Ethical Code Bonpilates S.L.

Leading Spanish manufacturer of Pilates equipment

INTRODUCTION

This Code of Ethics, hereinafter referred to as the ‘Code’, is the mandatory guide to ensure ethical and appropriate behaviour in the professional development of its management and administrative bodies, staff and third parties, in accordance with established laws and regulations. It is the reflection of how the management expects not only the entity but also each of its members to behave, compiling the values, principles and ethical and conduct guidelines that make up the organisational culture of Bonpilates, S.L., hereinafter ‘Bonpilates’.
El presente Código Ético, en adelante el «Código», es la guía de obligado cumplimiento para garantizar un comportamiento ético y adecuado en el desarrollo profesional de sus órganos de dirección y administración, personal y terceros, de acuerdo con las leyes y reglamentos establecidos. Es el reflejo de cómo la dirección espera que se comporte no sólo la entidad sino cada uno de sus miembros, recogiendo los valores, principios y pautas éticas y de conducta que conforman la cultura organizativa de Bonpilates, S.L., en adelante ‘Bonpilates’.
This Code of Ethics, hereinafter the ‘Code’, is the mandatory guide to ensure ethical and appropriate behaviour in the professional development of its management and administrative bodies, staff and third parties, in accordance with established laws and regulations. It is the reflection of how the management expects not only the entity but also each of its members to behave, reflecting the values, principles and ethical and conduct guidelines that make up the organisational culture of Bonpilates, S.L., hereinafter ‘Bonpilates’.
This Code was approved on 26 March 2021 at the Universal General Meeting of Shareholders.

STANDARDS OF CONDUCT

In relations with partners

Bonpilates conducts its business in accordance with the interests of society and with standards of transparency and correctness of corporate management, so as to ensure:
(i) Management efficiency and the validity of the control of objectives and activities in the corporate sphere.
(ii) The reliability and correctness of the accounting records, which allows the issuance of balance sheets and results with full transparency and in compliance with current regulations.
(iii) Compliance with tax and social security regulations, avoiding risks and inefficiencies in the execution of business decisions.
(iv) The safeguarding of corporate assets.

In relations with authorities and civil servants.

Bonpilates and its employees deal with public authorities and institutions in a lawful and ethical manner, respecting at all times the international provisions for the prevention of corruption and bribery.
No employee may offer, promise, grant, solicit or accept, directly or indirectly, any unlawful payment or other advantage, favour or compensation, of whatever nature, to or from any authority or official. The only exceptions are gifts and hospitality of small value that are proportionate and reasonable according to local practice, given for a legitimate, socially acceptable and sporadic interest, in such a way that they cannot cast doubt on the good faith of the employee or Bonpilates. Cash gifts are expressly prohibited.
Bonpilates collaborators shall refrain from making payments, in any form whatsoever, to facilitate or expedite procedures or proceedings before any judicial body, public administration or official body.

In employee relations

Bonpilates upholds and promotes respect for the human and labour rights recognised in the legislation in force at all times and undertakes to apply the regulations on employment conditions, health and safety in the workplace.
Bonpilates promotes non-discrimination on the grounds of race, colour, nationality, social origin, age, sex, marital status, sexual orientation, ideology, political opinions, religion or any other personal, physical or social condition of its professionals.
The evaluation of staff is carried out in accordance with the principle of equal opportunities for all concerned, respecting at all times the private sphere and the views of the candidates and avoiding favouritism in the selection and recruitment phases.
No form of illegal recruitment is accepted.
All employees are obliged to comply with applicable labour standards and to act in their working relationships with other employees in a respectful, dignified and fair manner, not allowing any form of violence, harassment or abuse at work or discrimination on the basis of race, religion, age, nationality, gender or any other status.
Access to functions and positions is established on the basis of competencies and capacities, avoiding forms of nepotism, and giving priority to the overall efficiency of the work.
At Bonpilates, the protection of its own financial, asset and human resources is a priority, and to this end it is constantly seeking the necessary synergies, not only internally, but also with suppliers, partners and customers involved in the development of its activity.
All Bonpilates employees must:
(i) Respect the obligations set out in his or her employment contract and all the provisions of this Code.
(ii) Avoid situations where conflicts of interest may arise.
(iii) Refrain from personally benefiting from business opportunities of which information has come to their knowledge in the course of their own duties.
(iv) act diligently to safeguard Bonpilates’ assets, and responsibly and in accordance with the operating procedures established to regulate their use.

In customer relations.

Bonpilates is committed to competing in the marketplace in a lawful manner by ensuring high standards of quality and wholesomeness in its products and services and by striving to promote consumer education and the fight against deceptive practices.
Bonpilates’ communications to its customers are made without pressure and without the use of misleading or false advertising tools, and the treatment of its customers is carried out under criteria of respect and courtesy.
Bonpilates deals with suggestions and complaints made by customers by using the appropriate communication systems and by taking care to inform customers of the time, which will in any case be short, needed to provide them with a response.

In supplier relations.

Bonpilates staff and its collaborators deal with suppliers of goods and services in a fair, ethical and respectful manner.
Purchasing and procurement procedures are based on the search for the greatest competitive advantage, but guaranteeing equal opportunities among suppliers. The key criteria for the selection of suppliers are based on objectivity and transparency, reconciling Bonpilates’ interest in obtaining the best conditions with the convenience of maintaining stable relationships with ethical and responsible suppliers.
Maximum transparency and efficiency of the procurement process is ensured, in accordance with the adopted ethical standards and principles.
Neither Bonpilates staff nor any employee may offer, grant, solicit or accept, directly or indirectly, any gift, favour or compensation, of any nature whatsoever, that may influence decision-making in relation to the performance of the duties arising from their position.

In relations with society

Bonpilates is firmly committed to the principles that govern a policy of crime prevention, anti-fraud, anti-money laundering, anti-corruption and anti-bribery.
Bonpilates and its collaborators develop environmental policies that minimise the environmental impact at each stage of the production process, minimising waste and pollution, conserving natural resources and promoting energy saving.

Confidentiality of information and protection of personal data.

Bonpilates staff may not use for their own benefit or communicate to third parties any data, information or document obtained during the course of their professional activity which, unless otherwise indicated, must be considered confidential and may only be used for the purpose for which it was obtained.
Likewise, the information may not be duplicated or stored in information systems that are not the property of Bonpilates and you are obliged to return it upon termination of your working relationship with Bonpilates.
When collecting personal data from customers, employees, contractors or any person or entity with whom a contractual or other relationship is maintained, Bonpilates staff undertakes to use them in accordance with the purpose for which they were obtained, respecting the internal procedures designed to ensure the different levels of security required.

ETHICS AND COMPLIANCE MAILBOX

Bonpilates, for the sole purpose of promoting compliance with the law and the rules of conduct set out in this Code, has set up an ‘ethics mailbox’ at the following e-mail address: [email protected].
Complaints will be received and processed by the Compliance Department, which will treat the identity of the person reporting the anomaly as confidential information. Likewise, any data provided will be included in a personal data file. In investigation processes, Bonpilates guarantees the rights to privacy, defence and the presumption of innocence of the persons under investigation.
Compliance is responsible for disseminating the content of this Code and for evaluating and issuing an annual report on its degree of compliance, which will be reviewed and updated periodically, taking into account the periodic Compliance report, as well as the suggestions and proposals made by employees, collaborators and third parties.

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