Code of Conduct

Introduction

ST Investigación y Desarrollo de Aplicaciones Informáticas, S.A. (ST Idea), was created in Madrid, July 17 2001,being the corporate purposes the following:

  • Design, analysis and development of Applications, Information Technology and Communication solutions.
  • IT Consultancy and IT Services.
  • Training in all type of Methodologies, Systems and IT Programs.
  • Management, Administration and Support of third party IT and Communications intallations.
  • The commercialization of software, hardware and communication products. Inhouse developments or third party products.

AT The General Shareholders Meeting held December 13th, 2013, it was considered necessary to formalize a Code of Conduct which is based in the following principles:

ST Idea Principles

  • Independence in the works developed by the Company.
  • Confidentiality and professional secret.
  • Transparency and Veracity.
  • Integrity and Honesty in its activities.
  • Respect, no discriminitation and fair labour conditions.
  • Loyalty with our clients.
  • Commitment with Suppliers.
  • Environmental Compliance.
  • Compliance with laws and regulation.
  • Cooperation with Government and Authorities.
  • The Code of Conduct developed is the central theme of our commitment with the integrity in all of our behaviors. It does not reflect all of the laws, requirements or internal regulations, but it offers key information which must be acknowledged by the company Administrators and Employees.

Control Committee

The Board of Directors is in charge of the following:

  • Develop the procedures and statutes of the Code of Conduct and improve the Code when needed
  • Promote the knowledge of the Code of Conduct and the principles and values of the Company throughout the employees and the company administrators.
  • Explain the Code and solve the doubts or questions which the employees or administrators might have .
  • Evaluate regularly and control, the efficiency of the measures and procedures established.
  • Evaluate regularly the activities developed to mitigate possible deficiencies in the code of conduct compliance.

The Board of Directors for this purpose created a Commission which informs regularly to the Board in all aspects regarding the Code of Conduct compliance.

Company Details

Address: Madrid, C/ Príncipe de Vergara 43.

Registered at the "Registro Mercantil de Madrid": Hoja M-287.391

C.I.F. nº: A-83/065128.

Share Capital: 300.000 Euros.

Insurance Company: Mapfre Seguros de Empresas, Cia de Seguros y Reaseguros, S.A.

Auditors: Grant Thornton Corporación, S.L.P

Confidencial address for employees with regards to the present document: canaldenuncia@stidea.com.

In the case you need help to comply with the Code of Conduct please contact: canaldenuncia@stidea.com.

The present document was approved at the: General Share Holders Meeting which was held December, 18th 2013.

Revised and updated version dated December 14, 2017