Suppliers´ code of ethics

CreaMNN aims to promote human rights in its relations with suppliers. Therefore, CreaMNN strives to work with suppliers that have human rights policies and procedures consistent with ours, which essentially specify the following for suppliers:

The User must refrain, inter alia, from:

Ensuring that its employees are recruited in accordance with current employment and migration law, international conventions and other employment laws and regulations, regardless of the jurisdiction of origin or destination.

Ensuring that employees are treated with respect and dignity, guaranteeing a working environment in which diversity and inclusion are promoted and in which discriminatory attitudes are not tolerated.

Fostering respect for and compliance with occupational health and safety rules in accordance with current legislation, providing its workers with a safe and risk-free environment and promoting accident prevention amongst all the staff.

Providing employees with a fair salary that is at least equal to the legal minimum or that established by collective agreement if higher.

Respecting working hours such that they do not exceed the maximum hours permitted by the applicable law.

Respecting the freedom of association of its employees and particularly with regard to collective bargaining, without any adverse consequences or reprisals arising from their exercise.

Ensuring that it complies with ILO Convention No. 138, on the minimum age for employment, and with ILO Convention No. 182, on the elimination of the worst forms of child labour and ensuring that minors are not recruited in accordance with those conventions.

CreaMNN will notify the supplier when it becomes aware that it has committed serious human rights violations to ensure the prevention, mitigation and promotion of the repair of harm caused. CreaMNN must refrain from operating with those suppliers that do not demonstrate progress in this area. CreaMNN also strives to support human rights in its supply chain by promoting actions and practices that are consistent with the UN Guiding Principles on Business and Human Rights and objectives included in the CreaMNN Commitment on Human Rights.

Environmental protection, sustainability and the aspiration to "eco-efficiency" are a priority for CreaMNN. The group of which CreaMNN is a member has developed an environmental policy and has adhered to the main international commitments in this area: Environmental protection, sustainability and the aspiration to "eco-efficiency" are a priority for CreaMNN. The group of which CreaMNN is a member has developed an environmental policy and has adhered to the main international commitments in this area:

UN Global Covenant

UNEP-FI

Ecuador Principles

CDP (Carbon Disclosure Project)

Principles for Responsible Investment

CreaMNN suppliers agree not to perform environmental actions that are contrary not only to applicable law but also to those international commitments.

Unless expressly authorised by the clauses governing the legal relationship between the supplier and CreaMNN, the use of subcontractors by the supplier is not permitted. In those cases in which this possibility is envisaged, suppliers must ensure that, when their supply chain provides products or services to CreaMNN, it is aware of, understands and complies with the standards contained in this Code. To do so, suppliers must implement the measures they consider appropriate to monitor their supply chain and mitigate any potential adverse impact on CreaMNN's reputation or integrity.

Additional controls may be established in the clauses governing the legal relationship between the supplier and CreaMNN (general terms, contracts, etc.) when relationships are maintained with higher risk suppliers (for example, suppliers that subcontract products in emerging countries).

CreaMNN does not tolerate any form of corruption or bribery in any of the activities it carries out, and we also expect this from our suppliers.

CreaMNN has adequate internal policies, procedures and controls to comply with the obligations that the different legal systems establish in relation to corruption prevention and prohibits its staff from offering, promising, directly or indirectly making any type of payment, gift, bonus, donation, job offer, sponsorship, preferential treatment or benefit of any type, that aims to influence or attempt to influence, so as to obtain an unjustified benefit or advantage, the decisions of third parties, individuals, public employees or authorities, with regard to the activity of CreaMNN, or with regard to persons working at CreaMNN. This prohibition also affects what are known as facilitation payments¹.

¹ Facilitation payments are payments of small amounts of money to public officials in exchange for ensuring or streamlining the course of an administrative process or routine action such as, for example, obtaining a permit or licence over which the institution has a right granted by law. What characterises facilitation payments of other forms of bribery is that the party making this payment does not intend to obtain a business, contract or commercial transaction but only to expedite a procedure and the fact that what is usually to be achieved with payment is something to which it is entitled.

In relation to the provision of goods and services to CreaMNN, suppliers agree to develop appropriate policies and procedures to comply with the applicable legislation in this area and not to offer, promise or make, directly or indirectly, any type of payment, gift, gratification, sponsorship, preferential treatment or benefit of any type that has the purpose of influencing, or attempting to influence, so as to obtain an unjustified benefit or advantage in the decisions of third parties, public employees or CreaMNN authorities or employees.

Not to accept gifts, payments, commissions or any other personal benefits from other third parties or CreaMNN employees.

Maintaining an adequate system of accounting records for all transactions, expenses and income, without omitting, concealing or altering any data or information, so that accounting and operating records accurately reflect the facts.

Not to make facilitation payments.

CreaMNN has the duty and legal obligation to prevent funds of illicit origin from accessing and using the financial system. To comply with this duty, CreaMNN, in the ordinary conduct of its financial activity, has developed a model to fight money laundering and the financing of terrorist activities in accordance with current law and international best practices in this field.

Suppliers should share its commitment to preventing their actions from constituting money laundering and terrorist financing. To do so, the necessary measures will be put in place to avoid this risk.

In addition, CreaMNN has procedures and systems to comply with the economic sanctions and embargoes imposed by the international community and some legislations to limit activity with certain countries, entities and individuals. Suppliers should also share this commitment by implementing any measures they consider appropriate to prevent infringement of the aforementioned sanctions and embargoes by exposing CreaMNN to these types of risks. Suppliers to which those regulations apply must implement policies and procedures to comply with the aforementioned economic sanctions and embargoes, as well as to prevent funds of illicit origin from accessing and using the financial system.

At CreaMNN we conduct our business activity respecting the political pluralism of the societies in which we have a presence. CreaMNN does not make contributions to election campaigns or donations to political parties. CreaMNN suppliers must comply with applicable legislation in this field and must not make political contributions on behalf of CreaMNN.

There is a conflict of interest when a personal, family, friendship or other type of external circumstance may affect the professional objectivity of CreaMNN employees related to a procurement decision.
CreaMNN has internal regulations that require its staff to notify these types of situations to their senior executives prior to any action and to abstain from taking decisions on matters affected by the conflict of interest affects or from exerting influence over the persons responsible for taking them.

Similarly, CreaMNN suppliers, in order to ensure their full independence, must maintain internal procedures for checking and verifying potential conflicts of interest and immediately inform CreaMNN of any actual or potential conflict that may arise in any procurement process that they intend to carry out with CreaMNN, due to their personal or professional relationships with customers, suppliers, competitors or CreaMNN employees.

Suppliers must notify CreaMNN, at the beginning of each process to engage services or purchase goods, if (i) any shareholder, (ii) any member of its management body or (iii) any of its employees, related to the aforementioned hiring or purchase, has maintained an employment relationship with CreaMNN within the previous three years. The same will be done if they have the collaboration of that person through a commercial relationship, when they are involved in the procurement or purchase process proposed by CreaMNN.

The professional activity of CreaMNN suppliers must be carried out respecting free competition and avoiding any conduct that restricts it illegally or that may be considered unfair competition, including:

Negotiating or reaching agreements with competitors on prices, product offer, production level, customer distribution, markets or quotas, boycotts on certain customers or suppliers; or any other action against free competition.

Actions that may entail an abuse of a dominant position.

Denigrating the reputation of competitors.
Negociar o llegar a acuerdos con los competidores sobre precios, oferta de productos, nivel de producción, reparto de clientes, mercados o cuotas, boicots a determinados clientes o proveedores; o cualquier otro supuesto contra la libre competencia.

Actuaciones que puedan suponer un abuso de posición dominante.

Denigrar la reputación de los competidores.

The information of CreaMNN, its customers, employees or any third party is confidential. With regard to access and storage of information, the legislation in force at any given time and in the closure governing the relationship between supplier and CreaMNN (general terms, contracts, etc.) must be followed.