1.- INTRODUCTION

This Code of Conduct lays out the fundamental values, principles and standards of conduct that should govern the performance and behavior of the professionals of Newdock France SAS (hereafter, Newdock France), and all those who work for or on behalf of the organization, like consultants, agents and subcontracted companies.

Today´s business demands are not focused solely on complying with the laws in force in the various legal systems. Our stakeholders expect that organizations achieve high ethical standards, to establish proper commercial relationships.

As a result, Newdock France expresses its firm commitment to a corporate culture based on strong ethical standards, by virtue of which each one of us has the duty and obligation to comply with the rules set out in this Code of Conduct.

In this way, we will contribute to the collective success of the Organization by promoting our brand and maintaining a good reputation. Our brand is an intangible asset that is essential to attract and retain talent, client trust, confidence of vendors, suppliers, and credibility with financial institutions, government agencies, business partners, as well as with the market and society in general.

In this way, all professionals must be an active part in our commitment to respect and preserve on daily basis and with every action Newdock France’s brand. We must be aware of the difficulty and great effort that acquiring a good reputation represents, and the ease with which said reputation could be negatively affected in the event of actions or decision-making that are not aligned with the highest ethical and behavioral standards.

For this reason, through this Code of Conduct and its associated policies, procedures, and instructions, Newdock France reinforces its commitment to comply with the current legislations and it promotes an ethical behavior, that implies the enhancement of our way of working, our modus operandi, our decision-making and our way of relating to the Organization´s stakeholders.

2.- AIM AND OBJECTIVES

The aim and main objectives of this Code of Conduct are as follows.

• Identify and embody the values, principles and ethical and professional guidelines that should guide the behaviour and conduct of the members of the Organization.
• Prevent the commission of criminal offences, corrupt practices, and acts contrary to the current legislation and to this Code of Conduct within the Organization.
• Promote among our business partners and other stakeholders’ behaviour guidelines that are consistent and aligned with the values, principles and conduct standards embodied in this Code of Conduct.

3.- SCOPE OF APPLICATION
The Code of Conduct shall be binding and directly applicable to all members of the Organization, regardless of their type of contract, their geographical location, the functions and tasks performed, and their hierarchical position or role within the Organization.

It shall also apply to Newdock France’s business partners when they carry out their activities for or on behalf of the Organization. Thus, all those who work with or for the Organization must adapt their conduct to the values, principles and standards set forth herein.

4.- OUR VALUES
4.1.- Honesty and Integrity
Correct and honest conduct, in line with our ethical commitments, protects and reinforces Newdock France’s reputation and credibility in the eyes of all our stakeholders and society.

To this end, all members of the Organization, as well as third parties working for or on its behalf, must carry out their activities with honesty, responsibility and integrity in their relations with stakeholders and, in particular, with clients, colleagues and other professionals.

Under no circumstances we will tolerate conducts that, to obtain benefits for the Organization, involve dishonest actions or implies a conflict with Newdock France’s values and principles.

4.2.- Commitment to quality and professionalism
Providing quality services entails not only technical rigor in the professionals’ activity, but also a constant commitment to responsibility, dedication, loyalty and the pursuit of excellence.

This quality requirement necessitates that all the member of the Organization receive adequate training in their respective areas of responsibility, so that customers can always obtain a valid and effective response in accordance with their needs.

Furthermore, all professionals must diligently fulfill the tasks assigned or entrusted to them, trying to provide maximum value and always acting with a collaborative spirit.

4.3.- Respect and dignity towards people
Fairness, respect and dignity towards people must permeate all relationships, both internal and external to the Organization, to preserve Newdock France’s image and reputation.

5.- OUR PRINCIPLES
5.1.- Legal and ethical behaviour
Newdock France is committed to carrying out its activities in accordance with the laws in force in all countries and in all areas in which it operates.

Consequently, all members of the Organization must reject any illegal practice and shall commit to comply with applicable laws and regulations, as well as they must carry out their professional tasks according to the ethical standards established in this Code.

5.2.- Accountability
Newdock France promotes the responsibility of each one of its members in the development of their professional tasks, which is manifested through a duty of accountability and control of the actions performed.

5.3.- Sustainability
Newdock France develops its activities with a long-term vision, seeking a balance between the achievement of its corporate objectives, on the one hand, and sustainable development and social growth, on the other.

In particular, the Organization pays the utmost attention to respecting and safeguarding the environment and nature, promoting the responsible consumption of natural resources, aiming to protect the natural heritage for future generations.

5.4.- Non-discrimination and equal opportunity
Newdock France encourages the creation of a work environment where all people are treated fairly, in accordance with the principle of non-discrimination and equal opportunities.

Therefore, the organization will not tolerate any discrimination based on birth, race, sex, sexual orientation, religion, opinion or any other personal or social condition or circumstance.

5.5.- Confidentiality and duty of secrecy
All members of the Organization shall treat corporate documentation and information to which they have access, whether verbal or written, whether from clients, other third parties or relating to internal know-how, with absolute confidentiality and exclusively for Company’s business purposes. This duty applies to all matters of which the professionals are aware in their fields of practice.

6.- STAKEHOLDERS’ RELATIONSHIP MANAGEMENT
6.1.- Staff relations
Equal opportunity and harassment zero tolerance
Newdock France’s human resources processes, from selection and hiring to promotion and professional development, must always comply with the principles of impartiality and equal opportunity. Any form of direct or indirect discrimination based on birth, race, sex, sexual orientation, religion, opinion or any other personal or social condition or circumstance is strictly prohibited.

Likewise, Newdock France promotes dignity, equality and respect for everyone, requiring all members of the Organization to behave in accordance with these values and principles.

In addition, Newdock France rejects any behavior or attitude that could violate the dignity of individuals or that, directly or indirectly, could constitute harassment, in any of its multiple forms.

Workplace health and safety
Newdock France constantly works to protect the safety, health and well-being of all its personnel.

To this end, all safety laws shall be carefully observed, and preventive actions and plans to improve working conditions and reduce workplace risks shall be promoted.

Professional development and training
Personnel represents one of Newdock France’s most important assets.

For this reason, we pay the utmost attention to the improvement of human resources, and we base the selection, recruitment and professional development processes on the pillars of loyalty, competence, dedication and the pursuit of excellence, in accordance with our values of « Commitment to quality and professionalism » and « Honesty and Integrity ».

Use of corporate assets
All members of the Organization, as well as its business partners, must use and conserve Newdock France’s assets, consisting of movable and immovable property, tangible and non-tangible, including intellectual and industrial property, according to the diligence of a good pater familias and exclusively for work purposes.

Work equipment shall be used in accordance with the Organization’s policies and applicable workplace health and safety legislation.

Newdock France’s computer systems and programs must be used within the limits strictly necessary for the execution of the activities and work of the Organization’s personnel. Their use for purposes other than those inherent to the employment relationship is prohibited.

Their access will be protected by a system of authorizations, and it is strictly forbidden to provide any other individual with personal access credentials to the computer systems.

6.2.- Customer relations
In line with our values, at Newdock France we are committed to providing services of the highest quality, which not only implies technical rigor, but also a responsibility, dedication, loyalty and the pursuit of excellence commitment, aimed at maintaining and strengthening our reputation with our clients.

In addition, we require all our personnel and business partners to always act in line with the corporate values, principles and standards of conduct, rejecting any type of conduct or practice aimed at obtaining or retaining undue advantages or securing an improper benefit in the development of Newdock France’s activity.

6.3.- Relations with business partners
Newdock France maintains business relationships with counterparties of recognized reputation and experience. Integrity, transparency and mutual trust must always prevail, in compliance with applicable laws and the values and principles contained in this Code of Conduct.

6.4.- Relations with suppliers
Our goal is to provide ourselves with goods and services of the highest quality, always guaranteeing an adequate quality-price ratio and maintaining a level of total transparency in our relations with suppliers.

Therefore, the members of the Organization in charge of relations with suppliers must select them and manage the corresponding relations according to criteria of objectivity, impartiality and avoiding situations of conflict of interest.

6.5.- Relations with the Public Administration
The relations of all members of the Organization with public bodies and administrations shall be based on the legality, cooperation and transparency principles, rejecting any type of conduct or practice aimed at obtaining or retaining undue advantages or ensuring an inappropriate benefit in the development of Company’s activity.

To this effect, only Newdock France’s personnel specifically designated and/or authorized to do so shall deal with the Public Administration, as well as with organizations that carry out activities of public utility or interest.

6.6.- Relations with supervisory and control authorities
Newdock France’s relations with supervisory and control authorities are based on maximum cooperation in full respect of their institutional role, avoiding any behaviour that could hinder, limit or mislead the control activity. To that effect, Newdock France shall promptly apply the prescriptions and indications received.

6.7.- Relations with political parties and trade unions
Newdock France does not make contributions of any kind, directly or indirectly, to unions or political parties, federations, coalitions or groups of voters.

Likewise, direct or indirect donations in favor of political representatives and candidates, companies, organizations, associations, foundations or groups of influence linked to political parties are prohibited, as well as donations in favor of unions, companies, organizations, associations, foundations or groups of influence linked to them.

6.8.- Relations with the press and other media
Actions performed through Newdock France’s different channels or media (such as press, radio, television, corporate website, social networks, etc.) must be inspired by the values of « Honesty and Integrity » and the principle of « Accountability ».

To this end, only authorized personnel can deal with the press and the media, who shall respect and act in a manner consistent with the mentioned values and principles.

7.- STANDARS OF CONDUCT
Accounting information integrity
Newdock France undertakes to keep orderly accounts in accordance with the principles of correctness, completeness, clarity and transparency, and to always comply with applicable fiscal and tax regulations.

Newdock France has the necessary internal procedures to ensure that each transaction is not only correctly recorded, but also authorized, verifiable, legitimate, coherent and consistent.

Data Protection
Newdock France respects confidentiality and maintains a strong commitment to protect the personal data collected for or in connection with its business activity, whether such data is held by its members, business partners, customers or third parties.

Therefore, Newdock France requires strict compliance with personal data protection legislation, in accordance with the provisions of Regulation (EU) 2016/679 (GDPR).

Intellectual and Industrial Property Protection
The protection of trademarks, patents, licenses and intellectual property belonging to Newdock France, or third parties is considered of primary importance and, therefore, any conduct aimed at their alteration and falsification, as well as their reproduction, dissemination, sale or misuse is prohibited.

Free competition
Newdock France operates in the markets in a fair and transparent way, and in compliance with the principle of free competition.

In particular, the Organization is committed to complying with applicable antitrust regulations, requiring all its members and business partners to refrain from conducts that could prevent, restrict or distort competition in the common market. Likewise, cartel activities and activities that give the appearance of participating in a cartel are strictly prohibited.

Managing conflicts of interest
A conflict of interest occurs when a professional’s private interests (such as external, financial, family, political or personal businesses) might interfere with the interest of the Organization.

Thus, it is a situation of conflicting interests that occurs when the interest that should govern the actions of a professional is displaced, altered or influenced by a personal interest, giving rise to the possibility that the person’s actions, the performance of his/her duties, the assumption of his/her responsibilities and the making of his/her decisions may deviate from the criteria of objectivity and impartiality.

Therefore, the interest that should govern the performance of the members of the Organization, that is, Newdock France’s interest, should never be opposed or compromised by a personal interest.

Therefore, professionals must perform their functions and duties with absolute responsibility, transparency, loyalty and the pursuit of excellence, as previously mentioned in our values and principles.

Prevention of money laundering and financing of terrorism
Newdock France acts with the utmost rigor to avoid any money laundering or terrorist financing operations, transactions or activities, guaranteeing a firm commitment to comply with all applicable national and international regulations in this area.

Therefore, all members of the Organization have the inexcusable duty to pay special attention to possible cases in which there are indications of a lack of integrity on the part of natural and legal persons which they maintain commercial or business relations with.

Corporate courtesy
Certain actions carried out improperly could give rise to corruption or bribery practices, based on the risk that, by means of these, an attempt may be made to influence the other party, modifying its will with the intention of obtaining from it an improper performance or benefit.

One of Newdock France’s unavoidable objectives is to actively fight any corrupt practice in which it might be incurred, which implies not only a violation, infraction, or breach of the rules of our legal system, but also a lack of alignment with the Organization’s ethical standards.

In line with the above, only business courtesy of modest value is permitted, and in any case such that likely it does not create, in the other party or in an outside and impartial third party, the impression that they are aimed at acquiring or granting undue advantages, or that they are likely to create in any case the impression of illegality or immorality.

Sponsorships and contributions must have a specifically established objective related to the Organization’s activity, the strengthening of its institutional relations, as well as its image and reputation.

8.- SUPERVISION
Compliance function
Newdock France’s compliance function is exercised through the Compliance Officer which has been appointed by the Management Committee and has autonomous powers of initiative and control to supervise, monitor and control effective compliance with this Code of Conduct.

Communication of doubts and non-compliances
Newdock France’s personnel must report any alleged or actual violation, infraction or non-compliance with current legislation, this Code of Conduct and other internal rules that have been implemented at Newdock France.

They may also raise any doubts or concerns regarding the application or content of this Code or other internal policies, procedures and instructions of the Organization.

To this end, Newdock France makes available to its members, business partners and other third parties a whistleblowing channel that is accessible at the following URL: https://canal-etico.online/app/sessions/comunicar?=newdockfrance

The Organization strictly prohibits any form of retaliation, discrimination or other unfair treatment against those who report violations in good faith and against those who cooperate in an internal investigation procedure.

Retaliation, as well as the filing of complaints in bad faith, will lead to the application of the disciplinary system adopted within Newdock France.

Disciplinary System
The violation, infraction or breach of the rules contained in this Code of Conduct, as well as in the rest of the Organization’s internal regulations, shall entitle Newdock France to adopt the applicable disciplinary measures against its members, in accordance with the internal disciplinary regime and with the labour provisions that may be applicable.

Likewise, in relation to business partners, suppliers and other third parties with whom Newdock France maintains commercial relations, behaviour contrary to the values, principles and rules of conduct expressed in this Code of Conduct, and to the regulations in force, may be considered, in the most serious cases, as a breach of the duties of loyalty and contractual good faith. Therefore, Newdock France may adopt the civil or commercial appropriate measures.

9.- COMMUNICATION AND DISSEMINATION
Newdock France’s reputation and image must be continuously protected. For this reason, it is essential to communicate, raise awareness of and observe the values, principles and standards of conduct contained in this Code of Conduct.

In this regard, Newdock France will inform all its members, and each new professional that joins the company, of the existence of this Code of Conduct, its contents, the mandatory nature of its observance and the consequences that may arise from its violation, infraction or non-compliance.

This will ensure that all members of the Organization, from the very moment of their incorporation, are aware of the values, principles and standards of conduct that must govern their actions and behaviour, remembering that they must be the first to set an example of consistency between the provisions of this Code of Conduct and their daily conduct.

To this end, this Code of Conduct will be communicated and disseminated to all members of the Organization through digital and physical distribution.

10.- TRAINING
The standards set forth herein will be included in the content of our Internal Training Plan, to promote a corporate culture of respect for the applicable laws, the Code of Conduct and other Company´s internal rules and policies. This will ultimately have a positive effect on our corporate health, on the proper development of our business processes and, especially, on maintaining our corporate image and reputation with our stakeholders.

11.- APPROVAL AND ENTRY INTO FORCE
This Code of Conduct was approved by the Management Committee of Newdock France SAS in July, 2024 and shall enter into force from the day following its communication or dissemination to the members of the Organization.

ANNEX I.- TERMS AND DEFINITIONS
Business partner: external individual or legal entity with which the Organization has, or plans to establish, some type of business relationship.

Examples: brokers, intermediaries, distributors, contractors, etc.

Compliance function: person or group of persons of the Organization with autonomous powers of initiative and control, which is responsible for supervising the Organization’s Compliance Program.

Members of the Organization: employees, managers, directors and administrators of the Organization, and other persons who are hierarchically subordinate to any of the above.

Organization: Newdock France SAS.

Personnel: individuals in a relationship recognized as an employment relationship under national law or practice, or in any contractual relationship whose activity depends on the Organization.

Public official: means: (i) any public or elected official, agent, employee (regardless of rank) or person acting on behalf of a national, provincial or local government, department, agency, instrumentality, state-owned or controlled company, public international organization, political party or entity that is largely financed by public funds, that is generally perceived to perform governmental functions, or that has key executives or directors appointed by a government; and (ii) any political party, political candidate for office or any person acting on behalf of the party or candidate for political office. Examples include issuers of governmental permits, approvals or licenses (whether at the international, national, regional, municipal, etc. level), airport authorities, employees and officers of state-owned enterprises, customs, immigration or tax agents, or ministers or representatives of domestic or foreign governments.

Stakeholders: natural or legal person or organization that may affect, be affected or be perceived to be affected by Newdock France’s decisions or activity.

Third party: any natural or legal entity that is independent of the Organization.

Whistleblowing Channel: confidential and secure channel through which members of the Organization, as well as third parties, can report in good faith suspicions of non-compliance and conduct contrary to the principles, values and standards of conduct to which the Organization is committed.