acceptance of gifts, invitations or hospitality by our people is always done with integrity, transparency and without compromising independent judgment. It defines which behaviors are inadmissible – such as high value gifts, recurring invitations or personal benefits – and which can be considered acceptable in legitimate professional contexts, always within established limits of this policy and under criteria of reasonableness.

As part of the Compliance System, it requires reporting any inappropriate request or offer and the application of the internal controls provided, including the mechanisms for approval, registration and communication to the Ethics Line. Its application ensures that our relationships with third parties are developed ethically, impartially and in full compliance with anti-corruption regulations.

The Corporate Purchasing Policy establishes the principles that guarantee that all purchases of goods and services are made with transparency, objectivity and responsibility, promoting equal opportunities among suppliers and avoiding any conflict of interest or favorable treatment It develops the technical, economic, sustainability and risk management criteria that must be followed to ensure balanced decisions that are aligned with the interests of the Sener Group.

The Policy incorporates formal controls on documentation, traceability and continuous evaluation, as well as the obligation to comply with internal procedures and to report any non-compliance to established channels, reinforcing a culture of integrity and good governance throughout the supply chain.

This Policy defines the framework for action to prevent, detect and mitigate risks related to money laundering and terrorist financing in the Sener Group’s operations.

It establishes the obligation to know our third parties, sets up controls for collections and payments, prohibits operations with sanctioned jurisdictions or entities, and establishes procedures for identifying and reporting suspicious operations.

It integrates supervision measures, continuous training and communication obligations through the channels of the Compliance System, ensuring that our activities comply with legal requirements and international standards in the matter, thus reinforcing integrity and transparency in all our financial operations.

The Conflict of Interest Management Policy establishes guidelines for identifying, preventing and managing situations in which the personal, family, financial or professional interests of our people may interfere with their duty to act in the best interests of the Sener Group. It provides clear examples of risky situations and defines criteria for transparency, independence and abstention to ensure objective decisions.

The Policy includes recommendations for immediate communication, resolution measures, and specific controls for decision-making, including the need to use the ethics hotline in case of doubt. Its application reinforces the culture of integrity, protects the group’s reputation and ensures responsible and ethical management in all our professional relationships.

Commitment to good practices, transparency and ethics is in our DNA, as well as to ensuring that the Group’s companies and the people who work in them comply with the law and with their duties of vigilance. We strive to foresee any changes in the Criminal Code, so that we can quickly align ourselves with changes in the law.

This is the reason why we drew up our Model for the Prevention and Detection of Criminal Offenses before Organic Law 1/2015 of March 30, 2015 came into force in Spain. This law, which reforms the Criminal Code, makes it possible to hold managers and directors criminally liable in certain cases. In other words, if, due to a lack of control and vigilance, they are unable to prevent criminal offenses from being committed within the company, they may be held criminally liable

The Prevention Model is in addition to our Code of Conduct, Compliance Policy, Anti-Corruption Policy and Ethics Line as a tool to achieve a common goal: to be a model for good conduct.

The purpose of this Policy is to establish the general principles and guidelines that must govern Sener’s actions in the area of personal data management and protection to ensure compliance with the applicable laws.

This Policy guarantees all individuals who interact with Sener the right to the protection of their data, ensuring respect of the right to honour and privacy in the processing of the different types of personal data originating in different sources and for various purposes, depending on their business activity. All of the above is consistent with Sener’s Code of Conduct and corporate policies.

This regulation defines the functioning and principles of Grupo Sener’s Ethics Hotline, and will be applicable to all those communications received through the Ethics Hotline and that relate to the activities and operations of any of the companies integrated in Grupo Sener.