Code of Conduct

What is the Code of Conduct?

The Code of Conduct, Ethics and Anti-Corruption (“Code”) of BB&G – RECYCLING, S.A. (“BB&G”) is the document that outlines the set of ethical and deontological principles and rules that govern the company’s operations, as well as the conduct of its Board Members, Employees, and Business Partners.

Who is it for?

The Code is intended for both internal and external audiences. Internally, it applies to all members of BB&G’s governing bodies, all Employees and Service Providers, as well as anyone who is, in any way, authorized to represent the company in its interactions with Clients, Suppliers, and Partners.
Externally, the Code also serves as a guide for the conduct of all entities that have an economic, institutional, or social relationship with BB&G, including, but not limited to, shareholders, investors, suppliers, clients, and business partners.

What is the purpose of the Code?

The Code was created with the fundamental purpose of:
a) Defining and sharing the principles that guide BB&G’s operations, as well as the ethical and deontological rules that should shape the behavior of all its Employees and Partners;
b) Promoting and encouraging the adoption of the principles and behavioral standards set out in this Code, both in the relationships among Employees and in their interactions with BB&G’s stakeholders;
c) Strengthening BB&G’s institutional image, which should be defined by excellence, high standards, responsibility, and integrity.

How is the Code disseminated?

The Code is shared with all Employees and Partners and will be published on BB&G’s website once it goes live.

BB&G’s Values

Ethics and Trust
Our main purpose is to create economic value based on ethical principles and sustainable development, with a long-term vision, grounded in trust-based relationships with our partners.

People at the heart of our success
We promote the development of everyone’s skills and competencies through continuous challenges, a readiness for change, and teamwork. We believe that all of this, supported by an internal culture that fosters meritocracy, are key factors in attracting, retaining, and developing highly capable and high-potential Employees.

Ambition
It is our guiding strength embodied in the continuous setting of goals that, while maintaining the resilient and courageous attitude of the organization, stimulate and challenge our capabilities, adding value to our clients.

Innovation
It is at the core and origin of our business.
We systematically break away from the conventional and have the ability to surprise the market. We believe that learning also comes from mistakes and failures, while being mindful of the importance of balancing this factor within regular risk standards.

Social Responsibility
We have an active sense of social responsibility, contributing to the improvement of the society we are part of, with a strong focus on environmental sustainability and the development of human knowledge.

Frugality and Efficiency
We value efficiency and healthy competition, striving to optimize the use of our resources and maximize their return.

Cooperation and Independence
We adopt a position of independence and autonomy in relation to central and local authorities, while always remaining open and willing to cooperate with governments to improve the regulatory, legislative, and social framework.

Guiding Principles of BB&G’s Activity

Clients
– We commit to treating our Clients with professionalism, respect, and loyalty.
– We provide our Clients with products and services of excellence in the sectors where we operate.
– We provide Clients with the necessary information for informed decision-making and ensure strict compliance with the agreed terms and conditions.
– We respect the privacy of Client information and, when the transmission of personal data is necessary, we commit to ensuring that such data will not be transmitted without the relevant consent, unless such consent is not legally required or the transmission is necessary for the fulfilment of a legal obligation.
– We do not engage in commercial practices that may discriminate against our Clients, exclude competitors from the market, or hinder the entry of new competitors.

Employees
– We base our human resources management policy on respect for the dignity, diversity, and rights of each individual. BB&G does not act in a discriminatory manner in its relationships with Employees, whether in recruitment, promotion, or dismissal.
– We treat each Employee fairly and foster equal opportunities for personal and professional development, providing appropriate training and rigorous, constructive performance evaluations. We hold each individual accountable and value them based on merit, allowing them to assume autonomy and responsibilities aligned with their ability and commitment.
– We respect the balance between work and personal life and encourage participation in extracurricular activities.
– We implement active policies promoting health, hygiene, and well-being in the workplace, ensuring compliance with applicable health, hygiene, and safety standards.
– We foster teamwork, the sharing of experiences, and common goals, thereby encouraging mutual support among Employees.
– Harassment: Any actions that could be considered harassment, whether moral (mobbing) or sexual, are contrary to BB&G’s values. We preserve a work environment that respects the physical and psychological integrity of all individuals working within the company.
– In line with the values and provisions outlined in this Code, BB&G has adopted a good conduct code regarding the prevention and response to workplace harassment, aiming to identify the phenomenon of “harassment” and actively contribute to its prevention, combating, and elimination.
– Privacy and Data Protection: We are committed to complying with and always enforcing data protection legislation in effect across the various geographies in which we operate, ensuring the effectiveness of the rights it grants to our Employees.

Diversity Policy
– We firmly believe that our success, in a world of constant transformation, is driven by our Employees.
– It is our fundamental premise to ensure that our recruitment processes prioritize both the alignment of candidates’ characteristics with the roles assigned to them, as well as the presence of diverse viewpoints, enriching the company.
– We also consider it essential that, in the selection of members for the governing and supervisory bodies, shareholders prioritize the approval of proposals for the election of social bodies based on diversity criteria, ensuring that these bodies encompass a broader range of knowledge, skills, experiences, and values.
– We believe that the key to our success lies in the diversity of our people, which brings different perspectives.
– Therefore, BB&G is committed to making efforts to promote diversity within its ranks and to prioritize policies and recommendations aimed at achieving the same goal, particularly regarding the appointment of its governing and supervisory bodies. This will always be assessed with consideration for the nature and complexity of the company’s activities, as well as the social and environmental context in which the company operates:

I. Professional Experience: The coexistence of diverse professional backgrounds and career paths brings the appropriate know-how for the company’s activities and strategy, particularly in areas such as finance, accounting, legal, corporate governance, investor relations, banking, strategy, corporate social responsibility, risk management, auditing, procurement and asset management, marketing, environment, and sustainability.
II. Gender: Gender diversity aims to promote the presence of different perspectives and styles, bringing innovation and creativity to the respective body.
III. Qualifications: The diversity of professional qualifications provides the company with the skills necessary for the development of its activities and defined strategy, considering their complexity. The inclusion of different areas such as engineering, economics, management, law, and others fosters a diversity of technical knowledge, which will lead to a better understanding of the issues, risks, and opportunities inherent to the company’s activities.
IV. Age: The group does not have a restrictive view on age limits, as we believe that age diversity will allow the combination of experience with innovation, resulting in a more innovative, agile, and balanced decision-making process.

– BB&G is committed to implementing and monitoring the alignment of this policy with the highest standards of corporate governance, reviewing it periodically (always with reasonable notice ahead of each elective general assembly – with regard to recommendations for the governing and supervisory bodies), while also considering the rules and principles of non-discrimination, including on the grounds of ethnicity, race, disability, or sexual orientation.

Data Protection
BB&G operates in strict compliance with the principles outlined in Regulation (EU) 2016/679 (General Data Protection Regulation) and national data protection legislation in all activities involving the processing of personal data under its responsibility.

Shareholders
– We always act to protect the interests of our shareholders with the aim of creating shareholder value.
– We ensure the accuracy, transparency, and truthfulness of the information provided to shareholders.
– We are committed to acting in accordance with applicable legislation and international best practices in the prevention of money laundering.

Suppliers and Business Partners
– We select suppliers based on clear and impartial criteria.
– We treat suppliers with respect, particularly by honouring the commitments made.
– We are committed to respecting the industrial and intellectual property rights of our suppliers and business partners whenever we are aware of them in the course of our activities and whenever we need to use them.
– We ensure that suppliers comply with the ethical, environmental, and social standards set forth in this Code.

Competition
– We respect market rules and criteria, promoting fair and honest competition and avoiding any practice that could impede, distort, or restrict it.
– We engage with competitors in a cordial manner and promote mutual respect, particularly for each party’s intellectual property and materials.

Public Authorities and Regulatory Bodies
– We respect and ensure the strict compliance with the legal and regulatory standards applicable to BB&G’s activities.
– We provide the necessary cooperation to Public Authorities in the exercise of their activities, particularly by providing timely information that has been requested.
– We preserve BB&G’s independence from public institutions and political parties, without prejudice to professional relationships. Under no circumstances do we finance political parties or organizations whose mission is essentially political.

Media
– We ensure that social media and all existing communication channels are used by BB&G in an ethically responsible manner.
– We avoid disclosing any information to the media that has not been previously authorized.

Environment
– We adopt the best environmental practices, particularly by promoting eco-efficient management, minimizing the environmental impacts of our activities, and using natural resources rationally.
– We promote, communicate, and encourage the adoption of good environmental and social practices among employees, partners, clients, and the community at large.
– We promote the use of information and communication technologies, contributing to sustainable development, particularly in the fight against climate change.

Community
– We promote and participate in initiatives aimed at raising social awareness and focused on promoting corporate responsibility.

Individual Conduct Rules

Interpersonal Relationships
– We demonstrate honesty, respect, cooperation, and clear communication with our employees and stakeholders, thereby fostering a positive work environment.

Responsibilities
– We respect the values and principles outlined in this Code, both in internal and external relationships.
– We guide our actions by strictly adhering to the assigned limits of responsibility.
– We report any alleged irregularities (behaviours or circumstances) that could jeopardize the development of the business or the good reputation of BB&G.

Professionalism and Entrepreneurship
– We act responsibly and rigorously, continually striving to enhance and update our knowledge to ensure the continuous improvement of our professional capabilities.
– We contribute to the company’s business in a consistent, creative, committed, and persistent manner.

Confidentiality and Use of Inside Information
– We preserve confidential facts or information, respecting the established rules regarding confidentiality.
– We do not use inside information for personal benefit or for the benefit of third parties.

Protection and Use of BB&G Resources
– We ensure the protection and proper maintenance of BB&G’s resources provided for the performance of our duties or to which we have access as a result of our role.
– We use BB&G’s resources rationally and efficiently, aiming to achieve the objectives for which they are designated.

Conflict of Interest
All employees must demonstrate loyalty to BB&G, and in this regard, they should:
– Avoid intervening in decision-making processes that involve, directly or indirectly, organizations with which they collaborate or have collaborated, or people with whom they have or have had family or friendship ties. If it is impossible to refrain from intervening in such processes, employees should report the situation to their immediate supervisor, so they can assess the situation and decide whether another person should be assigned.
– Refrain from participating in or engaging in any activities, whether paid or unpaid, with other companies or organizations that may undermine the fulfilment of their duties as an employee of BB&G, or that could conflict with the interests of the company. In this regard, employees must refrain from holding any position or engaging in any negotiations, either on their own behalf or on behalf of others, in competition with BB&G, and must not disclose information related to the organization, production methods, or business operations.

Gifts and Business Offers
– Aware that the offering and receiving of gifts and presents must be preceded by appropriate legal and social analysis, so as not to be perceived as a means of unduly influencing decision-making by BB&G or third parties, we have established mandatory internal compliance rules.
– We do not accept, for personal benefit, goods, services, or any advantages (including Christmas gifts) with an individual value exceeding €100 (one hundred euros) from clients, suppliers, service providers, or any other individual or legal entity that has or seeks to have commercial relations with BB&G. However, if refusal or return of such items becomes unfeasible or inadvisable, the goods and services in question shall be assigned to BB&G and donated to charitable organizations.
– The previous restriction does not apply to the offering or payment of goods or services, such as travel, meals, accommodation, or entertainment, granted by third parties to the Employee due to their position, within the scope of their representative duties and in the interest of BB&G. However, these exceptions must be previously communicated to the respective line manager.
– The offering of goods to any external entity by a BB&G Employee is only permissible if it is made on behalf of the company, is related to its business activity, and aligns with customary practices or standards of the sector. Such offerings must be previously approved by the respective line manager.
– The offering or acceptance of money, checks, or other legally restricted items is strictly prohibited under any circumstances and regardless of value.