Code of Ethics, Professional Conduct
and Anti-Corruption

1. Objective

Warpcom adopts this Code of Ethics, Professional Conduct and Anti-Corruption, hereinafter referred to as the Code, which includes a set of Values, Principles, Rules of Conduct and Professional Ethics, transversal to the entire organization.

The adoption of Values, Principles, Rules of Ethics, Professional Conduct and Anti-Corruption is essential for Warpcom and its Employees to act with integrity and consistency in conducting their relationships with the different interest groups they deal with on a daily basis, and guarantee the articulation necessary for common success. This Code is therefore intended to regulate the actions of Warpcom employees with society, customers, suppliers, service providers and third parties in general.

2. Field of Application

The values and principles that have been included in this Code emanate from Warpcom’s vision and objectives. The trust of customers and the market is ensured through relationships guided by ethical behavior and exemplary conduct.

All employees must act in a way that reflects the values, principles and rules of ethics and conduct expressed in this Code.

3. Definitions

N/A

4. Description

Warpcom has its employees as its greatest asset. It recognizes and values the contribution of each one, seeking to establish and maintain an environment of trust, with clear, open and constructive communication. The Human Resources policy is available on Sharepoint for internal consultation.

Warpcom is committed to developing work of excellence and improving knowledge, technical competence and professional performance both individually and collectively. We seek to assess your needs, understand your expectations and satisfy both.

Warpcom defends the fundamental and essential principles for a democratic society, based on equality, transparency, free competition, impartiality, legality, integrity and fair redistribution of wealth.

All Warpcom employees must feel responsible for achieving the highest standards of integrity, ethics and professionalism.

4.1 Warpcom’s Mission and Vision

4.1.1 Mission

We foster close and trusting relationships with the aim of contributing to technological evolution. We work with enthusiasm, committed to creating value and exceeding the expectations of our people, partners and clients, actively contributing to their development.

4.1.2 Vision

We work daily to be the leading company in the design, development, integration and management of technological solutions, enhancing the evolution and competitiveness pf our client´s businesses and making us a benchmark, innovative company with a dynamism capable of impacting its ecosystem.

4.2 Warpcom values

The values that define Warpcom’s DNA are:

Trust – Over the years we have established trusting relationships with our team, our clients and partners.
Excellence – Excellence is at the heart of everything we do!
Proximity – We work with a management close to the team, that allows the continuos evolution of our people, contributing to the transformation of our client´s business.
Commitment – It is with dedication and commitment that we develop our teams relationships, and with clients and partners, actively contributing to the success of their journey.
Integrity – Honesty and transparency are the pillars on which an ethical and inclusive work culture is based, which aims to protect both the people and business.

4.3 Work Environment

4.3.1 Labor Relations

In all its operations, Warpcom seeks to build constructive relationships with recognized unions or other legitimate employee representatives.

4.3.2 Health and Safety

The company commits to provide all employees with a good working environment, both in terms of hygiene and safety. Warpcom provides means that allow its employees to report all situations that may constitute a potential danger.

4.3.3 Drug-Free Environment

The possession, distribution or use of any illicit substance, as well as the abuse of alcohol or medication on Warpcom premises is expressly prohibited.

4.3.4 Copyright/Intellectual Property

All employees are aware of and are responsible for legal compliance regarding the use of software licenses used in the performance of their duties.

4.3.5 Environmental Concerns

Warpcom recognizes the value of a clean and healthy environment and is committed to maintaining it. The health and safety of our employees, customers and the surrounding community is paramount in everything we do. We are committed to reducing waste and minimizing this impact on the environment. We are dedicated to energy reduction, recycling and other waste management methods.

The company takes environmental issues into account in its business and complies with all laws and regulations on this topic.

4.3.6 Discrimination

Warpcom promotes equal employment and does not discriminate on the basis of race, color, religion, gender, age, national origin, sexual preference, disability or any other discriminatory factor.

Warpcom is an inclusive company that will provide and adapt working conditions in order to provide equal conditions for all.

4.3.7 Harassment

Warpcom guarantees a work environment free of harassment (moral and/or sexual). We have implemented our Whistleblower Channel, which is available on the institutional website.

4.3.8 Personal Data

All employees who, in the performance of their duties, have access to personal and confidential data of other employees or customers, suppliers or third parties with which Warpcom establishes a relationship, are subject to professional secrecy and must guide their behavior with the utmost discretion.

4.4 Use of Warpcom facilities and assets

All employees must make good use of Warpcom’s facilities, reporting any situation they consider anomalous. All Warpcom assets, including information, know-how, must be used exclusively for professional purposes.

4.5 IMS Policies

The quality, environment, OHS and service management policy, as well as the information security policy, are available on Sharepoint for internal consultation and on Warpcom’s institutional website for external consultation.

These policies are included in the IMS manual where their approval is formalized. These policies must be known and respected by all employees.

Warpcom has implemented an Integrated Management System, based on 5 normative references, namely:

ISO 9001
ISO 14001
ISO 45001
ISO/IEC 20000-1
ISO/IEC 27001

This System is composed of procedures and policies that guarantee the best market practices in the relationships established with customers, suppliers and partners, or other interested parties.

4.6 Professional Ethics

4.6.1 Financial Practices

Warpcom repudiates any form or manifestation of corruption, which, within the scope of the Civil Convention on Corruption of the European Council, adopted on 11/04/1999 and in force since 11/01/2003, was defined as “the act of requesting , offer, give or accept, directly or indirectly, an illegal commission or any other advantage that is not due or the promise of such an undue advantage that affects the normal exercise of a function or the required behavior of the recipient of the illegal commission, undue advantage or of his promise”.

We have implemented our Whistleblower Channel, available on the institutional website, as well as publicized our Risk Prevention Plan for Corruption and Related Offenses.

4.6.2 Money Laundering

Warpcom has implemented instruments that allow the prevention of illicit commercial practices, including Money Laundering and Corruption, or other similar practices.

4.6.3 Conflicts of Interest – Incompatibility of Employees

Situations that should be avoided:

Having an outside interest, activity or other employment that does not allow the employee to work full time for Warpcom. Any external interest must be disclosed by the employee during the recruitment process or as soon as it becomes relevant if later than that time;
Having a financial interest in having employment with or serving on the governing bodies of a company that is a competitor of Warpcom or a company with which Warpcom does business;
Provide consultancy services to one of our Clients or Suppliers;
Doing business with an entity owned by a colleague or a family member without the prior consent of the company;
Any other commercial relationship with third parties or with a person who may influence third parties and which results in a gain for the employee, friend or family member and which harms the company.

4.6.4 Commercial agreements

With the aim of providing the most appropriate solutions to the needs of customers and the market, Warpcom is continually committed to partnerships and commercial agreements with technology and innovation leaders as a guarantee of quality and technological independence.

Warpcom’s partnership strategy focuses on delivering added value to our customers’ business, taking into account their reality, their specific needs and market trends.

All our commercial agreements with clients or potential clients must be fair, honest and impartial. We acquire or retain business based on the high quality of the services we provide and the competitive prices we charge.

We must advertise our services on the market using our skills, certifications, prices and value to the client.

4.6.5 Sponsorships and donations

What is meant by:

Sponsorship: the act of financially supporting a project or initiative presented by an organization external to Warpcom, either through payment of money or another type of contribution in kind, in exchange for the association of a brand image, for advertising purposes, or in return for a benefit with a similar purpose.
Donation: value that is passed on free of charge to another person or organization, which accepts it.

Sponsorships and donations must always be made in accordance with the provisions of the applicable legislation and must never be linked, directly or indirectly, to illegal acts or undue benefits for Warpcom.

It is forbidden for donations to be intended, or to be interpreted, as having the intention of conditioning the bidding for contracts or any other benefit in favor of Warpcom.

The Finance Department manages and controls all sponsorships and/or donations made by Warpcom.

4.7 Anti monopoly

4.7.1 Anti monopoly laws

Anti-monopoly laws were created to preserve free competition. Anti-competitive behavior is prohibited in many countries and, in particular, in the United States and the European Union. This means that any contract entered into by Warpcom must be compatible with the Anti-monopoly Laws.

Anti-monopoly laws regulate 3 types of conduct:

Restrictive Practices or Agreements
Please note that the term “Agreement” means more than a formal written contract. A tacit understanding between companies or individuals may be enough for regulators to find that competition law has been broken. A restrictive agreement can exist between competitors or between companies operating at different levels in the supply chain (e.g. industry and commerce or industry and retail). An example of a restrictive agreement could be price fixing or a territorial restriction.
Abuse of dominant position
Anti-monopoly laws were created to prevent companies from behaving in a way that leads to the extinction of competitors or the exploitation of customers.
Acquisitions, Mergers and Joint Ventures
Transactions such as these must be subject to government review to ensure that the new business will not restrict competition.

Breaches of anti-monopoly laws can result in severe financial penalties. Breaches can potentially occur in any area of our business, but most often in relation to the sales and marketing of our services. In particular, prices, discounts, advertising, sales conditions and markets should not be discussed with competitors.

4.7.2 Trade associations

Participating in trade associations can be advantageous and legitimate, but you should always make sure that they are not used for questionable purposes. You should immediately leave any meeting of any association if you find that competition laws are being broken.

4.7.3 Coopetation with authorities

It is Warpcom’s policy to cooperate with all competent authorities when they inquire about our business practices, while defending our interests, and to cooperate with any inquiry or investigation carried out by competent authorities.

4.7.4 Getting Information about others

You may not obtain or attempt to obtain confidential information about our competitors’ businesses or confidential information by improper means. Industrial espionage, violation of the rights of others, surreptitious tapping of telephone calls and theft are illegal.

Improper requests in any form for confidential data from a competitor or a competitor’s customer violate our policy.

Any information provided by third parties or of external origin must be kept secure and handled in accordance with the defined classification. In the absence of classification, we must adopt the highest degree of classification in our methodology and in accordance with I-35-CSI-Classification of information.

4.8 Corruption and Bribery

Warpcom repudiates any practice of corruption or bribery, actively or passively, as well as any other forms of undue influence or illegal conduct, in all internal or external relations, with public or private entities.

Any behavior that may constitute a crime of corruption or related offenses is expressly prohibited, in accordance with P-54-RGPD – Plan for the Prevention of Corruption and Related Offenses.

It is expressly prohibited for all Warpcom Employees, in the performance of their duties and within the institutional scope, to promise, offer, demand, receive or imply that they intend to receive any type of Benefits, both to public and private entities, with the aim of obtaining preferential treatment or an advantage , or exert some kind of influence, in a certain commercial decision, business or official act.

The development of events and/or activities without any compensation for the company and other interested parties is excluded from the aforementioned prohibition.

4.9 Political Entities

It is forbidden to support financially or in kind, under any circumstances, political parties, candidates for political office and organisations or individuals whose mission is essentially political.

4.10 Non-compliance

Non-compliance with the rules established in this Code represents a violation of the duties of the Employee, Partner or Supplier, and may lead to awareness measures, as well as, and after an internal process (investigation, analysis and report preparation), lead to the application of disciplinary measures and/or resolution of contracts, appropriate and proportionate to the offense committed and/or resulting in criminal and/or civil liability.

The crimes defined in this Code are punishable in accordance with the legislation in effect.

4.11 Communication of Irregularities

The communication of any signs of non-compliance with this Code must be done through the Whistleblower Channel available on the institutional website.

Any communication shall be treated as confidential, unless its author expressly and unequivocally requests otherwise.

The communication does not preclude or replace the obligation to report in cases and under the terms determined by criminal law and criminal procedure.

For more information about the Whistleblowing Channel, consult the FAQs of the respective channel.

Direct or indirect retaliation against any whistleblower who has reported any violation of this code is not permitted.

4.12 Penalties

Failure to comply with the Code or the practice of incorrect conduct will subject the Warpcom employee to the application of disciplinary sanctions, under the legal terms.