Code of Conduct

Employees of Empresaria Group plc and each of its subsidiaries (together, the ‘Empresaria Group’) must observe the highest standards of ethical behaviour and must conduct themselves in a manner designed to enhance the operation, image and reputation of the Empresaria Group.

Ethical behaviour is not simply compliance with legal requirements but extends to professionalism, integrity, good faith, respect and fair practice. It is conduct that can withstand public scrutiny.

This Code of Conduct sets out the minimum standards which employees must meet to maintain a productive and safe working environment that is free from harassment and discrimination. It sets outs a framework for employees’ relationships with others, whether internal or external.

Employees must:

• comply with this Code of Conduct, Empresaria Group policies and all relevant legislation
• be responsible and accountable for their own conduct
• undertake their duties in a professional, responsible and ethical manner
• act in the best interests of the Empresaria Group
• treat colleagues and others with courtesy and respect
• build positive relationships with clients and candidates
• act with honesty and integrity to ensure that others are not misled
• use market prices for all business transactions
• follow proper records management practices and procedures
• implement all necessary security measures to minimise the risk of fraudulent activity
• be alert to cyber security risks and phishing scams
• take all reasonable care when using Empresaria Group property
• inform the Group CFO or Company Secretary immediately if they are subject to blackmail or extortion

Employees must not:

• knowingly make a false or inaccurate statement or fail to disclose a material fact
• make a representation as to future matters without having reasonable grounds for making it
• pursue any political activity or make political donations or contributions in the name of the Empresaria Group without the CFO’s prior written approval
• use Empresaria Group resources for private purposes without permission

Privacy and use of personal and official information

Empresaria Group information, including employee, client and candidate information, is strictly confidential and must be secured against loss, misuse, unauthorised access or disclosure.

All employees must comply with data protection laws and our data protection policies and procedures. Employees must ensure that individuals have been notified (and if appropriate, consent has been obtained and documented) before disclosing confidential or personal information. Employees must report data breaches immediately.

Bribery and corruption

All employees must comply with our Anti-Bribery and Corruption Policy. Facilitation payments must not be made in any circumstances. Any gift (whether given or received) or hospitality provided, that is intended to influence a business decision, is deemed to be bribery and is strictly prohibited. If in doubt, an employee should refuse to seek or accept it.

Tax evasion facilitation

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The Empresaria Group takes a zero-tolerance approach to tax evasion. Any form of tax evasion or its facilitation is forbidden. All employees must observe our Tax Evasion Facilitation Prevention Policy.

Modern slavery

Employees must be alert to the risk of modern slavery taking place anywhere within the Empresaria Group’s businesses or supply chains and must report concerns immediately in accordance with the Empresaria Group’s Modern Slavery Policy.

Whistleblowing

The Empresaria Group encourages open communication from its employees and aims to ensure that all employees feel secure about raising concerns in the knowledge that they will not suffer detriment if they report malpractice in good faith, even if their concerns later prove to be unfounded. Employees are encouraged to report any concerns in accordance with our Whistleblowing Policy.

Summary

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Any breach of this Code of Conduct will be the subject of disciplinary proceedings and may result in summary dismissal. The following are examples of such misconduct:

• accepting or offering bribes
• falsification or misrepresentation of records such as candidate records and legal records
• conduct bringing either the employee or Empresaria into disrepute
• any act of race, sex, disability or other unlawful discrimination
• dishonesty, fraud or unethical conduct
• bullying or harassment
• abuse of the Company’s business systems
• misuse of personal data or confidential information
• tax evasion or the facilitation or enabling of tax evasion
• involvement in, or failing to report suspicions of, slavery or trafficking
• subjecting any employee who has raised a concern in good faith to detriment as a result
• any major breach, or continual minor breaches, of our policies or general code of conduct