Ethical Code

1 Preamble

MQS is aware of the role it plays in society and of its responsibility towards its customers and business partners as well as its shareholders and employees. The Company has therefore committed itself to clear principles which serve as the foundation for the actions MQS takes as a business and as a corporate citizen.

MQS’s core values are trust, forward thinking, reliability, performance and customer focus. They reinforce the actions of all MQS employees and cultivate a shared corporate identity and culture across all the operating companies within MQS.

The actions taken by MQS and by its employees are founded on personal responsibility, honesty, loyalty, and respect for others and for the environment, aligned with the three fundamental pillars of the management system: Commitment to people, Social Responsibility, and Sustainability.
Managers bear particular responsibility in this regard.

MQS’s key business goals are to provide customers with the services and thus to achieve business success. Fair market returns for MQS shareholders can only be secured over the long term if the Company continually strives to improve the degree to which quality and performance demands are met.

In order to do this, MQS relies on:

  • the skills, strength and dedication of its employees,
  • a stable social, political, and regulatory environment,
  • opportunities offered by scientific and technological advances.

2 Purpose

The Code of Ethics has two main purposes:

1. First, it encourages each employee to take responsibility for their actions, and tries to provide them with adequate guidance, whatever their responsibility, their position in the organization, the contractual modality that determines their relationship with the company or the where they develop their activities.

In this way, the MQS Code of Ethics determines the expected behaviour of employees in matters of an ethical nature, related to the commitments of the organization in the matter or to the applicable regulations, which are more relevant given their activities and characteristics.

The Code highlights the principle of due diligence applied by the organization in matters of ethics and integrity for the prevention, detection and eradication of irregular ethical acts, whatever the nature of these. The Code reflects the principles of MQS in matters related to ethics and integrity but does not modify or replace any of the existing standards or policies in the organization.

The Code also includes the behaviours expected of employees in those matters included in the Spanish Penal Code, which the company’s management understands to be more relevant given its characteristics and the businesses in which it operates.

2. Second, it describes goals and principles that guide MQS business activities.

3 Principle of due diligence

For MQS, due diligence on ethics and integrity refers to the set of activities that the organization develops to prevent, detect and, where appropriate, eliminate misconduct, opposing to internal and external rules, which may appear in the organization.

MQS understands that exercising due diligence in matters of ethics and integrity comprises various elements.

3.1 Emphasize the risk áreas

The Code of Ethics provides guidelines in matters of ethics and integrity with a higher relevance, given the characteristics of the organization and the businesses in which it operates.

3.2 Assign responsibilities

The board of MQS is ultimately responsible for overseeing the effective implementation of the Code. Management responsibilities related to their knowledge, understanding and compliance are delegated to the Compliance Committee.

3.3 Establish commitments

The MQS Code of Ethics includes the commitments assumed by the Company and all its employees regarding ethics and integrity.

3.4 Ensure that people know and understand the commitments

MQS will allocate the necessary resources to ensure that this Code, as well as the rules on which it is based, is known and understood by all of its employees.
3.5 Supervise and monitor
The Compliance Committee has responsibility for ensuring the knowledge, understanding and compliance with the Code of Ethics and ensures the proper functioning of safeguard mechanisms established for this purpose. Their function also is monitoring compliance with the Code in the organization and periodic report on such end to the board of MQS.

3.6 Safeguard compliance

MQS has established a notification and consultation procedure that, supervised by the Compliance Committee, allows the employees of the organization, in good faith and safe from reprisals, to communicate irregular practices in the matters contemplated in the Code. All employees of the organization are required to report any irregular behaviour they may observe. The Compliance Committee will process the notifications and inquiries received and ensure, in general, compliance with the Code in the organization.

3.7 Correct bad practices

MQS applies the principle of zero tolerance to bad practices in the matters included in the Code. Breaches will be analysed and resolved by the Compliance Committee in accordance with internal and external regulations that may be applicable and in accordance with the established procedure for resolving notifications and consultations in criminal and otherwise.

3.8 Improve

MQS undertakes to develop, if necessary, the internal regulations, procedures and elements of control that could be necessary for the effective implementation of the commitments included in the Code of Ethics.

4 Scope of Application

The Code of Ethics applies uniformly in MQS and is aimed to all employees of the Company, regardless of the position they occupy, the type of contract that determines their relationship with the company or the place where they perform their work.
MQS encourages other companies that have business relations with it to adopt the Code’s principles. If, in the course of such business relationships, the Code conflicts with another company’s ethics policies, MQS will do its best to find a mutually acceptable solution.
The Code of Conduct forms the basis for other internal regulations which take into account aspects specific to the industry and country concerned. The Code covers Company interests and all areas in which employees are viewed as representatives of the Company. However, the Ethical criteria included in this Code are not intended to describe the totality of situations or circumstances which MQS employees may find, but to establish general guidelines of behaviour that guide them in the performance of their responsibilities.

5 Principles

The United Nations Global Compact initiative asks companies to recognize in their sphere of influence a set of core values in the areas of human rights, labour standards, the environment and the fight against corruption and to comply with this set of fundamental values in practice.

5.1 Human Rights

Businesses should support and respect the protection of internationally proclaimed human rights and make sure that they are not complicit in human rights abuses.

5.2 Labour standards

Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining, as well as, the elimination of all forms of forced and compulsory labour, the effective abolition of child labour, and the elimination of discrimination in respect of employment and occupation.

5.3 Environment

Businesses should support a precautionary approach to environmental challenges, undertake initiatives to promote greater environmental responsibility, and encourage the development and diffusion of environmentally friendly technologies.

5.4 Anti-corruption

Businesses should work against corruption in all its forms, including extortion and bribery.

5.5 MQS values

In line with these principles, MQS’s core values are trust, forward thinking, reliability, performance and customer focus. They reinforce the actions of all MQS employees and cultivate a shared corporate identity and culture across all the operating companies within MQS.

6 Compliance with Laws and Regulations

6.1 General principles

The personnel of MQS must strictly comply with the internal rules and the legal provisions that are applicable to the organization and their own activity. This commitment forms the basis of the ethical behaviour that is expected of all people in the organization.

MQS activities must be developed with strict respect for human rights and public freedoms, in accordance with internationally accepted laws and practices. Among the standards that the organization takes as reference is the International Bill of Human Rights or the OIT fundamental conventions on labour practices.

MQS ensures compliance with the labour provisions contained in the fundamental conventions of the International Labour Organization and does not admit, under any circumstances, practices contrary to these principles, which refer to freedom of association, collective bargaining and the elimination of child labour and forced labour. Neither will it admit practices contrary to these fundamental principles among its suppliers, contractors nor, in general, collaborating companies.

The people of MQS must observe, in all circumstances, an ethical behaviour and avoid activities of a nature that could harm the material interests or social prestige of MQS. Neither will they collaborate with third parties in activities that could violate the law or damage the trust of third parties in the organization.
MQS is subject to laws, directives and other regulations that can be international and national as well as regional and local in scope. For example, such laws and regulations set safety and environmental standards for facilities and their operation, set quality standards for products and services, regulate business activity within various markets, and forbid certain behaviours and practices. In general, the principles here listed intent to provide compliance to company rules and protection for bribery.

MQS’s foremost objective is to comply with all laws and regulations and to always operate within the bounds of these — frequently changing — legal and regulatory parameters. The integrity of all actions is an essential prerequisite for sustained successful business performance. MQS expects individuals and subsidiaries to abide by the law.

The environment in which MQS operates is shaped not only by national and international law, but also by many social and cultural rules and customs. MQS also factors these — often unwritten — rules and customs into its decision-making and evaluation processes and strives to act in accordance with them.
For that purpose, all MQS employees must know and understand the laws and regulations relevant to their professional activity and request, in case of doubt, the advice they need to those areas of the organization that specialize in the different areas.

MQS is committed to providing the means for the people of the organization to know and understand the internal regulations and the most relevant legal provisions in their area of responsibility.

6.2 Internal control and fraud prevention

Fraud is any intentional and deliberate action, made by an employee or a third party, to achieve a benefit for their self or for the organization, direct or indirect, making use for that purpose, and in an inappropriate way, of information, assets or resources of the organization.

6.3 Use and protection of assets

The people of MQS have the means they need to develop their professional obligations. The assets that MQS makes available to its employees include, but are not limited to, physical assets and information.

Both misappropriation and improper use of MQS assets constitute fraud.
MQS employees must protect and make a good use of the resources and assets that the Company offers and use them in a responsible manner to avoid damage, loss, theft or misuse. MQS resources must be used, unless the organization determines otherwise, exclusively for the performance of the functions assigned by the people of the organization.

However, MQS occasionally allows the use of company assets for personal use, provided it is used sporadically, whether it is everyday assets, such as telephone and personal computer, its cost to the company is marginal and does not affect negatively to employee productivity. In any case, the people of MQS will consult with their hierarchical superior in case of doubt and in no case will they use the assets of the company to develop socially unacceptable activities or inappropriate behaviours.

MQS employees must also strictly comply with the provisions of internal and external regulations regarding the protection of intellectual property. This includes patent rights, trademarks and service marks, domain names, reproduction rights (including software reproduction rights), design rights, database extraction or technical expertise rights.

Regarding access to and use of information technologies, it is important to remember that MQS employees will conduct themselves ethically, legally and professionally. In any case will they use these means to access or distribute material that intimidates, harasses, threatens, has a sexually explicit content or could be otherwise offensive or inappropriate, nor will they send any false, pejorative or malevolent communication or that may be offensive to the recipient.

All documents, data and correspondence contained in the information systems that MQS makes available to its employees are subject to review. With the acceptance of this Code of Ethics, the employees of the company recognize the right of the latter to the surveillance, supervision, inspection and control of the electronic communications and of the computer equipment that the company puts at their disposal, as long as it does not contravene the regulations imposed in article 20.bis of the ET.

MQS persons must also comply with current legislation on data protection, including those of a personal nature.

MQS is committed, on its part, to offer employees the information, knowledge and resources necessary to comply with the provisions of the internal and external regulations applicable in matters of information management and data protection.

Finally, the good name of MQS is the hallmark of the company.

The conduct of the people of the organization must be aimed at preserving and protecting this asset.

6.4 Confidentiality of the information

MQS discloses information about the company in compliance with the laws and regulations of Spanish and international securities, in order to allow proper negotiation of the company’s securities. This requires that non-public information that could reasonably be expected to significantly affect the price of the company’s securities should remain confidential until it is officially published. Take advantage of privileged information to buy or sell publicly traded securities of MQS or its trading partners or to pass this information on to third parties, constitutes a violation of the securities laws and company policy to.
In general, and unless otherwise indicated, the information (understood in a broad sense) to which the people of MQS have access in the development of their professional obligations, must be considered reserved and must be used exclusively for the development of the functions that each one has assigned.

The employees of MQS compromise to maintain confidentiality and to make a discreet use, in accordance with the internal regulations in the matter, of that information to which they have access in the performance of their professional obligations. In this way, they will only share information classified as confidential with other persons of the company that require it for the performance of their work. They should not disclose any classified information to other people until it has been made public.
Nor will duplicates, or reproduce, or make more use of information than strictly necessary for the development of their tasks. Likewise, under any circumstances they will use or access information to which they are not authorized by the company, nor they will disclose it to third parties.
The obligation to maintain the confidentiality of the MQS information will persist even if its professional connection with the organization has ended and it will include the obligation to return any material related to the company that the employee has in its possession at the moment of the termination of its relationship with the company.

6.5 Control of financial and accounting information

The falsification, manipulation or deliberate use of false information constitutes fraud.

In MQS, the transparency and reliability of financial and accounting information, as well as compliance with applicable regulations, is assumed as the principle of behaviour.

Employees must transmit this information in a truthful, complete and understandable manner. Under no circumstances will they knowingly provide incorrect, false or inaccurate information that could mislead to the recipient.

MQS employees will clearly and accurately reflect the transactions, actions and events in the company’s records and will pay special attention to the reliability of the financial and accounting information entered into the systems of the organization, which will reflect, as of the corresponding date, the rights and obligations through the corresponding assets and liabilities, in accordance with the applicable regulations. The records must reflect the totality of the transactions, actions and events of the organization.

In addition, the board of MQS and all the people in the organization are committed to ensure regular monitoring of the effectiveness of internal control over the preparation of financial and accounting information.

If the employees of the organization observe circumstances that, according to their knowledge and understanding, suppose a breach of the previous Ethical principles in the matter of internal control of the financial information, they should inform the Compliance Committee.
MQS is committed to making available to its staff the training that is necessary to know, understand and comply with the commitments established by the organization in terms of internal control of financial information.

In any case, only the authorized spokespersons of the organization may publicly comment on the activities or results of MQS.

6.6 Corruption, bribery and relations with third parties

The personnel of MQS will reject corruption in all its forms and will act in a manner aligned with the national and international provisions on the matter, among which are the Spanish Penal Code, the “Foreign Corrupt Practices Act” or the guidelines for multinationals companies of the OECD.

Under any circumstances will MQS people resort to unethical practices to influence the will of third parties in order to obtain some benefit for MQS or for themselves. In the same way, MQS staff must remain alert to prevent third parties from using these practices in their relationship with the company.
MQS expressly prohibits payments, gifts or undue attention to any person or entity, public or private, with the intention of obtaining or maintaining business or other benefits or advantages. MQS employees may not make, offer or receive, directly or indirectly, in any case, benefits, gifts or cash gifts. Neither may they perform, offer or receive, directly or indirectly, attention, gifts or attentions that, due to their value, characteristics or circumstances, may reasonably alter the development of commercial, administrative or professional relationships in which they participate. In this sense, MQS employees must apply their professional judgment and common sense to determine the border between what is acceptable and what is unacceptable, based on socially appropriate uses in the different areas of the Group’s operations. In case of doubt, they should always consult with their hierarchical superior or with the channels established by the company for the purpose of compliance with the Code of Ethics.

In this way, gifts and attentions should be received or delivered exclusively on the basis of legitimate interests, complying with the applicable internal and external regulations, and be enjoyed jointly by the recipient and the person who delivers them. In the same way, the gifts and attentions received or delivered should be sporadic; to avoid that regularity could lead an independent third party to doubt its good faith. Additionally, gifts and attentions should be socially acceptable, such that, if publicly known, they will not cause discomfort to the recipient or the person who delivers them. To determine to what extent a gift or service is acceptable in terms of its value, the people of MQS will apply the reciprocity criterion. Whether they are recipients or if they are who gives away, a gift will be acceptable to the extent that it could be reciprocated by the recipient.

In any case, the acceptance of attentions by MQS employees will be free up to an amount of 15 euros. Regarding the business lunch invitations, they cannot be accepted for a value higher than 50 euros or 250 euros accumulated by a company in a year.
MQS employees should ensure not only that gifts and attentions to third parties are provided, reasonable, transparent and legitimate but that they are also properly registered by the company.

Likewise, they will abstain from facilitating payments or expediting procedures, consisting of the delivery of money or other things of value, whatever their amount, in exchange for ensuring or expediting the course of a procedure or action before any judicial body , public administration or official body. Expenses related to administrative procedures are not considered facilitation payments.

6.7 Irregular transactions

The people of MQS should remain alert to those cases in which there may be signs of lack of integrity of the people or entities with which they relate professionally.

In particular, employees of MQS will avoid, in general, cash payments that are unusual, those made through bearer checks or those made in other currencies than those previously agreed upon. They should also avoid payments made to or by third parties not mentioned in the corresponding contracts, as well as those made in accounts that are not the usual ones in the relations with a certain entity, organization or person and with special attention to review those payments not foreseen in the agreements or corresponding contracts.
Also, in general, no payments may be made to persons, companies, entities or accounts opened in countries or places qualified as tax havens by the applicable Spanish regulations, or to entities in which it is not possible to identify the partner, owner or beneficiary latest.

The people who work in MQS will put all their efforts in preventing money laundering. In addition, they will apply the principle of due diligence to avoid collaborating with third parties that could serve as a cover for terrorist or criminal activities.

6.8 Conflicts of interest and loyalty to the organization

MQS employees must conduct themselves with loyalty to the organization.
Conflicts of interest arise when the interests of employees are not aligned with those of MQS, interfere with their obligations or lead them to act for other reasons than compliance with the responsibilities assigned to them.

The relationship between MQS and its employees must be based on loyalty that arises from common interests. In this sense, the organization respects the participation of its employees in other social, financial or business activities, taking into account that the internal regulations do not provide otherwise, that such activities are legal and that they do not compete or cause possible conflicts of interest with their responsibilities as employees of MQS or with the interests of the organization. In any case, the people of the company must previously communicate, through the channels established for this purpose, their intention to develop activities in addition to their responsibilities in MQS and will not be able to take advantage of opportunities that they have had knowledge of in their condition of employees of the organization.

MQS employees must avoid situations that may suppose a conflict between their personal interests and those of the organization. They must also abstain from representing, intervening or influencing the decision-making process in which, directly or indirectly, they or a third party close to them have a personal interest.

Any employee may provide services as a consultant, counsellor, manager, employee or consultant to a competitor of the organization, except for services that may be provided at the request of MQS or with their authorization.

The MQS policy on conflict of interest also extends to the family members of the company’s people. All MQS employees have the obligation to communicate to the organization those circumstances from which a conflict of interest of their own or that of their family could reasonably be derived.
In the same way, MQS employees will not be able to participate in external activities, of any nature, that could have a negative impact on the performance of their work or on the image, public perception and reputation of the organization.

7 Foreign Relations

7.1 General principles

MQS carries out its business in a legally and ethically irreproachable manner and expects the same from its employees. MQS urges its business partners, suppliers and customers to comply with this principle.

The private interests of MQS employees and the interests of the Company must remain strictly separate. A conflict of interest occurs when private interests collide with MQS’s interests, interfere with their obligations or lead them to act for reasons other than compliance with the responsibilities assigned to them.

Monetary benefits from third parties must therefore not be solicited or accepted by any employee, nor must they be offered or given to third parties by any employee. This applies without exception, particularly to individuals holding public office, including those in foreign countries or international organisations. Other types of benefits from suppliers, customers or other business partners may not be solicited.

Token business gifts, business entertainment or other gifts may only be accepted within the bounds of customary business practices, as long as they do not influence corporate decision-making.
These types of benefits may only be given within the bounds of normal customer relations practices, as long as they are not seen as an attempt to gain undue influence.

7.2 Conduct towards shareholders

MQS views the capital of its shareholders as the prerequisite for and foundation of its business activities. Maintaining this capital and delivering fair market returns on it, are therefore MQS’s primary goals. Our conduct towards our shareholders is governed by transparency and responsibility.

7.3 Conduct towards suppliers

In its relationship with suppliers, MQS makes sure to comply with the regulations in the Code of Ethics. MQS therefore does not have business relationships with suppliers who are publicly known to be in violation of the principles underlying the Global Compact. MQS works to further enforce the Global Compact principles in its business relationships.

The people of MQS that participate in selection processes of suppliers, contractors or external collaborators have the obligation to act with impartiality and objectivity adopting the selection criteria adopted by the organization. In the same way, they must take reasonable steps and act diligently to avoid acquiring material of uncertain origin and exercise due control to avoid illegal employment of workers along the supply chain of the company.

No employee of MQS may offer, grant, request or accept, directly or indirectly, gifts or presents, favours or compensations, in cash or in kind, whatever their nature that may influence the decision-making process related to the performance of the functions derived from his position.

In particular, no employee may, without authorization, offer, grant, and request or accept gifts, or presents to / from a natural or legal person with which the Group has relations of any kind which, isolated or added together in the period of one year, have a value greater than 150 euros.

In any case, gifts and cash payments are strictly prohibited.
MQS employees will observe respect for the image and reputation of the organization by contractors and suppliers and, in general, collaborating companies, to avoid undue influences in the selection and hiring processes.

MQS will disseminate the contents and principles of this Code among suppliers and contractors, encouraging them to report irregular practices by persons of the Company who might observe, eventually.

7.4 Conduct towards consultants

MQS will only sign consultancy contracts with individuals or companies whose capabilities will contribute direct benefit to MQS. Such agreements must conform to the following principles:
Consultants will be chosen and employed on the basis of a documented profile of job requirements and specified tasks. The level of compensation must appropriately reflect the value of the services performed and the consultant’s professional qualifications. Payment for consulting services is generally made only after such services have been provided. Cash payments are prohibited. In the fields of corporate, strategic, market and organisational consulting, individual management coaching, and consultancy activities associated with the development of new markets, the management board of the respective operating company must be involved in the decision-making process to appoint a particular individual or company. Agreements with MQS must contain a clause in which agents working on behalf of the company state that the service they provide will not violate any laws, regulations, or the Code.

7.5 Conduct towards the public

All communications of MQS are required to be full, fair, accurate, timely and understandable. MQS respects the professional independence of journalists and media. MQS therefore does not pay for editorial content.

Only authorised persons are allowed to disclose information concerning MQS or its subsidiaries to the public, the media or to other third parties.

7.6 Conduct towards the Political Establishment

In light of its importance for the economy and society, MQS feels that dialogue with representatives of government bodies and political parties is indispensable.

MQS has established the following principles to exclude even the impression that it exercises undue influence:
MQS is non-partisan and does not make contributions to political parties or to organizations and foundations that are closely associated with political parties.
MQS will not employ or undertake consultancy agreements, including “payment for services” agreements, with individuals whose main occupation involves holding a public office or parliamentary seat.
MQS recognizes the shared responsibility of the Company and its employees to the development of the common good. MQS therefore welcomes its employees’ commitment to civic, political and social activities outside of the workplace, particularly charitable and community-based activities. Employees who volunteer their services politically do so as private individuals and not as representatives of the Company. MQS does not pursue its business interests through its employees’ activities in this area.

8 Commitment to Corporate Responsibility

8.1 General principles

Responsible business practice towards society and environment is critical to sustaining the success of the Company. Through its products and services, its investments, and as an employer, MQS plays an essential role in society and in the economy as a whole.

MQS faces its environmental commitment from the strict compliance with the applicable legislation in the matter in all its areas of operation. The organization develops its activities with the greatest respect for the environment and minimizing the negative effects that, eventually, it could cause.
To this end, MQS will establish the best practices and promote among its employees the necessary training to preserve the environment. In its relations with contractors, suppliers or external collaborating companies, it will transmit these principles and will demand compliance with environmental procedures and requirements that are applicable in each case and will provide the means to ensure their proper compliance.

Accordingly, the organization is committed to correct environmentally inappropriate behaviour, or not committed to caring for the environment, which could be detected.

The organization makes a continuous effort to identify, characterize and minimize the environmental impact of its activities and is committed to efficiency, responsible consumption and protection of the natural environment. All the members of the company share their environmental commitment.
MQS continually strives to act as a living part of the community on an international, national, regional and local level. As part of this effort, MQS seeks out dialogue with the groups that are affected by its business activities or whose activities influence the business activity of MQS.

MQS believes it has a special responsibility to promote the development of the regions and communities where it operates, whether it is by providing employee training opportunities that go beyond the company’s own needs, undertaking initiatives of a primarily social, environmental and cultural nature, supporting its employee’s volunteer activities, or by implementing other appropriate measures.
MQS therefore welcomes the involvement of its employees in activities for the common good, as long as their activities are appropriate as regards national, regional or local conditions and do not conflict with the business interests of MQS.

8.2 Sponsoring and community investment

Sponsoring and similar initiatives to contribute to the development of regions or local communities are examples of corporate responsibility. Such initiatives primarily involve financial and other support of activities that are related to the common good and are of a public nature.

8.3 Register

All monetary payments and benefits with monetary value given to holders of public offices or parliamentary seats, public bodies or authorities, charitable organisations or institutions dealing with social concerns are to be recorded in a register. Payment for services occurs through bank transfer. Cash payments are prohibited.

9 Internal Relations

9.1 Occupational health and safety

MQS works to continually improve the occupational safety and health conditions for its employees and the safety of its facilities.

In terms of safety and health, MQS commitment is based on the strict compliance with the regulations applicable in all the environments where it operates, in order to offer its employees a healthy and safe working environment. Likewise, the organization will continuously improve the prevention of occupational hazards and the promotion of health at work in each of the places where it operates.

Every employee is responsible for helping to keep his/her workplace safe and to protect the environment. Every employee must comply with all relevant laws and regulations. All managers are required to instruct and support their employees in fulfilling their responsibilities in this regard. In the event of violations or accidents, the responsible authorities must be notified without delay.

For its part, the organization is committed to providing its employees with the resources and information necessary for them to perform their functions safely and in a healthy environment.

MQS people will refrain from using alcohol or drugs in the workplace. Alcohol can only be served at company meals according to local practices. In addition, of the above, the people of MQS will refrain from accessing their job under the influence of alcohol or drugs.
MQS promotes and encourages the adoption of advanced safety and health practices among its suppliers, contractors and, in general, collaborating companies.

9.2 Commitment to people, respect and dignity of the person

In MQS, the management of human resources and the relationships between employees always start with strict respect for the dignity and rights of people.
MQS employees should be treated in a respectful, professional and friendly way, to create a pleasant, rewarding and safe work environment that encourages people to give their best, with the aim of contributing to an adequate social climate and a respectful coexistence in the relations between the members of the organization. Likewise, they will strive to be open, honest and respectful when sharing ideas and thoughts and in receiving the contributions of others.

In the same way, the relations between the people of MQS and its suppliers, contractors and collaborating companies will be based on respect and collaboration.

MQS employees expressly avoid and reject the abuse of authority, and any type of harassment, physical, psychological or moral, as well as any other conduct that may generate an intimidating, offensive or hostile work environment.

Also MQS employees will remain caring and exercising a proper control to avoid circumstances that might be illegal employment of foreign workers, both within the organization and throughout its supply chain to suppliers, contractors and other business partners.

In the same way, the employees of MQS will remain caring to avoid that there could be cases in which they could be working for the workers organization in an irregular manner, that the payrolls do not reflect the corresponding collective agreements or that they contain erroneous compensation concepts.

9.3 Collaboration and teamwork

In MQS, the collective over the individual prevails. Collaboration and teamwork are essential requirements for MQS to achieve its objectives and to make the most of the capacities, resources and diversity of knowledge, skills and experiences that conforms the organization.

The organization promotes, facilitates and encourages collaboration and teamwork, regardless of the functional area in which they perform their activity.
All employees must show a spirit of collaboration, making available to those who need it their knowledge, skills and talent to contribute in this way to the achievement of the objectives and global interests of the organization.
Likewise, MQS employees work efficiently, taking full advantage and benefit of the organization, time and resources that the organization offers.

9.4 Equal opportunity and mutual respect

MQS respects the dignity and individuality of each and every employee. Workplace interactions should be characterized by mutual respect, fairness, teamwork, professionalism, and openness.
Managers are expected to be role models and competent points of contact, particularly when conflicts arise.

MQS promotes equal opportunity and diversity, which are indispensable to achieving commercial success and to maintaining an excellent reputation as a company.

No employee or job applicant will be discriminated against on the basis of his or her gender, marital status, race, nationality, age, religion, or sexual orientation. Decisions regarding the selection, training, and development of employees are made according to strictly job-related criteria and must be relevant to the job.

High performance is important to achieve business success. MQS is therefore committed to developing individuals who have both the professional and interpersonal skills to help to maintain the sustainable success of the Company. MQS offers opportunities for professional and personal development and encourages employees to take advantage of such offers. MQS endeavours to have its employees achieve a balance between work and private life. Special emphasis is put on reconciling the employees’ family lives and careers.

10 Compliance with the Code of Conduct/Reporting

10.1 General principles

Each MQS employee will receive a copy of the Code of Con-duct. The Code must become a living part of the MQS corporate culture and must be incorporated into the day-to-day work of all employees.

The people of MQS are responsible for knowing, understanding and complying with the rules relevant to their role, responsibility and place of work. The organization, meanwhile, will make available the necessary means to facilitate knowledge and understanding of the regulations and legislation more relevant to the performance of their professional duties and ethical principles set out in this Code, in particular, asks the administrators to actively promote the application of the Code. This involves ensuring that all employees assigned to them are familiar with the Code of Ethics so that they can comply with their regulations in their daily work. The MQS Compliance Committee verifies compliance with the Code, and incorporates the principles of the Code into its review criteria.

In case of doubt or if they observe an irregular behaviour, the employees may appeal to their hierarchical superior and to the Compliance Committee, which has among its tasks to ensure the dissemination, knowledge and compliance with the Ethical principles established in the Code of Ethics and in the norms in which this is supported.

MQS expects from its employees behaviour aligned with the Ethical principles included in this Code and in the standards on which it is based. Complying with the principles and norms indicated is part of the obligations contracted by all MQS employees when they join it.

No MQS employee, regardless of their position in the organization, is authorized to contravene or request another employee to contravene the provisions of this Code of Ethics. In the same way, they cannot justify a bad practice by relying on an indication of a superior or ignorance of the Code of Ethics.

10.2 Notification of irregular acts and Compliance Committee

Irregular behaviour in the matters contemplated in the Code of Ethics could have serious consequences for MQS.

All MQS employees have the obligation to comply with the Code of Ethics and to contribute to its compliance, as well as to consult their doubts and notify irregular behaviours that they could observe. The obligation to inform also extends to those cases in which irregular behaviours can be detected by third parties and, in particular, by suppliers, contractors or collaborating companies.
MQS has a procedure that allows all its employees to inform the organization, in good faith, confidentially and without fear of reprisals, irregular conduct in the matters contemplated in the Code, which refers to matters of a criminal nature and of another nature, and in the Ethical internal rules on which it is based.

The people of MQS can also consult questions or propose improvements in the internal control systems that the organization has in the areas contemplated in the Code or to point out behaviours or areas in which there is a significant risk of irregular acts.

Ultimately, the responsibility for ensuring compliance with internal rules of the organization must be carried out by the board of MQS, which delegates the management of issues related to knowledge, understanding and compliance with the Code of Ethics on the Compliance Committee.

Among the responsibilities that the Compliance Committee assumes in matters related to the Code is the supervision of the procedure established for the notification of irregular conduct. In this way, the Committee is assigned the following functions:

· Ensure the proper functioning of the notification and consultation procedure for the communication of irregular conduct in matters that are relevant from a criminal point of view or of any other nature.

· Process the notifications received about irregularities in matters covered by the Code of Ethics, control their resolution according to the procedure defined for that purpose and resolve any doubts that may arise from the application or interpretation of this Code of Ethics.

· Promote knowledge and understanding of the Code in the organization.

· Report regularly to the board of MQS about the degree of compliance with the Code of Ethics, proposing the recommendations it deems necessary.
Employees will send their communications in matters related to the Code of Ethics, confidentially, in good faith and without fear of reprisals, to the Compliance Committee through the web:

https://canalresponsable.marcafranca.com/canaletico/presentacion_cliente/5674984663941120

The Compliance Committee will resolve the doubts regarding the application or interpretation of the Ethical principles contained in the Code of Ethics. In its resolution it will have the collaboration of the functional areas of MQS specialized in the different subjects. The resolution of the irregularities notified and the possible sanctions that are accompanied will be resolved according to the specific procedure established for that purpose.

If the Compliance Committee considers that the irregularities that are communicated may constitute “irregularities of potential importance, especially of a penal, financial and accounting nature,” could decide to transfer them to the board of MQS, who will decide the best way to solve them.

All notifications will be anonymous, and will be evaluated and treated confidentially. The data of the involved parties may be subject of communication only in the case that the event denounced could result on the initiation of proceedings by the administrative or judicial authorities and to the extent that they are required by such authorities, as well as in compliance of the European Data Protection Regulation, and, where applicable, the persons involved in any subsequent investigation or judicial proceeding initiated as a result of the investigation.

MQS will not tolerate any reprisal committed on those persons who make use of the established procedures for the communication of irregular acts.
All MQS personnel in charge of managing matters related to the Code of Ethics will pay the highest attention to ensure the right to honour people.

11 Responsibilities

The people of MQS are responsible for knowing, understanding and complying with the Ethical principles included in the Code of Ethics. Those employees who have managerial or team management responsibilities have some additional responsibilities.

In this way, the people of the organization must:

· Know, understand and comply with the Ethical commitments included in this Code, as well as with the rules and procedures applicable to their positions.

· Contribute, as far as possible, to the knowledge, understanding and compliance with the Code.

· Request help in case of doubt.

· Report irregular behaviours that may be observed.

· Provide collaboration in the proper functioning of the internal control systems implemented by the organization to ensure the compliance with the Code of Ethics and other internal rules of the organization.

· The people of MQS who have entrusted management functions or directives have additional responsibilities regarding the Code of Ethics:
· Collaborate, within its scope of responsibility, in the knowledge, understanding and compliance with the Code of Ethics and the rules and procedures in which it is based.
· Contribute to generate the desired ethical tone in the organization, helping the organization to know the expected behaviours.

· Provide support to those persons who, in good faith, report irregular conduct in the matters contemplated in the Code of Ethics, maintaining confidentiality and protecting them from possible reprisals.

· Observe a professional conduct that serves as an example and a reference for all the workers of MQS. Your behaviour should be an example to follow.

12 Information and help

The Code of Ethics includes the expected behaviour guidelines of the people who are part of MQS.

In case of doubt, employees may obtain help from their hierarchical superior or the Compliance Committee.

If they need specific advice on the topics included in this Code, employees can also use functional areas and departments of the organization that specialize in these matters.

13 Effectiveness of the Code

The Code of Ethics will enter into force once it has been approved by the board of MQS and will be applicable until its update, revision or repeal is approved.

The Code will be revised and updated as indicated by the board of MQS. Any revisions and updates will comply with the commitments acquired by MQS in matters of ethics and good governance and new obligations that may arise from regulatory changes and will be communicated to all personnel.

14 Verification of the Rules

MQS employees have to confirm every year that they have been complying with company rules.

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