NUBALIA CODE OF ETHICS AND CONDUCT

1. PREAMBLE

Corporate Social Responsibility is a moral obligation for NUBALIA CLOUD COMPUTING, hereinafter NUBALIA. For this reason, the mission of our company, a strategic Google Cloud partner, is to carry out services related to digital innovation and transformation using Cloud Collaboration, Data, Artificial Intelligence, Infrastructure and Development technologies, always offering the best guarantees. of quality, commitment, innovation and efficiency, thus providing a competitive differential in the market.

Our values stipulate the principles of action of those who are part of the company, which is why, from all the Nubalia teams, it will always be promoted to work in this line.

2. OBJECT

This Code of Ethics aims to establish the values that should guide and preside over the behavior of anyone who belongs to the company. We are committed to the highest ethical and integrity standard.  This code is our solemn promise to live the values that we have adopted as an organisation and adhere to the standards we have set ourselves on every action and decision we make at both organizational and individual level. 

Furthermore, this corporate culture aims to promote the transparency and quality of the relationships carried out by: employees, between employees and employees with clients, shareholders, suppliers, external collaborators, public and private institutions, but also with society in general .

Likewise, this Code of Ethics is based on values and general principles that serve as a guide for responsible and correct action in the professional performance of employees, in accordance with current legislation and established internal regulations. For NUBALIA, it is important to highlight the following values as the basis of the company’s philosophy and behavior: professionalism, commitment, ambition, team and clarity.

In this way, the principles applied by WCA for the prevention, detection and eradication of irregularities related to breaches of the Code of Ethics are reflected. Therefore, the knowledge and internalization of this Code as well as the definition and identification of responsibilities and procedures in normative terms for NUBALIA are essential. In addition, the regular control of risks in any aspect is also relevant, especially in relation to this Code and the constant training and updating of the worker in this matter.

3. AREA OF APPLICATION

This Code, together with other organizational specific policies, presents a guide to help us all understand how we can all contribute to building the ethical organisation we strive to be known as by all our stakeholders and how to live NUBALIA values.

Therefore, the best means will be made available to those who make up the company to promote and enforce the standards contained in this Code. It is worth noting the mandatory compliance with the guidelines for conduct contained in this Code.

When deemed appropriate, convenient and viable, the company may request its suppliers, collaborating companies, counterparties and / or any other individual related to NUBALIA the commitment to comply with the guidelines established by the Code.

Likewise, this model of reference in behavior can also be used to assess the level of ethical compliance and the requirement of each worker with the behavioral criteria stipulated in the performance of their duties during professional activity.

As discussed so far, the main purpose of the Code is the prevention of misconduct through respectful and honest behavior within the framework of current legislation. Therefore, we must always bear in mind that the breach of the rules of the Code of Conduct represents a violation of the principles of NUBALIA and, therefore, is a serious issue that may entail not only legal responsibilities (either individual or for the legal person), but can especially affect our reputation.

4. BASIC PRINCIPLES OF CONDUCT 

The set of rules and principles that guide the conduct of all of us who make up NUBALIA can be divided into two areas:

Corporate ethical values that mainly define NUBALIA

Mainly they are: 

PROFESSIONALISM

  • Executive capacity for rapid decision making and implementation
  • Quality taken to the maximum through the continuous improvement of the [email protected] and the company’s processes. 
  • Focus on the generation of value and competitive advantages for the company. 

COMMITMENT

  • Defending and honoring the company’s values
  • Internalisation and struggle to achieve the objectives set 

AMBITION

  • I work to make our company a world reference of Google Cloud
  • Growth and continuous improvement to reach our best

TEAM

  • Work in a united and coordinated manner to achieve goals
  • Sharing knowledge and experience by bringing out the best in each other and trusting each other to take responsibility for achieving a common goal 
  • Feedback is part of our daily life 

CLARITY: trust is the cornerstone of relationships through:

  • Honest, open and direct communication
  • Consistency in what we say and do
  • Acting with objectivity and integrity

Our work methodology is mainly focused on the client and on quality, creativity and proximity. The main commitment is based on the ability to fulfill our obligations in an optimal way, involving and involving the client in any type of decision, in order to meet their requests and fulfill the objectives set, thus ensuring customer satisfaction.

In addition, we seek the training and continuous learning of our workers, combining research and development to achieve excellence and permanent innovation.

Fundamental ethical values in the performance of professional work

  • Respect for the human rights and public freedoms recognized in the United Nations Universal Declaration of Human Rights
  • Respect for legality.

Likewise, no employee shall knowingly collaborate with third parties in the violation of any law, nor shall he or she participate in any action that compromises respect for the principle of legality. The company, for its part, shall establish the necessary internal control models that ensure compliance with such legality.

NUBALIA does not tolerate, allow or get involved in any type of corruption, extortion, money laundering or bribery in the performance of its business activity with the purpose of obtaining favorable treatment or any other type of benefit, neither in the public nor in the private sector.

  • It offers good working conditions, respecting labour rights and workers’ health.

NUBALIA promotes the adoption of health and safety policies in the workplace and adopts the preventive measures established in the current legislation, providing a working environment that respects the health and dignity of employees.

All NUBALIA employees must know and comply with the rules of health and safety protection at work and ensure the safety of themselves, other employees and, in general, any person.

NUBALIA, on the other hand, expects the respect from its workers to the material, devices and the rest of complements, materials and tools that it makes available to each and every one of its employees.  

  • Respect for people. 

All employees, regardless of their position within the company, have the obligation to treat and be treated fairly and respectfully, thus providing a pleasant working environment. The same applies to relations between employees and external collaborating companies or entities.

NUBALIA rejects any manifestation of harassment and/or discrimination, promoting effective equality of members and ensuring equal access to opportunities through its policies.

The selection and promotion of employees is based solely on the competencies and performance of their duties, as well as on the criteria of merit and ability defined in the requirements of the job position.

NUBALIA considers the integral development of the person to be important, and will therefore always facilitate the necessary balance between professional and personal life.

  • Promotion of sincerity, fairness, truthfulness, compliance with commitments, transparency and teamwork.
  • Innovation to develop social and environmental improvements. 

For NUBALIA the preservation and respect for the environment is a constant commitment that is carried out through actions to promote habits and behaviours related to positive environmental practices.

  • Recognition of people and achievements in results to achieve the loyalty of employees. 

In NUBALIA, the development and motivation of the employees is taken into account, for this reason, everyone can actively participate in the training plans that are made available, in order to promote their professional progress.

  • It manages Quality and Safety. 

At NUBALIA, it is essential that all products and services comply with the quality and safety standards and parameters required by the applicable laws, paying special attention to the compliance of SLA’s required.

Likewise, we have a Quality Management System implemented and certified (ISO 9001).

  • Professional secrecy and information treatment.

All employees must take the utmost care to preserve the image, intellectual and industrial property and reputation of the company in all their professional activities. Information and knowledge are essential assets for business management and must therefore be the object of special protection. NUBALIA’s employees must maintain the strictest confidentiality regarding all reserved information to which they have access as a result of their professional activities and must refrain from using it improperly for their own benefit or that of third parties.

Likewise, the correct and adequate use of the corporate image and reputation by companies outside NUBALIA will be ensured. 

Likewise, NUBALIA complies with the current legislation on data protection (Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 (RGPD).

In this section, reference should be made to the values that affect suppliers and external collaborators in the relationship with NUBALIA. These are:

  • Respect for the conflict of interests: all suppliers must avoid situations that could lead to a conflict of interest for NUBALIA. 
  • Fair competition: NUBALIA is committed to practicing competition with loyalty and total transparency. 
  • Confidentiality: suppliers must respect the confidentiality of privileged information to which they have access due to their condition and the provision of our services, and must not in any case make improper use of it.
  • Use and return of information: it is the responsibility of the supplier or other external collaborators and their team to adopt sufficient security measures to protect the reserved information. It will include the obligation to return any material related to NUBALIA. 

In order to ensure that all employees guide their behavior in line with this Code of Ethics, it is relevant to have a good basis of trust between each and every one of the professionals who are part of the company. Creating a working environment of these characteristics facilitates and supports the development of integrity and good faith performance and responsibility and positive will in the professional performance of all people who are part of NUBALIA.

If there is any doubt about the interpretation of the guidelines of conduct that appear in this Code, employees can consult the Human Talent Team and Legal Team. In this way, the principles of business ethics and transparent management will be addressed and reinforced, avoiding any behaviour that could discredit NUBALIA.

5. ACCEPTANCE AND COMPLETION OF THE CODE

NUBALIA will communicate, disseminate and implement among its employees and in certain cases, among suppliers and other collaborators, the content of this Code of Conduct. All employees who join or become part of NUBALIA must commit to accept the Values and Principles and the rules of conduct established in the Code and may not justify improper conduct on the grounds of ignorance of this Code. Therefore, violations of this Code may result in warnings and/or sanctions.

In addition, the company will carry out training sessions on the different aspects of the Code, expecting from its employees a high level of commitment in the fulfilment of its Code of Ethics.

6. COMMISSION OF THE CODE OF ETHICS 

The Code of Ethics Commission is a consultation and recommendation body whose main purpose is to

To promote the dissemination, knowledge and compliance with the Code of Ethics. 

To guide actions in case of doubt among those who make up NUBALIA.

To facilitate the resolution of conflicts related to the application of the Code of Ethics.

To elaborate recommendations or proposals to keep it updated, improve its content and facilitate the application of those aspects that require special consideration.

7. VALIDITY 

The Code of Ethics comes into force on the day of its publication to all [email protected] will be in force until its cancellation is approved. It will be periodically reviewed and updated, taking into account the suggestions and proposals made by the employees as long as these are viable and consistent.

Consequently, NUBALIA provides its employees with an Ethical Mailbox by means of a totally anonymous form to communicate any type of information related to the implementation of the Code of Conduct. All information obtained will be covered by anonymity, and therefore, employees must inform, in good faith and without fear of reprisals.