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Code of Conduct

1. PURPOSE

This Code of Conduct establishes the principles governing the behaviour of IFEMA employees and helps to cement a corporate conduct that is respected and accepted by all our workers and executives, based on respect for the values of honesty, integrity, transparency and safety.

2. SCOPE

This Code of Conduct shall apply to all employees contracted by IFEMA.
The IFEMA Management Committee shall make all means available to employees so that they can comply with the standards included in this Code of Conduct, with the permanent support of the Governing Board.
Moreover, all supplier companies that work for IFEMA shall be given the Code of Conduct so that they feel that they are part of it.

3. BASIC PRINCIPLES OF CONDUCT

The policy and goal of IFEMA is to maintain the highest standards of ethical business conduct. Ethical behaviour in carrying out IFEMA's functions essentially means being fair and honest in our treatment of other employees, clients, providers, our competition and the general public.
IFEMA's reputation is one of the company's most valuable assets, which is achieved and maintained through the efforts of its employees and through its refusal to carry out any activity that could reflect badly on its image or reputation.
This Business Ethics Code of Conduct therefore provides basic guidelines for the ethical conduct expected from all employees:
Follow laws and regulations.
Treat everybody fairly and equitably, including customers, providers and other employees.
Refrain from speaking in public about confidential IFEMA matters unless authorised to do so.
Respect the confidentiality of the information to which you have access, and refrain from sharing it unless there is a real need to do so.
Always perform your job in the best interests of the company.
Avoid conflicts of interest, both real and apparent.
Be honest and act with integrity.
Handle IFEMA assets with care and refrain from using them, or company time, for personal purposes.
Respect the rights of all employees to fair treatment and equal opportunities.
Respect the rights of all employees to a workplace free of any kind of discrimination or harassment.
Act respectfully and professionally toward other employees.
Work in an environmentally friendly manner.

4. STANDARDS OF CONDUCT

4.1. ETHICAL CONDUCT

Act with independence, moral integrity and respect for people as you carry out your daily work. This includes the following:
Loyalty and good faith: Always ensure that your actions are in line with the principles of loyalty and good faith to the company, to your managers, peers and co-workers, and to all third parties with whom you have professional dealings.
Conflict of interest: Give priority to IFEMA's interests over your personal interests or those of third parties that could influence your decisions, actions, services or advice on behalf of the Organisation.
Information integrity: The information you handle within your area of responsibility must be processed and reflected fully, accurately and truthfully.
Insider information: The use or disclosure of insider information obtained by virtue of your functions shall not be used to your own benefit or that of third parties.

4.2. RIGHTS OF IFEMA WORKERS

The basic rights of workers include:
The right to IFEMA providing them effective work that matches their professional qualifications.
The right to promotions and vocational training at work, which is to say, the right to access a more skilled position that is better paid or with better prospects based on experience and professional merit, and the right to receive permission to attend training and development courses.
The right to not be directly or indirectly discriminated against in seeking employment, or once employed, on the grounds of sex, marital status, age within the limits set by law, racial or ethnic background, social status, religion or convictions, political ideas, sexual orientation, union affiliation or due to language, within the Spanish State. The right to not be discriminated against on the grounds of disability, as long as they are fit to perform the work or job in question.
The right to their physical integrity and a suitable safety and hygiene policy.
The right to privacy and due regard for their dignity, including protection from harassment on the grounds of racial or ethnic origin, religion and convictions, disability, age or sexual orientation, as well as protection against sexual and gender-based harassment.
The right to the timely payment of the contracted or legally established remuneration.
The right to the individual exercise of the actions included in their employment contract.
The right to organise freely.
The right to collective bargaining.
The right to take collective labour dispute measures.
The right to strike.
The rights of assembly, information, consultation and participation in the company.
The right to the individual exercise of the actions included in their contracts, and any other rights included in the Workers Statute and any related legislation in force.

4.3. DUTIES OF IFEMA WORKERS. Workers have basic duties, including:

The duty to comply with the specific obligations of their job position, in accordance with standards of good faith and diligence, and to comply with obligations under the contractual structure for which they have been contracted.
The duty to observe general safety and hygiene measures, particularly as they apply to their workplace and working conditions.
The duty to look after the supplies, tools, equipment, clothing and machines entrusted to them as part of their job, keeping them in perfect condition and cleanliness.
The duty to comply with the orders and instructions given by IFEMA leadership as part of the regular exercise of their management functions.
The duty to not interfere with IFEMA's activity.
The duty to contribute to improving productivity.
Any other duties arising from their respective work contracts.

4.4. USE OF INFORMATION AND COMMUNICATION SYSTEMS

Workers may use e-mail and the Internet to carry out the activities of their job positions in accordance with IFEMA's internal regulations in this area.
Whenever they must use these means more than usual or send mass or complex mailings, they shall use the appropriate channels in accordance with IFEMA's Information Technology Division, so as not to hinder normal communications and network operations.
In general, IFEMA workers shall not overuse e-mail and the Internet for personal purposes.
Thus, under no circumstances shall workers use these means to send mass messages, send messages with large attachments, or send anything not related to their professional activities that may interfere with the communications of other workers or disrupt the normal operations of the corporate network. Likewise, they may not send e-mail chains, falsify e-mails, send messages or images that are offensive, inappropriate or discriminatory on the grounds of gender, age, sex, disability, etc., send messages that encourage sexual harassment, or use the network for gambling, prize draws, auctions, or downloading video, audio or any other material not related to their professional activity.
A failure to comply with these rules will lead to the company restricting the use of these means as it deems appropriate, and taking disciplinary measures if necessary.
If there is evidence of illicit or abusive use by a worker, the company shall make the necessary checks and, if necessary, shall perform an audit of the worker's computer or of the systems providing the service. This shall be performed during working hours and in the presence of a worker's representative or the appropriate union representative, if the worker is in a union and so chooses, with respect for the worker's dignity and privacy.

4.5. LOYALTY TO THE COMPANY AND CONFLICTS OF INTEREST

IFEMA believes that its relationship with its workers must be based on loyalty stemming from common interests, and thus workers must avoid real and potential conflicts of interest that may arise during the course of their work, and must not promote their personal interests at the expense of IFEMA.
IFEMA workers are expected to act in the interests of the Organisation and avoid conflicts of interest, making reasoned impartial decisions.
Employees must carry out their functions honestly and in good faith, to the benefit of IFEMA and avoiding situations involving a conflict between their personal and professional interests. Employees' actions and decisions must be based on impartial and objective assessments of the facts of each situation, free from the influence of gifts and favours.

4.6. CONFIDENTIAL INFORMATION

IFEMA believes that information and knowledge are among its major assets, essential to managing the business. Thus, they must receive special protection.
Employees must truthfully and fully convey all the information they are required to communicate, both inside and outside the company, and in no case shall they knowingly provide incorrect or inaccurate information that could mislead its recipient.
In the course of their work, employees may gain access to and knowledge of confidential information, to the extent that the information is necessary or at least useful for them to properly carry out their tasks.
All employees must maintain the strictest confidentiality of all restricted information that they access in the course of their work, including after they stop working at IFEMA, and must abstain from making improper use of it for their own benefit or that of third parties.
Confidentiality restrictions apply not only to IFEMA's confidential information, but to information received from third parties under a duty of confidentiality.
IFEMA makes its computing resources available to authorised users, and trusts them to operate them to carry out tasks related to the activity of Feria de Madrid and within the roles and functions of the job carried out by each user. Any employees who input any kind of information into IFEMA computer systems must ensure that it is accurate and reliable.
Users authorised to access computing resources shall be responsible for using and maintaining the resources at their disposal, and not diverting them from their material objectives.

4.7. PRIVACY POLICY

IFEMA complies with current legislation on data protection, protecting the personal data provided by its clients, employees, job candidates and others. Likewise, it agrees to request and use only the data necessary for the effective management of its business.
Employees who, in the course of their work, have access to other employees' information, shall respect and maintain the confidentiality of this information and make responsible and professional use of it.

4.8. EFFECTIVE EQUALITY

IFEMA's labour policy ensures equal employment opportunities and no discrimination on the grounds of gender, sexual orientation, marital status, age, race, nationality, social status, political or religious ideas, union membership or any other area protected by law.
IFEMA is committed to providing a workplace in which all people are treated with respect and dignity. Each person should be able to work in a professional environment that promotes equal employment opportunities and prohibits discriminatory practices.
This commitment entails removing all obstacles that may negatively affect compliance with equal conditions between men and woman, as well as implementing affirmative action or similar measures to correct possible discrimination.
Based on the above, one of the primary objectives of IFEMA's labour relations is to protect the values of effective equality of men and women and to allow workers to find a balance between their work and family lives as well as possible, promoting several specific measures for gender equality:
Staff selection period
In selecting people to join its staff, IFEMA shall not compel any candidates to respond to questions about their marital status, pregnancy or family responsibilities, nor shall it include any mention of preferring one gender or the other, unless objectively justified.
Preference in employment
IFEMA and the Governing Board promote policies favouring equal access to employment and to career advancement within the company.
Given the above, the IFEMA Equality Committee shall prevent anything that blocks access to employment or career advancement that unjustifiably and deliberately attempts to have a gender be under-represented in any area of activity or professional group.
To effectively apply the principle of non-discrimination and carry it out under the concepts of equal working conditions and work of equal value, we must implement affirmative action particularly in the areas of hiring, salaries, training, advancement and overall working conditions. In this way people from the less-represented gender in any professional group will be favoured when all other suitability conditions are equal.
Affirmative action to promote the employment of women
With an eye to implementing affirmative action to promote women's access to employment and the measures to encourage it, as per the provisions of Articles 42 and 43 of Organic Law 3/2007, of 22 March, on the effective equality of men and women, and as a means to promote employment to facilitate women joining the work force,
preference shall be given to unemployed women who, in the year prior to the hiring date, had a child (biological, adopted or through foster care) or were declared victims of gender-based violence, over any other candidate to fill any vacant job position to be covered by IFEMA, provided their merits and professional profiles are equivalent or equally suitable to cover the position in question.
Remuneration
IFEMA shall be required to pay the same remuneration for carrying out work of equal value, without any discrimination on the grounds of gender or any other elements or conditions of it.
Vocational training at work
As established in Article 23 of the Workers' Statute, in terms of attending training courses, particular consideration shall be given to the potential existence of under-represented genders in the worker's areas of activity or professional group.
Use of gender-inclusive language
The use of sexist language that could lead to discriminatory situations or accusations of harassment shall be avoided.
In this context, we must note that in the text of the Collective Bargaining Agreement, the masculine is used generically to encompass male and female workers for the purposes of brevity, however this does not imply ignorance of existing gender differences.
We respect ethnic and cultural diversity and human rights without discrimination on the grounds of gender, ethnicity or religion. We reject child labour in all its manifestations and promote its abolition. All employees have equal opportunities and we are all treated with dignity and respect. All staff selection and hiring decisions are based on skills, attributes, abilities, professional experience and consistency with the company's values. We do not take into account race, sex, age, skin colour, ethnicity or any other factor not related to the stated criteria for this decision-making.

4.9. PROTECTION AGAINST GENDER-BASED VIOLENCE

1. Any workers who can confirm, through the existence of a court ruling, having been a victim of gender-based violence shall have the right to effectively implement their protection and to full social assistance; to a reduced working day with a proportional salary reduction; to the rearrangement of their working hours, by adapting their timetable or being flexible with other means of time management; to temporarily suspend their employment with job security; and to terminate their work contract.
2. If a victim of gender-based violence feels obligated to leave their job, the suspension period shall initially not exceed six months, except when judicial review proves that the effectiveness of the victim's right to protection requires continued suspension. The obligation to pay Social Security contributions shall be suspended for the victim during this time, and they will be considered as effectively contributing. Their situation will be regarded as equivalent to active employment.
3. Absences or tardiness to work caused by the physical or psychological effects of gender-based violence shall be considered justified when so determined by social services or health services, as appropriate, though the victim must notify the company of these absences at the earliest opportunity.
4. Law 1/2004, on Comprehensive Protection Measures against Gender-Based Violence, sets forth everything not included in this document.

4.10. PROTECTION AGAINST MORAL AND SEXUAL HARASSMENT

IFEMA Management and the Governing Board jointly declare that any form of harassment at work is totally unacceptable, and thus it may not and must not be tolerated. All workers have the right to a workplace free from hostile or intimidating conduct and behaviour, ensuring their dignity and physical and moral integrity.
For that reason IFEMA Management and the Governing Board express their commitment to providing positive work environments, preventing harassing behaviour and prosecuting and resolving cases that occur in the workplace.
For this reason, a Harassment Prevention Code and Action Protocol for harassment complaints have been drawn up, establishing the measures IFEMA must take to prevent and avoid harassment situations or situations which may constitute harassment, as well as an internal action protocol for cases in which, despite trying to prevent these situations, an internal complaint or grievance is lodged by a worker regarding an alleged harassment scenario.
In short, the document aims to establish an efficient, flexible and confidential process for preventing, and if necessary immediately resolving, any situations or behaviours that could lead to harassment at work.
IFEMA Management makes all workers aware of this Harassment Prevention Code by distributing it to the entire staff.
In addition, notwithstanding the document being presented and publicised to the entire staff, the Harassment Prevention Code shall form part of the Welcome Package given to all workers when they join IFEMA.

4.11. SAFETY AND HEALTH AT WORK

IFEMA workers
IFEMA, in close collaboration with the Safety Delegates of the Safety and Health Committee, is committed to ensuring a healthy workplace and safe working conditions, equipment and workplaces for its employees, and encouraging them to take part in preventing occupational accidents. IFEMA has adopted a Safety Policy in order to document its goals in this area. All employees must be aware of this Policy and have the responsibility of working safely.
Collaborators
Guaranteeing the safety and health of all people who provide their services at the Exhibition Centres is one of the objectives of IFEMA Management. This commitment, expressed in the Prevention Policy position paper, also covers companies that work for IFEMA inside the exhibition centres.
In addition, the Law on Prevention of Occupational Risks compels companies owning Work Centres to inform the other businesses that work in their centres about the risks and protection, prevention and emergency measures that exist.
Contracting companies must also monitor compliance with occupational risk prevention regulations in companies contracted to perform jobs or services in its same line of business.
It must therefore give them informational literature on the occupational risks of the exhibition centres and the corresponding protection, prevention and emergency measures, so they may pass it on to all their employees who will be working for IFEMA.

4.12. COMPLIANCE WITH LAWS, RULES AND REGULATIONS

IFEMA is committed to carrying out its business and professional activities in accordance with current legislation, to the highest ethical standards.
All workers must comply with the laws, rules and regulations governing their employment
or job position, and IFEMA shall not tolerate any kind of fraudulent, dishonest, criminal or discriminatory conduct.
Moreover, they must avoid any conduct that, though legal, may damage the reputation of IFEMA and adversely affect its interests.
All employees must know the laws that impact their work, requesting accurate information from their superiors or through the proper channels if necessary.
Employees shall not knowingly collaborate with third parties in breaking a law, nor shall they participate in any activity that compromises legal observance.

4.13. RELATIONS WITH PROVIDERS

IFEMA's relations with its providers are based on the principles of transparency, competition and publicity, and always fall within the legal framework governing these commercial relations. Providers shall be considered partners of IFEMA.
IFEMA workers shall always act according to the principle of contractual good faith and shall never use their positions as employees to obtain personal advantages from providers.
Thus directly or indirectly offering, giving, requesting or receiving payments in cash, in kind or any other benefit with the intention of unlawfully obtaining
or maintaining business or other advantages, is prohibited.

4.14. FAIR COMPETITION

IFEMA is committed to the principles of fair competition in the purchase and sale of products and services, basing its decisions exclusively on commercial considerations such as quality, price, availability, service, reputation and other factors directly related to the product, service or provider.
It must provide its clients with equal rights to make contracting decisions on the same terms, therefore IFEMA shall not attempt to gain, encourage or tolerate special favours with providers or clients that could impede fair and unrestricted commercial relations. Thus, all IFEMA workers who participate in selection processes for contractors, providers and external partners must act impartially and objectively, applying cost and quality criteria and preventing their personal interests from clashing with those of the company.

4.15. CORPORATE IMAGE AND REPUTATION

IFEMA considers its corporate image and reputation to be among its most valuable assets for maintaining the trust of its employees, clients, providers and the general public.
All employees must be extremely careful to preserve IFEMA's image and reputation in all their professional activities. Likewise, they will ensure respect for and proper and appropriate use of the corporate image and reputation by employees of partner companies.
Employees must be particularly careful in any public appearances and must have proper authorisation to appear as IFEMA employees when speaking to the media, taking part in professional conferences or seminars, or participating in any other event that may be publicly broadcast.
Unless authorised, no employee may give their personal opinion, disclose confidential information or discuss matters related to IFEMA with any member of the press or the general public.
The only individuals authorised to speak about IFEMA with the media are members of the Management Committee and Trade Show Managers.
All questions or requests for interviews must be referred to the Director of Communications.
Nobody may communicate any unpublished information related to IFEMA until the information has been publicly disclosed to the general public, except to those who need to know the information as part of the necessary course of their commercial activities and under a duty of confidentiality.
If any non-public information about IFEMA is disclosed inadvertently, any employees who have knowledge of the disclosure must immediately contact the Director of Communications so that IFEMA can take the proper measures.

4.16. COOPERATION AND DEDICATION

IFEMA fosters an environment of cooperation and teamwork to make better use of all skills and resources.
All employees must act in the spirit of collaboration, making all knowledge and resources available to other units and individuals in IFEMA that could help them achieve the goals and interests of the company.
Employees must work efficiently during the work day, making the most of the company's time and resources.

5. ACCEPTANCE AND COMPLIANCE WITH THE CODE

IFEMA shall notify all its employees of this Code of Conduct and make its contents available to them. All present and future employees of IFEMA must accept the principles and rules of conduct set forth herein.
IFEMA expects a high level of commitment in complying with its code of conduct from all its employees. Any failure to comply shall be judged under legislative procedures and the IFEMA collective bargaining agreement.
Nobody, regardless of their level or position, is authorised to ask an employee to act in breach of this Code. No employee may justify improper conduct by invoking an order from a superior or ignorance of this Code.

6. ENTRY INTO FORCE

The Code of Conduct enters into force for all employees on the date of its publication, and shall remain in force until its withdrawal is approved.
It shall be revised and updated regularly by the Human Resources Department, which will take into account the suggestions and proposals of the Governing Board and employees, as well as IFEMA's social responsibility and good governance commitments.
Moreover, this document shall be immediately updated with any legal modifications and changes to texts also included in the Collective Bargaining Agreement.

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