CODE OF ETHICS AND CONDUCT OF TRANSPORTES HERMANOS CHINCHON LOPEZ S.L.

The Code of Ethics and Conduct developed by TRANSPORTES HERMANOS CHINCHON LOPEZ S.L.constitutes an express statement of the values, principles and rules that must guide the conduct of all employees and managers in the responsible performance of their professional activity in all their relations with other employees, managers, clients, suppliers and external collaborators, shareholders, public and private institutions, and society in general.

Accordingly, the purpose of this Code is to prevent the commission of criminal conduct and any unlawful behavior by the persons bound by this Code in the performance of their professional activity, establishing the monitoring and control mechanisms necessary to ensure compliance.

The standards of conduct set out in this Code are not intended to cover every possible situation or circumstance that employees of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. may encounter, but rather to establish general guidelines of conduct to guide them in the way they act in the performance of their professional duties.

All employees of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. may and should consult their line manager or the Compliance Unit regarding any doubts about the interpretation of the conduct guidelines contained in this Code or through the Consultation and Reporting Line, without prejudice to the dissemination, communication and training activities carried out for employees.

At TRANSPORTES HERMANOS CHINCHON LOPEZ S.L., no employee shall be subject to discrimination. Any form of physical, sexual, psychological or verbal harassment or abuse of employees is prohibited, as is any conduct that creates an intimidating or offensive environment.

Scope of Application and Values

Compliance with this standard is mandatory for all directors, managers and employees (and therefore for all companies in the group, if any), regardless of the type of contract governing their employment relationship, the position they hold, or the place where they perform their work, as well as for all persons who have been temporarily transferred to TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. to provide professional services.

Likewise, this Code shall apply to third parties who regularly maintain relations with TRANSPORTES HERMANOS CHINCHON LOPEZ S.L., including, among others, suppliers, collaborators and agents.

This Code of Ethics and Conduct shall be valid in all national and international markets where TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. carries out or intends to carry out commercial activities. It shall apply both in Spain and abroad, always taking into account the legal, cultural, social and economic differences of the various countries.

When establishing business relations with other companies or professionals, one of the selection criteria shall be whether they have adopted principles of conduct and management similar to those set out in this Code.

This Code of Conduct is the basis and foundation of the Organization and Management Model and the Criminal Risk Prevention Program, as well as its implementing rules.

Employees breach their duty of loyalty to the company if they engage in conduct that may violate the rules and standards set out herein. No employee shall be obliged to comply with orders or instructions contrary to the law or this Code. Should such a situation arise, the employee may contact the Regulatory Compliance Unit through any of the channels provided.

When irregular conduct is detected as a result of the normal exercise of the control, prevention or internal audit functions of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L., the person who detects or becomes aware of such irregular conduct shall report it to the Regulatory Compliance Unit through any of the means available at the relevant time.

Employees are required to participate in the mandatory training and update courses on the knowledge and application of the Organization and Management Model and the Criminal Risk Prevention Program organized by the Regulatory Compliance Unit.

General Values:

  • Respect for legality, human rights and ethical values.

  • Respect for people: avoiding harassment, intimidation, abuse and disrespect.

  • Equal opportunities, professional development and non-discrimination.

  • Team spirit: trust, collaboration and loyalty.

  • Transparency and impartiality in decision-making.

  • Excellence: rigor, talent and passion.

  • Innovation: imagination, creativity and courage.

  • Adaptability: resilience, pragmatism and austerity.

  • Integrity: honesty and transparency. Ethical conduct and good faith.

Internal Conduct and Behavioral Guidelines

EQUAL OPPORTUNITIES AND NON-DISCRIMINATION

At TRANSPORTES HERMANOS CHINCHON LOPEZ S.L., we promote the professional and personal development of all our employees, ensuring equal opportunities through our policies. All employees of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. shall enjoy equal opportunities for the development of their professional careers. At TRANSPORTES HERMANOS CHINCHON LOPEZ S.L., we respect the principle of non-discrimination on the grounds of race, sex, ideology, nationality, language, religion, sexual orientation or any other personal or social condition of our employees.

RESERVED AND CONFIDENTIAL INFORMATION

At TRANSPORTES HERMANOS CHINCHON LOPEZ S.L., we consider information and knowledge to be among the main and essential assets for business management, and they must therefore be subject to special protection.

Information is one of our main assets and is essential for the management of our activities. For this reason, an information security policy has been developed with the aim of preserving its integrity, availability and confidentiality and thus minimizing the risks arising from its disclosure and misuse.

Employees shall not disclose, disseminate or use reserved and confidential information for unauthorized purposes or for purposes unrelated to the company’s interests, as this would constitute a breach of loyalty to TRANSPORTES HERMANOS CHINCHON LOPEZ S.L., except in those cases in which such disclosure is legally required or permitted. Employees must prevent any sensitive information from becoming known to competitors.

TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. complies with current data protection legislation, protecting the personal data entrusted by its clients, employees, candidates in recruitment processes and other persons. Likewise, it undertakes to request and use only such data as are necessary for the effective management of its business.

USE AND PROTECTION OF ASSETS

Each employee is responsible for the proper use and protection of the assets and resources provided by TRANSPORTES HERMANOS CHINCHON LOPEZ S.L.. These include intellectual property, facilities, equipment, machinery and the financial resources of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L.

Employees shall not use such resources for personal or non-professional purposes and/or for the performance of activities not directly related to the interests of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L., and shall also be responsible for protecting those entrusted to them in connection with their work, exercising the utmost care in their safekeeping.

The use of files or programs from external sources that may entail serious risks to the security of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. or constitute an infringement of intellectual property rights is prohibited.

TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. provides its employees with the resources necessary for the performance of their professional activity. For this reason, the use of unauthorized software and downloads or any other behavior involving the risk of introducing viruses or any other element dangerous to IT security must be avoided, for example, making unauthorized copies or improper use of external devices (USB drives, removable disks, etc.).

CONFLICT OF INTEREST

All persons and employees of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. shall serve only the interests of the company and, consequently, shall refrain from engaging in any private activity or activity of mere personal interest that could give rise to conflicts of interest. Employees must always act, in the performance of their responsibilities, with loyalty and in defense of the interests of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L.

HEALTH AND SAFETY AT WORK

TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. promotes the adoption of occupational health and safety policies and adopts preventive measures, providing a working environment that respects the health and dignity of employees, and undertakes to permanently update occupational risk prevention measures, as well as to strictly comply with the regulations applicable in this area in all places where it carries out its activities.

All employees are responsible for strictly complying with health and safety rules and may report, through the Consultation and Reporting Line, any violation or breach of measures affecting the health and safety at work of employees of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L.

Likewise, they must make responsible use of the equipment assigned to them when carrying out hazardous activities and shall share knowledge with colleagues and subordinates, promoting compliance with risk protection practices.

PERSONAL AND PROFESSIONAL DEVELOPMENT

At TRANSPORTES HERMANOS CHINCHON LOPEZ S.L., we promote and will continue to promote balance and reconciliation between employees’ personal and professional lives, recognizing the benefits that such balance brings both to the employee and to the company. For this reason, measures aimed at reconciling these two spheres are encouraged.

Conduct and Behavioral Guidelines in the Market

FAIR COMPETITION AND DEFENSE OF COMPETITION

TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. is committed to competing fairly in the market, respecting free competition for the benefit of consumers and users and always complying with current legal regulations.

Our employees shall not engage in misleading advertising regarding the company’s business activities and shall avoid any conduct that constitutes or may constitute unlawful abuse of or restriction of competition.

FINANCIAL RECORDS

Employees must ensure that all operations and transactions with economic significance are clearly and accurately recorded in the accounting records.

In particular, employees shall refrain from:

  • Recording transactions in off-the-books records not entered in official books;

  • Failing to record transactions carried out or recording them incorrectly;

  • Recording non-existent expenses, income, assets or liabilities;

  • Making entries in the accounting books with an incorrect indication of their purpose;

  • Using false documents; and

  • Deliberately destroying accounting documents before the legally established retention period.

Likewise, TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. shall ensure full compliance with the applicable tax regulations, with the support of external advisors specialized in this area.

RELATIONS WITH CLIENTS

TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. promotes commitment to quality by acting in accordance with the best recognized and standardized national and international practices. All employees must aim to achieve the highest levels of quality and excellence in the provision of services, seeking the long-term development of relationships based on trust and mutual respect.

In the event of situations involving possible conflicts of interest in relations with clients in which any member of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. is involved, such person must first refer the matter to their line manager and, if that is not appropriate, to the Consultation and Reporting Line, which will provide all collaboration, support and coverage necessary to manage and resolve the conflict.

RELATIONS WITH SUPPLIERS AND COLLABORATING COMPANIES

TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. shall establish with its partners in joint business ventures a collaborative relationship based on trust, transparency of information and the sharing of knowledge, experience and capabilities—within the limits permitted by competition law—in order to achieve common objectives and mutual benefit.

All employees of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. who participate in the selection of contractors, suppliers and external collaborators are required to act impartially and objectively, applying quality and cost criteria and avoiding any conflict between their personal interests and those of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L.

The contents of this Code of Ethics and Conduct that are applicable to contractors, suppliers and external collaborators shall be included in the collaboration or service agreements formalized in each case.

RELATIONS WITH GOVERNMENTS AND AUTHORITIES

TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. declares its political neutrality and undertakes to comply faithfully and respectfully with all legal obligations to which it is subject in any country or territory where it carries out its activities.

Employees of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. shall avoid any conduct which, even without violating the law, could damage its reputation before the community, the government of the country or other bodies, and produce adverse consequences for its business. No employee shall collaborate with third parties in violating any law, nor participate in actions that compromise respect for the principle of legality.

They must act honestly and with integrity in all their contacts or transactions with authorities and employees of governments and public administrations, ensuring that all information and certifications they submit, as well as the statements they make, are truthful, clear and complete.

Likewise, employees of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. shall not obstruct requests for information by public officials or the performance of any other function they may carry out in the legitimate exercise of their powers, provided that such requests or actions are covered by and comply with the applicable laws.

ANTI-CORRUPTION MEASURES

Zero-tolerance principle regarding corruption. TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. opposes influencing the will of persons outside the company in order to obtain any benefit through the use of unethical practices. Nor will it allow other persons or entities to use such practices with its employees.

Bribery

TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. must act in accordance with the laws that apply and, under no circumstances, may resort to or tolerate bribes from third parties to the Company or its employees, or vice versa.

TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. prohibits the use of any form of unlawful payment, by any means whatsoever, involving a material or moral advantage for the recipient—whether a public entity or a private company or person—for the purpose of obtaining any advantage or preferential treatment in its relations with third parties.

Employees are likewise prohibited from accepting bribes for their own benefit.

Payments may not be made to political parties, trade unions or similar entities except where expressly permitted by the legislation of the country in which the company operates.

Gifts, Presents and Hospitality

Employees of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L., by reason of the position they hold, may not accept gifts, hospitality, services or any other kind of favor from any person or entity that may affect their objectivity or influence a commercial, professional or administrative relationship.

Likewise, employees of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. may not offer, directly or indirectly, gifts, services or any other kind of favor to clients, partners or any other person or entity that maintains or may maintain relations with the company, with the aim of unlawfully influencing such relations.

PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING

In order to prevent and avoid money laundering operations or terrorist financing arising from criminal or unlawful activities, employees of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. must pay special attention to situations in which there are signs of a lack of integrity on the part of the persons or entities with whom business is conducted.

PROTECTION OF PERSONAL DATA

TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. declares that it has adopted all necessary and appropriate security measures in accordance with EU Regulation 2016/679 and Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights, and has established all technical means within its reach with the intention of preventing the loss, misuse, alteration, unauthorized access or theft of the data we process.

Employees of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. shall not disclose personal data obtained from clients, suppliers, employees, public administrations and the general public.

At any time, additional and detailed information on Data Protection can be consulted in the Legal Notice and Privacy Policy of our website www.transporteschinchon.es.

RESPECT FOR THE ENVIRONMENT

Preservation of and respect for the environment is one of the basic pillars of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L., as reflected in compliance with the best environmental practices in all its activities.

TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. undertakes to conduct its activities in such a way as to minimize negative environmental impacts and achieve a high level of safety in its processes, facilities and services, paying special attention to the protection of its employees, suppliers, clients and local surroundings.

Conserving natural resources, promoting energy saving and land-use planning are fundamental pillars, requiring all staff to comply with environmental guidelines.

INTERNAL CONTROL OF CRIMINAL LIABILITY

Internal control of criminal conduct is a priority objective for TRANSPORTES HERMANOS CHINCHON LOPEZ S.L., which is committed to the prevention, detection and avoidance of any unlawful act carried out within the scope of its responsibilities, in its name or on its behalf and for its benefit, by any of its employees.

The commission of any possible criminal offense by an employee of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. for the employee’s own benefit constitutes a breach of the Code of Conduct that the company shall duly sanction, without prejudice to any other liabilities that may be imposed on the offender and to other infringements of the Regulatory Compliance Model not classified as criminal offenses referred to in the Code of Conduct or in the rules comprising said Model.

CONSULTATION AND REPORTING LINE

Employees of TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. have the duty to report unlawful conduct, irregularities and breaches of the Code and the Model of which they become aware.

The doubts, questions and reports submitted through the Consultation and Reporting Line contribute to the detection of possible offenses and constitute a means for the Code of Ethics to fully operate, serving to continuously improve the preventive system.

No employee should think that they are acting in the interest of the company when concealing a fact or incident that violates the law or the Code of Ethics and Conduct.

The Consultation and Reporting Line is a corporate tool intended to facilitate the confidential and secure submission of any query regarding the scope and applicability of this Code of Conduct and, in general, of the Regulatory Compliance Model, as well as to report or denounce situations of infringement or risk in relation to the guidelines and conduct regulated in the Code of Conduct or in the Regulatory Compliance Model as a whole.

The Consultation and Reporting Line Procedure guarantees confidentiality in the handling of reports processed and the identity of the whistleblower, in full compliance with data protection legislation, as well as a reliable and objective analysis of the possible infringement and the utmost respect for the rights of the persons allegedly involved.

We have created and maintain a consultation and reporting line through which you may contact us, even anonymously, regarding acts or conduct committed within TRANSPORTES HERMANOS CHINCHON LOPEZ S.L. or in the actions of third parties contracting with us that may be contrary to the general or sector-specific regulations applicable to them.

Reports may be sent to the email address info@transporteschinchon.es or through the internal system or whistleblowing channel on our website.