Compliance and Business Ethics Policy

Purpose: This policy establishes the standards and expectations for ethical behavior and regulatory compliance at LTS Consulting Iberica S.L. Our commitment to integrity, transparency, and respect for the law is fundamental to our operations and business relationships.

1. Regulatory Compliance:

• All employees must comply with all applicable laws, regulations, and policies in all jurisdictions where we operate.
• Any violation or potential violation of laws and regulations must be reported immediately to the compliance department.

2. Business Ethics:

• All employees are expected to act with honesty, integrity, and ethics in all business interactions and employment relationships.
• The use of insider information or engagement in illegal or fraudulent activities is prohibited.

3. Anti-Corruption:

• Bribery, commercial bribery, or any other form of corruption in our business operations is not tolerated.
• Offering, promising, giving, or soliciting bribes to any person, including government officials and clients, both domestic and foreign, is prohibited.

4. Commission Payments:

• All commission payments must be transparent, legal, and properly documented.
• Payments of commissions that violate applicable laws or regulations are prohibited.

5. Gifts and Entertainment:

• Courtesy gifts and entertainment are permitted as long as they are reasonable, legal, and intended to promote legitimate business relationships.
• Prior approvals must be obtained for gifts or entertainment exceeding the limits set by the company policy.

6. Compliance and Monitoring:

• The compliance department is responsible for monitoring compliance with this policy and providing guidance and training on compliance and business ethics matters.
• Regular audits will be conducted to ensure compliance with this policy and corrective actions will be taken as necessary.

7. Consequences of Non-Compliance:

• Non-compliance with this policy may result in disciplinary action, including termination of employment, and may give rise to legal liability for both the employee and the company.

8. Disclosure and Communication:

• All employees will receive a copy of this policy and must certify that they have read, understood, and agreed to comply with it.
• Open communication and disclosure of potential concerns regarding compliance and business ethics are encouraged.

Effective Date and Review: This policy is effective as of the approval date and will be reviewed and updated as necessary to ensure its continued relevance and effectiveness.

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