Code of Ethics and Legal Compliance

Direct Channel

Net Studio S.p.A. is committed to Indra Group’s Compliance Model, consisting of the Criminal Risk Prevention Model and the Antitrust Risk Prevention Model, both focused on promoting a culture of compliance, with the objective of preventing any illegal activity in our business fields that may violate the law. The Audit and Compliance Committee of Indra’s Board of Directors is the maximum body of control of the Model, and the Compliance Unit is responsible for implementing and executing the Compliance Model.

Both Senior Management and the Board of Directors have the firm commitment to establish a solid culture of compliance and integrity throughout the group. This culture is based on “doing the right thing” and is applicable to all employees and Partners (i.e. representatives, suppliers and other third parties that provide services or act on our behalf), who must comply with the legislation in force and apply the principles of Indra.

To accomplish with the above-mentioned commitment, maintain a controlled environment and continuous improvement, Indra has established a Code of Ethics and Legal Compliance, with a Whistleblower Channel (aka Direct Channel), which have been adopted by Net Studio as well.

Code of Ethics and Legal Compliance

The Code of Ethics and Legal Compliance is a framework, which establishes the following corporate principles and standards of conduct:

Corporate Principles:

• Integrity: means acting in good faith and establishing professional relationships based on transparency and ethics
• Professionalism: means maintaining a proactive attitude with respect to ensuring the excellence of our efforts
• Respect: means recognizing the value of people and their work, and of the social and natural environment in which we operate

Standards of Conduct:

• Compliance with legislation
• Rejection of corruption and bribery. In this sense, we have specific procedures to regulate the hiring of Commercial Consultants and Strategic Advisors as well as the request of donations, sponsorships and corporate courtesy.
• Conflicts of interest
• Information security
• Equality and Non-Discrimination
• Foreign trade of defense materials and dual-use goods
• Subsidies and public aids
• Sustainability
• Best tax practices
• Economic-Financial information management
• Protection of Antitrust
• Money laundering and terrorist financing
• Occupational health and safety
• Relations with governments and authorities

The Code of Ethics also reflects recognized Human Rights, within the framework of the United Nations Guiding Principles on Business and Human Rights, the International Bill of Human Rights, and principles related to rights established in the International Labour Organization’s Declaration.

Additionally, the Code of Ethics, the Criminal Risk Prevention Model, the Antitrust Risk Prevention Model and the procedures and politics of Indra establish action Guidelines and controls, which are executed periodically in different areas of the company to minimise potential risks of unlawful conducts perpetrated by employees and Partners del gruppo.

Direct Channel

The Direct Channel (https://canaldirecto.indracompany.com/), is a confidential channel available to all group employees and Partners, as well as other parties, for communicating any doubts regarding the interpretation/application of our Code of Ethics. The above link, available as well on all our internal and external websites, can be used to anonymously report any illegal behaviour detected in relation to the Code of Ethics, as well as other infringements or irregularities listed in Annex 4 of the aforementioned Code.

In accordance with local laws regulating the protection of persons who report violations and fight corruption, Indra has designated a Chief Compliance Officer as the person responsible for the internal information system, who carries out its functions independently and autonomously. Additionally, its governance body together with Senior Management are involved actively in the supervision of the Compliance Model. To that effect, and as mentioned above, the Audit and Compliance Committee is in charge of supervising the functioning, effectiveness, and compliance of the Model.

Indra has defined an organisational chart and an organisational model that establishes the functions, responsibilities and reporting lines of each of the organisation's departments in all the businesses and countries in which it operates, including Net Studio. This organisational chart is available internally to all employees on a global scale through the corporate Intranet. This, together with the Code of Ethics and Legal Compliance, allows us to establish a regulatory and behavioural framework throughout the organisation.