CODE OF ETHICS

Ethical conduct, integrity and honesty are core values of the Arkana Group Business Units that constitute the ARKANA Group and we expect the same adherence to these standards from our Third Parties (suppliers and customers).

This Code sets out the minimum standards of conduct of our Third Parties and is intended to clarify their responsibilities throughout the contractual relationship with any of the Arkana Group’s Business Units.

Our Third Parties must be ethical, responsible and must fully comply with all applicable laws and regulations, as well as with this Code of Conduct.

 

 

Ethical principles of the divisions of the ARKANA Group.

Integrity.
We are open and honest in our professional opinions and business relationships.
We are honest in the services we provide, the knowledge we possess and the experience we acquire.

Quality.
We are committed to providing quality service by bringing together the expertise and scope of our resources, experience and knowledge to help clients address their needs and problems.
We strive to develop results that generate a relevant impact for our clients.

Professional behaviour.
We comply with laws, regulations and professional standards, and seek to avoid any actions that may discredit us or our profession.
We foster a culture of appropriate professional scepticism and personal accountability, which supports clients and promotes quality in the services we provide.
We understand the wider impact our work has on society, our people and our clients, and have their best interests at heart when doing business.
We strive to do not only what is legal, but also what is right.

Objectivity.
We are objective in forming a professional opinion and giving advice.
We do not tolerate bias, conflicts of interest or improper influence from others to avoid our professional judgements and responsibilities.
We do not offer, accept or solicit gifts, entertainment or other favours that we have reason to believe may influence our business decisions or undermine our objectivity.
We welcome differences of opinion and judgement and value them constructively and professionally.

Competence.
We take due care to assign to each client, according to their needs, the professionals who have the necessary competence for their work.
We encourage innovation and new ideas to improve the value and performance of our services.
We understand that both the public and our clients expect our work to be of the highest professional standards.

Fair business practices.
We respect our competitors and are committed to fair business practices.
The fees we receive reflect the value of the services provided and the responsibilities undertaken.
We make decisions based on our Values and expect the same from our fellow professionals.

Confidentiality, privacy and data protection.
We protect and take steps to safeguard confidential and personal information in our possession by collecting and processing data in accordance with applicable laws, professional obligations and our own data management policies and practices.
Disclosure of any confidential and personal information entrusted to us is prohibited unless authorised or required or permitted by law, law or professional duty.
The use of any confidential information about our clients for personal gain or for the benefit of others is prohibited.

Respect, diversity and fair dealing.
We foster a culture and working environment in which our professionals treat each other with respect, courtesy and fairness, promoting equal opportunity for all.
We promote and value a diversity of people, views, talents and experiences.
We create inclusive work environments that not only address individual needs, but also enable our people to draw on their unique strengths.
We do not tolerate discrimination or harassment of any kind on the basis of gender, race, religion, age, disability, gender identity, sexual orientation or those categories protected by local law in any of our work environments.
We understand that our individual behaviour influences our firm, our colleagues and society, and we strive to always act responsibly.

Professional development and support.
We invest in our people to develop the knowledge and skills they need to perform their role effectively.
We help our people achieve their potential by investing in professional and personal development and support programmes.
We provide a safe working environment for our people and expect our customers to do the same.

Anti-corruption.
Under no circumstances do we tolerate corruption or the acceptance or offering of bribes, either by us or by others on our behalf.

Social responsibility.
We promote and respect human rights.
We recognise that our business operations and the delivery of our services may, from time to time, affect the environment and we work to reduce any harmful effects they may have.
We take our role in society seriously, striving for its well-being.
Through our efforts and our financial capacity, we contribute to the development of the profession and the environments in which we operate.
Our Third Parties must carry out their activities in accordance with the applicable environmental regulations and safety regulations in their facilities, the production of their products and the provision of services.

 

 

General conduct
Behaviour towards our customers.

Honesty and rectitude.
From the first moment and on all occasions, always try to do the right thing in accordance with the Ethical Principles of the ARKANA Group. To be honest and trustworthy, always acting with frankness and sincerity, both in professional and personal matters. To do the job, whatever its category, respecting both the letter and the spirit of the laws and regulations applicable to each case. Do not just do what is legal, but what is right. Seek to exceed the expectations of clients, colleagues and the general public. Avoid letting any ambition cloud professional and ethical responsibilities.

 

Quality.
Aim for the highest standards that customers and the general public can expect in the provision of services by the ARKANA Group. To understand that ARKANA’s reputation depends on the quality of the services provided, which is the responsibility of each and every member of the group. Commit to achieving the highest quality individually, as a team and corporately. To be permanently sceptical when assessing the quality of the work carried out, seeking continuous improvement.

Confidentiality.
As a general rule, any information obtained as a result of the professional relationship with clients must be considered confidential, and the disclosure of such information, whether personal or commercial, in public or informal conversations with third parties must be scrupulously avoided.

In the event of external requests for information (e.g. from the media or regulators), these must be channelled through the relevant areas of the ARKANA Group for processing. This also includes legal requirements, sector publications, etc. In short, not everyone has to answer every question. It is ARKANA’s policy to deal with all external requests for information by the appropriate means in an honest and truthful manner, always respecting the duties of confidentiality. All contacts with Public Administrations and regulators must be carried out through the appropriate channels. Maintain confidentiality in social networks, both in terms of projects, clients, type of work, etc.

Think before publishing any information about the effects it may have on confidentiality for our clients.

Creation and retention of documentation.
Maintain complete and accurate records of all projects in which you are involved, so that you comply with your accountability to clients and with legal and financial reporting requirements.

Information included in the group’s records must be truthful, accurate, understandable, up-to-date and in accordance with the firm’s policies, regulations and professional standards.

Know and master the procedures and systems for storing and reporting records and working papers, including archiving and retrieval of data and the requirements for access to them.

Once the work has been completed, ensure the preservation, in accordance with the firm’s policies, of all supporting documentation, avoiding its subsequent alteration or destruction.

Conflict of interest.
Make all decisions without being influenced by factors outside professional judgement, always making sure to maintain and give an image of impartiality. Avoid putting personal interests ahead of those of the group. Act legally and ethically in the event of any conflict of interest.

Intellectual and industrial property.
Always and at all times ensure respect for the rights of third parties, among others, in relation to the technologies used, compositions, data, ideas, improvements, layout plans, images, videos, etc. All ARKANA Group professionals must respect and preserve intellectual and industrial property rights, both their own and those of third parties.

Independence.
All of the firm’s professionals must act towards their clients with absolute objectivity and independence of judgement, avoiding any risk that could reduce the quality of the service provided. Avoid situations which, due to family or similar ties, may give rise to conflicts of interest, in accordance with the policies of the ARKANA Group.

Invoicing.
Accurately record the time and expenses incurred in the provision of services in accordance with the Group’s policies. Charge hours and expenses to the appropriate internal codes or projects, or to the appropriate clients from whom prior authorisation has been obtained. Invoice clients only the appropriate amounts accurately and honestly, in accordance with the hours spent, the value added, the complexity of the task performed and the expenses incurred, and in accordance with the commitment made to them.

Confidential information.
To preserve the confidentiality of the information obtained during the services provided to clients, treating it with special responsibility, control and protection. It is strictly forbidden to share confidential or restricted customer information with anyone outside your organization, including employees of the customer or professionals of the ARKANA Group who do not have access to it, except for legal or professional reasons, or because you have written consent to do so. In all circumstances, information owned by a client or the firm, whether confidential or not, obtained through work in the ARKANA Group, may not be used for personal gain or for the benefit of others.

Diligence and professional competence.
Respect and comply with the standards and customs of the profession in the provision of services, and constantly strive to improve their quality. To be diligent in the management of commitments to clients, meeting their needs with the appropriate professional team, with the necessary technical level and training.

Only use, as far as possible, the resources of the group to plan, execute and supervise the contracted services. Only in those cases in which it is convenient, or because it is required by the client, will its own resources and facilities be used. To constantly monitor the quality of the services, the fulfilment of commitments acquired with clients and the adequacy of the reports issued to the standards of the profession.

Acceptance of gifts.
As a general rule, no gifts or presents, including cash, should be given or accepted in order to acquire new customers or to recruit suppliers. ARKANA bases its competitiveness in the market solely on the quality of the services it provides. However, ARKANA Group policy in this regard accepts the possibility of giving or receiving gifts, provided that they are within reason, and their value cannot be considered excessively high, lavish or exaggerated.

Acceptable gifts include the following:

– Small, customary gifts between professionals, mainly of symbolic value and of a promotional nature (pens, diaries, etc.).
– Invitations to professional meetings, congresses or conferences, the cost of which is moderate (e.g. courses and business lunches).

In case of doubt, consult the Ethics Committee or existing internal regulations.

ARKANA does not permit the use of gifts, for or by members of the group:

– That improperly influence the company’s business relationships or create obligations to customers, suppliers or partners.
– That are contrary to laws, regulations or professional standards.
– That may impair the ability to act with objectivity and independence of judgement.

No professional, or any family member or friend, may use their work in the ARKANA Group to solicit cash, gifts or free services from any client, supplier or any other person or company, for their personal benefit or that of a third party.

Respect for competitors.
To refrain at all costs from any competitive tactics that could damage the reputation of the profession. Compete honestly and fairly, according to the rules of the market and free competition.

 

 

Internal behaviour.

Health, safety and well-being.
To provide a healthy and respectful working environment, wherever the work is carried out, encouraging behaviour that promotes the well-being and safety of employees.

Honesty and trust.
Conduct all our relationships with integrity, ethics and responsibility. Be honest in the way we do business and in our relationships with colleagues. Ensure the confidentiality of information entrusted to us and protect information to which the firm owns the rights. Accurately and truthfully reflect the hours spent on each project and the costs incurred.

To foster a culture of trust with the rest of the professionals where the emphasis is placed on the spirit of consultation and the taking of thoughtful and consensual decisions.

Not to accept work that could pose a risk to the reputation of the ARKANA Group or that involves behaviour contrary to the provisions of this Code of Ethics. Only accept work for which they have the capacity to provide high quality services.

Diversity and Equal Opportunity.
To develop a culture of diversity and tolerance, reflecting the mission of the ARKANA Group. Respect and value the richness that comes from the mix of views, talents and experience of the people who work in the ARKANA Group.

Comply with laws and internal policies regarding equal opportunity, diversity and fairness in recruitment, hiring, promotion and training programmes.

Apply human resources policies on an equal basis to all employees regardless of race, creed, colour, national origin, age, gender, sexual orientation, marital status or disability.

Facilitate access for all professionals to the work-life balance plans established in the ARKANA Group’s policies.

Respect and equal treatment.
Treat all professionals and professional colleagues with respect, demanding the same behaviour from them.

To strive to achieve a safe and healthy working environment that contributes to the achievement of personal and professional objectives, avoiding any circumstance or conduct that is annoying or harmful to others.

Not to tolerate discrimination, verbal or physical abuse, or offensive behaviour by professionals, clients or any other agent of the ARKANA Group.

Use of ARKANA resources.
Use the firm’s information, technological structure, facilities, intellectual property (patents, trademarks, copyrights, etc.), software, machinery, cash, etc., only for professional purposes and in a responsible manner, with accuracy and precision when claiming reimbursement of expenses.

To care for and protect the firm’s technological equipment, including the data it contains and the software with which it operates, in order to prevent its destruction, theft or improper use, maintaining the necessary security measures.

Not to use other people’s passwords to access the systems, and to avoid lending their own passwords for use by other people, whether or not they are members of the ARKANA Group.

Only use computer programmes that have the corresponding licence, and restrict their use to the terms for which they were acquired.

To make responsible and productive use of communication systems, such as e-mail, mobile devices, telephone and Internet access. Access to pornographic or illegal material is specifically prohibited.

 

 

 

 

Harassment protocol.

ARKANA declares its zero tolerance for any conduct constituting sexual harassment or harassment based on sex throughout its organisation.

To this end, we have adopted the PROTOCOL FOR PREVENTION OF AND ACTION AGAINST SEXUAL HARASSMENT AND HARASSMENT ON GROUNDS OF SEX.

By adopting this protocol, ARKANA wishes to underline its commitment to the prevention of and action against sexual harassment and harassment based on sex in any of its manifestations, informing of its application to all personnel who provide services in its organisation, whether they are its own personnel or from other companies, including people who, not having an employment relationship, provide services or collaborate with the organisation, such as trainees, those who carry out non-labour practices or those who volunteer.

Likewise, ARKANA assumes the commitment to inform the companies to which it sends its own personnel of the existence of this protocol, indicating the need for strict compliance with it, as well as to the companies from which the personnel working at ARKANA originate. Thus, the obligation to observe the provisions of this protocol shall be stated in the contracts signed with other companies.

When the alleged harassing person is outside the management of the company and, therefore, ARDE MARKETING S.L. cannot apply the procedure in its entirety, it will contact the competent company in order to solve the problem and, where appropriate, sanction the person responsible, warning them that, if they do not do so, the business relationship between the two companies may be terminated.

You can consult the full details of the protocol here.

 

 

 

 

 

Ethics Committee.

The ARKANA Group has an Ethics Committee in which it places all its trust to constantly monitor the development and compliance with the code. The Committee has the power to resolve any conflicts or situations of non-compliance related to ethics that arise in the ARKANA Group, and serves as a guide to resolve any doubts that may arise in this regard.

Compliance.

The ARKANA Group’s commitment to ethics and legal compliance is a fundamental part of our culture. The confidentiality and security of the information we handle is a basic principle of the way we work. The respect we demonstrate for our values distinguishes us as a company and enables us to provide a level of trust that is highly valued by our customers. Observance of the law and compliance with our Code of Ethics, as well as our handling of situations that could compromise our values, are part of our commitment to integrity and professional excellence.

All of us who form part of the ARKANA Group have a professional and moral obligation to report any breaches of the law or our Code of Ethics that we may become aware of. One of the main tasks of the Ethics Committee is to help professionals resolve their doubts and questions related to ethical behaviour. All members of the ARKANA Group have free access to it, and the Committee will deal with any questions that may arise in complete confidentiality. The professionals who make up this Committee have extensive experience in dealing with complex situations.

 

 

Canales de contacto.

Communications to resolve doubts and questions related to ethical behaviour are multiple and can be made through the usual channels in each group or directly to the partners, to Administration, or if you prefer, you can use the Nailted platform, which is available to all employees of the ARKANA group.