Code of Ethics

 

1. Purpose and scope.

APTA SOLUTIONS & PARTNERS, S.L. (hereinafter APTA) is a company based in Valencia, founded in 2004 as a Limited Company, operating internationally and endowed with legal personality and full capacity to act in pursuit of its objectives.

APTA is part of the Tricise group, the largest value-added alliance in Europe and Latin America for Broadcom enterprise and mainframe software solutions. This strategic alliance has enabled APTA Solutions & Partners and the group’s subsidiaries (Tricise Iberia SL, Tricise SAS, and Tricise SRL) to offer a wide range of specialized technological services and solutions, tailored to the needs of the respective regional markets in which they operate.

Our mission is to provide innovative and personalized technological solutions that drive the growth and efficiency of our clients. We are committed to delivering high-quality services based on integrity, excellence, and collaboration, helping our partners and clients achieve their strategic objectives, always prioritizing people.

In the pursuit of improvement and excellence, the current Administration of the Company has decisively promoted the implementation of the values that should underpin the company’s behavior and guide the conduct of all its employees and managers.

Moreover, and as it could not be otherwise, these principles will determine the type of relationships the company expects all its employees to maintain with clients, suppliers, contractors, or collaborators, as well as with public administrations and society in general.

These principles are embodied in this Code of Ethics, applicable to both APTA and all its subsidiaries, which systematically sets out the principles and values that must govern the actions of all members of the entity, as well as demonstrate to society the commitment to transparency, honesty, and professionalism of those who compose and lead it, who will always adopt ethical and socially responsible behavior in accordance with the applicable legislation in all their areas of activity.

This Code of Ethics aims to develop and expand the scope of these commitments of APTA as a legal entity and its administrators.

This Code of Ethics sets out the principles with which APTA identifies and intends to make a reference and guideline for its actions in society. In developing these, it defines the role and establishes the basic rights and obligations of its governing bodies, as well as all members of the entity, regarding their internal sphere, also indicating their social responsibility commitments, guiding their relationships with clients, suppliers, and external collaborators, and relationships with public and private institutions and society in general.

The background on Good Corporate Governance issued by international, community, and national organizations, mainly aimed at listed public companies, coincide in the essential principles that should guide the governance of a company such as APTA.

For this reason, this Code of Ethics, in its preparation, in addition to considering APTA’s current strategic orientation, has been inspired by reference texts in the national landscape, such as Law 19/2013, of December 9, on transparency, access to public information and good governance, and Law 1/2014, of June 24, as well as the Spanish Strategy for Corporate Social Responsibility 2014-2020 approved by the Government of Spain on October 23, 2014, those issued by the International Labour Organization or the United Nations Global Compact, all while considering APTA’s own uniqueness.

2. Scope of Application.
This Code of Ethics and Good Governance apply to the APTA Administration body, management positions, and all personnel providing services in said company.
The conduct guidelines contained in this Code affect all companies participated by APTA in which it has management control, as well as other entities and organizations linked to APTA.
APTA will promote the adoption of principles and values like those of this Code in those companies in which it participates even without control; as well as among its clients, suppliers, contractors, and collaborators.

3. Purpose.
This Code of Ethics aims to implement the achievement of the company’s objectives and purposes through the creation of conduct guidelines inspired by the values of ethics, honesty, and professionalism, as well as the creation of the necessary instruments for achieving the entity’s principles and objectives, as defined below.

The assumption by all members of APTA of this Code of Ethics entails strict compliance with current legislation both in the exercise of the functions that any representative and/or member of the company carries out, and in the contribution of their opinions and proposals that facilitate the administration body’s decision-making in line with the company’s objectives.

But this Code of Ethics also aims to go beyond legal and statutory obligations, as it seeks to determine the principles and conduct guidelines that should serve as a reference for APTA, both internally, regarding the rights and obligations of all those who make up the organization, and externally, in its relationship with public administrations, clients, suppliers, and society in general.

The drafting and approval of this Code of Ethics responds to APTA’s voluntary decision to self-impose an ethical code of conduct concerning the performance of its activity based on transparent management in achieving APTA’s purposes and objectives.

This Code of Ethics aspires to guarantee the trust of public administrations, clients, suppliers, and society in general towards APTA’s administration and management body and the decisions emanating from them.

4. The principles of APTA.
Apta will act in accordance with the following principles:

a. Respect for legality and transparency in management.
APTA undertakes to comply with all applicable laws in the development of its activities and to observe ethical behavior in all its actions.

This commitment is also transferred to all APTA employees, who must also avoid any conduct that, without violating the law, could harm APTA’s reputation and negatively affect its interests.
All employees must know the laws that affect their work and, in case of doubt, should request additional information from their superior or the appropriate person in each case.

All employees involved in the registration, preparation, review, or reporting of financial information must know and comply with both legal regulations and internal control standards and procedures affecting their work to ensure the reliability of the financial information issued.
No employee will knowingly collaborate with third parties in violating any law, nor participate in any action that compromises respect for the principle of legality.

b. Respect for people.
APTA rejects any manifestation of physical, psychological, or moral harassment or abuse of authority, as well as any conduct that may create an intimidating or offensive environment regarding people’s rights.

APTA employees must treat each other with respect, fostering a pleasant, healthy, and safe work environment.

All employees are obliged to treat their colleagues, superiors, and subordinates fairly and respectfully. Similarly, relationships between APTA employees and those of collaborating entities will be based on professional respect and mutual collaboration. APTA promotes and respects the rights of freedom of association and collective bargaining in the workplace.

c. Equal opportunities.
APTA promotes real equality of opportunity in the professional development of all its employees, avoiding any scenario of discrimination based on age, race, sex, religion, political opinion, national ancestry, sexual orientation, social origin, or disability. It also ensures compliance with International Labour Organization provisions, especially regarding minors, not allowing any relationship with child labor.

All employees are obliged to comply with the above principle of non-discrimination.
The selection and promotion of employees are based on competencies and performance, as well as merit and ability criteria defined in job requirements and the principle of diversity. APTA will promote the professional development and advancement of its employees.

Working conditions that prevent sexual harassment and harassment based on sex will always be promoted. Likewise, respect for real equality of opportunity between women and men will be promoted, avoiding any scenario of direct or indirect discrimination.

d. Occupational health and safety.
APTA has implemented occupational health and safety policies and adopted preventive measures established by current legislation to provide workers with a work environment respectful of their health and safety.

APTA will also apply this health and safety policy to collaborating companies and suppliers with whom it operates.

All APTA employees must know and comply with occupational health and safety regulations and ensure their own safety and that of other employees, clients, suppliers, collaborators, and, in general, all people who may be affected by their activities.

e. Collaboration and responsibility.
APTA promotes a collaborative and teamwork environment for better use of capabilities and resources, committing to provide its employees with the necessary resources for their activities.
All employees must collaborate with each other, making available to the entire organization the knowledge and resources they have, committing to use them responsibly and assuming the duty to preserve them from any misuse that could harm the company’s interests.

f. Corporate reputation and image.
APTA considers its corporate image and reputation as one of its most important assets and a means of generating trust among its clients, employees, suppliers, authorities, and society in general.

All employees must take the utmost care to preserve the company’s reputation and image in their activities in general, ensuring that this principle is also respected by employees of client companies, collaborators, or suppliers.

g. Loyalty to the company.
APTA considers that the relationship with its employees should be based on loyalty arising from common interests, and in this sense, APTA respects the participation of its employees in other activities, provided they are legal and do not compete unfairly or conflict with their responsibilities as APTA employees.

In situations where there may be any doubt, the employee must inform the company of such activity to avoid any suspicion of conflict of interest.

h. Anti-corruption measures.
APTA declares itself opposed to corrupt practices in all their forms, including extortion and bribery, committing to reject them outright against any person or entity.

APTA employees are obliged to respect all applicable laws to the company and may not, under any circumstances, encourage or tolerate bribes from third parties to the company or its employees or vice versa.

APTA employees may not accept, offer, or deliver, either directly or indirectly, any cash or in-kind payment, nor obtain any other kind of benefit from a person serving or acting on behalf of, directly or indirectly, a public or private entity to maintain illicit or unethical business or advantages.

In invitations or courtesies made by the company, austerity rules will be observed, which in no case may be interpreted outside the general rules of courtesy.
Employees must confidentially report any situation, incident, or behavior they consider irregular so that the corresponding investigation can be initiated.

i. Environment.
APTA is committed to the preservation and respect for the environment, which has materialized by opting for the best environmental practices in the development of its activity, through the prevention and minimization of adverse environmental impacts, committing to comply with all current regulations on environmental protection.

APTA has adopted its own Environmental Policy based on prevention, respect, and sustainability criteria.

All APTA employees must know and apply these policies and strive to minimize the environmental impact resulting from their activities and the use of facilities, equipment, or work means.

j. Quality.
APTA is committed to quality in the provision of its activity, seeking business excellence, and therefore has implemented its own quality policy. All employees must know the approved procedures and have as a general objective to achieve the highest standards of quality and excellence in the provision of services.

k. Information and knowledge.
All information and knowledge generated within the company is the property of APTA, within the terms provided by current legislation.

All non-public information used by company employees is considered reserved, confidential, and/or for internal use and, therefore, may not be used by employees outside the scope of professional performance and must refrain from using it for their own benefit or that of third parties.

Employees must transmit the information they handle truthfully, rigorously, and completely, avoiding the transmission of information that may mislead.

All employees must know the legislation on data protection and are obliged to comply with it in the performance of their duties.

APTA undertakes to request, use, and retain only the data necessary for effective business management, respecting the legal provisions on the matter.

l. Relationships with suppliers, clients, contractors, and collaborators.
APTA undertakes to share these principles with its suppliers, clients, contractors, and collaborators, doing everything possible to include them in the contracts formalized with them in each case.

5. Dissemination and compliance.

APTA will disseminate the Code of Ethics among all its employees, suppliers, clients, contractors, and collaborators, as well as to society in general, for which it will be published on the company’s website.

APTA expects a high degree of commitment from all its employees in complying with the Code of Ethics, and compliance may be evaluated accordingly. Non-compliance may result in sanctions in accordance with applicable legal regulations and agreements.

APTA also undertakes to require full compliance from suppliers, clients, contractors, and collaborators to the extent that it affects them.

6. Ethics Committee.

An Ethics Committee is created as a collegiate consultative body generally responsible for ensuring compliance with this Code of Ethics, with the following powers:

a) Promote the dissemination and knowledge of this Code, interpreting any doubts that may arise in its application.
b) Examine and ensure compliance with this Code.
c) Make proposals for improvement in good governance, issuing reports it deems appropriate, both ex officio and at the request of company representatives, to keep it updated and facilitate its application.
d) Issue compliance reports on this code and any others required by company managers or established in applicable regulations.

The Ethics Committee will be composed of two company managers, preferably from the areas of People Management, Information Security, and/or Quality and Environment.

The Committee will always guarantee confidentiality in the processing of complaints received, and no reprisals of any kind will be admitted against employees who report breaches in good faith.

The Committee is also obliged to respect the rights of persons allegedly involved in a possible breach.

APTA has established an ethical channel to report irregularities related to the Code of Ethics. The contact method must always be visibly announced.

7. Validity.

The Code of Ethics will enter into force upon its publication on the website and dissemination to employees and will remain in effect until its repeal is approved.

 

Valencia, February2026

 

Signed:  Management Board