Work Governance at WITH Madrid

At WITH Madrid, we recognize that our business success is built upon a foundation of ethical conduct, integrity, and responsible practices. As a technology and transformation company guiding businesses through their digital journeys, we understand the profound impact our work has on our clients, their stakeholders, and the broader community. This Work Governance framework outlines our commitment to conducting business according to the highest ethical standards, with particular emphasis on anti-corruption measures and respect for human rights.

We acknowledge and embrace the principles contained in the Code of Ethics, the Zero Tolerance against Corruption Plan, and the Human Rights Policy of our valued customers and partners. This document articulates how these principles are integrated into our own business operations and relationships with third parties, demonstrating our alignment with these essential values while reflecting our unique position as a Spanish SME specializing in tech transformation, data insights, and AI innovation.

Ethics forms the cornerstone of our business approach at WITH Madrid. We believe that maintaining trust with our stakeholders—clients, employees, suppliers, business partners, and the communities in which we operate—is essential to our long-term success and sustainability. Our ethical framework is built upon the following foundational principles:

• Transparency and Integrity: We conduct all business activities with maximum transparency and propriety. Our ISO 9001 certification demonstrates our commitment to quality management systems that ensure consistency and continuous improvement in our service delivery. We provide clear, accurate, and timely information to all stakeholders, avoiding any practices that could be considered misleading or deceptive.
• Responsibility and Accountability: We take full responsibility for our actions and decisions. Our management and employees at all levels are accountable for adhering to our ethical standards and for reporting any concerns or violations. We have established clear lines of responsibility and appropriate control mechanisms to ensure compliance with our ethical principles.
• Respect and Fairness: We treat all individuals with dignity and respect, valuing diversity and prohibiting any form of discrimination. We engage with our stakeholders fairly and equitably, ensuring that our business relationships are based on mutual respect and benefit. We recognize the importance of creating an inclusive environment where diverse perspectives are valued and contribute to innovation.
• Excellence and Innovation: We strive for excellence in all our endeavors, continuously seeking to improve our processes, services, and solutions. Our innovation is guided by ethical considerations, ensuring that technological advancements serve human needs and respect fundamental rights. We believe that true innovation must be responsible and sustainable.
• Compliance with Laws and Regulations: We strictly adhere to all applicable laws, regulations, and standards in Spain and in any jurisdiction where we operate. We go beyond mere compliance, aspiring to exemplify best practices in corporate governance and ethical business conduct. Our ISO 27001 certification demonstrates our commitment to information security management and data protection.

These principles guide our daily operations and strategic decisions, forming the basis for our specific commitments regarding anti-corruption and human rights detailed in the following sections.

WITH Madrid maintains a zero-tolerance approach to corruption in all its forms. We recognize that corruption undermines fair competition, damages trust, and hinders sustainable development. Our anti-corruption commitments are designed to prevent, detect, and address any form of corrupt practice within our sphere of influence.

• Prohibition of Bribery and Facilitation Payments: We strictly prohibit the offering, giving, soliciting, or receiving of bribes in any form, whether directly or through third parties. This includes facilitation payments, which are small payments made to secure or expedite routine governmental actions. Our employees and representatives are trained to recognize and resist requests for such payments.
• Gifts, Hospitality, and Entertainment: We have established clear guidelines regarding the giving and receiving of gifts, hospitality, and entertainment. These activities must be reasonable, proportionate, and transparent, serving legitimate business purposes rather than influencing decisions improperly. All such exchanges must be accurately recorded in our financial records.
• Conflicts of Interest: We require all employees to disclose any actual or potential conflicts between their personal interests and the interests of WITH Madrid. We have implemented procedures to manage such conflicts appropriately, ensuring that business decisions are made objectively and in the best interest of the company and its stakeholders.
• Due Diligence in Business Relationships: We conduct appropriate due diligence before entering into business relationships with third parties, including clients, suppliers, contractors, and business partners. This process helps us identify and mitigate corruption risks associated with these relationships. We expect our business partners to adhere to anti-corruption standards comparable to our own.
• Transparent Financial Practices: We maintain accurate books and records that properly document all financial transactions. Our financial practices are transparent and subject to appropriate internal controls and external audits. We prohibit any "off-the-books" accounts or inadequately identified transactions.
• Reporting Mechanisms: We have established secure and accessible channels for reporting suspected corruption, ensuring that individuals can raise concerns without fear of retaliation. All reports are taken seriously and investigated thoroughly, with appropriate corrective actions implemented when necessary.
• Training and Awareness: We provide regular training to our employees on anti-corruption policies and procedures, ensuring they understand their responsibilities and the consequences of non-compliance. We foster a culture where ethical conduct is recognized and valued.

Through these commitments, we aim to contribute to a business environment characterized by integrity, fairness, and transparency, aligning with the Zero Tolerance of Corruption Plan principles embraced by our customers and partners.

WITH Madrid recognizes the inherent dignity and equal rights of all individuals. We are committed to respecting human rights as defined in international standards, including the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights. Our approach to human rights is integrated into our business operations and relationships, reflecting our responsibility to respect human rights and avoid complicity in human rights abuses.

Employment Practices: We are committed to providing a safe, healthy, and respectful workplace for all our employees. This includes:

• Rejecting any form of forced, compulsory, or child labor in our operations and supply chain. We verify the age of all employees and ensure that young workers are protected from hazardous work.
• Promoting diversity and inclusion while prohibiting discrimination based on race, color, gender, language, religion, political or other opinion, national or social origin, property, birth, or other status. Our recruitment and promotion processes are based on merit and objective criteria.
• Respecting the right of employees to form and join trade unions of their choice and to bargain collectively. We engage in constructive dialogue with employee representatives to address workplace concerns.
• Prioritizing occupational health and safety, implementing appropriate measures to prevent accidents and injuries, and providing regular training on safety procedures. Our commitment to employee well-being extends to mental health and work-life balance.
• Offering fair and competitive compensation and benefits, complying with all applicable wage laws, including those relating to minimum wages, overtime hours, and legally mandated benefits.

Additional Human Rights Commitments:

• Data Privacy and Security: As a technology company handling sensitive information, we recognize our special responsibility to protect privacy rights. We have implemented robust data protection measures, complying with the General Data Protection Regulation (GDPR) and other relevant privacy laws. Our ISO 27001 certification demonstrates our commitment to information security management.
• Environmental Responsibility: We acknowledge the connection between environmental protection and human rights, recognizing that environmental degradation can impact the enjoyment of human rights. Our eco-designed website and EcoVadis sustainability rating reflect our commitment to minimizing our ecological footprint.
• Community Engagement: We respect the rights and interests of the communities in which we operate, engaging with them in a transparent and inclusive manner. We seek to make positive contributions to these communities through our business activities and initiatives.
• Supplier and Partner Relationships: We expect our suppliers and business partners to respect human rights in their operations. We incorporate human rights considerations into our procurement processes and contractual arrangements.
• Remediation: We are committed to providing appropriate remediation when we identify that we have caused or contributed to adverse human rights impacts. We have established grievance mechanisms that are accessible to potentially affected individuals and communities.

Through these commitments, we aim to ensure that our business activities respect and support human rights, aligning with the Human Rights Policy principles embraced by our customers and partners.

At WITH Madrid, we recognize that effective implementation and monitoring are essential to translate our ethical principles and commitments into consistent practice. We have established a comprehensive framework to ensure that our Work Governance policies are understood, applied, and continuously improved.

• Governance Structure: Our executive team holds ultimate responsibility for ethical conduct and compliance within WITH Madrid. They provide oversight and strategic direction for our Work Governance framework. Day-to-day implementation is managed by our Ethics Committee, which includes representatives from key departments and reports directly to the executive team.
• Policies and Procedures: We have developed detailed policies and procedures that operationalize our ethical principles and commitments. These documents provide clear guidance to employees on expected behaviors and decision-making processes.
• Risk Assessment: We conduct regular risk assessments to identify potential ethical, corruption, and human rights risks in our operations and business relationships. These assessments inform our priorities and resource allocation for risk mitigation.
• Due Diligence: We perform appropriate due diligence before entering into significant business relationships or undertaking major projects. This process helps us identify and address potential ethical issues proactively.
• Training and Communication: We provide comprehensive training to all employees on our Work Governance framework, with specialized training for those in high-risk positions or functions.
• Reporting Mechanisms: We have established multiple channels for reporting concerns or suspected violations, including an anonymous whistleblowing system. All reports are treated confidentially, and we strictly prohibit retaliation.
• Monitoring and Auditing: We regularly monitor compliance with our Work Governance policies through internal audits and reviews. Our ISO 9001 and ISO 27001 certifications require regular external audits.
• Continuous Improvement: We are committed to continuously improving our Work Governance framework based on lessons learned, stakeholder feedback, and evolving best practices.
• Transparency and Reporting: We report on our Work Governance performance to our stakeholders, including information on significant risks, incidents, and improvement initiatives.

Through this implementation and monitoring framework, we aim to ensure that our ethical principles and commitments are consistently reflected in our business practices, creating sustainable value for all our stakeholders.

At WITH Madrid, our Work Governance framework represents our commitment to conducting business with integrity, respect for human rights, and zero tolerance for corruption. As we guide our clients through their tech, data, and AI transformation journeys, we remain steadfast in our dedication to ethical practices that create sustainable value for all stakeholders.

We recognize that adherence to these principles is not only the right thing to do but also essential for building trust, managing risks, and ensuring our long-term success. By aligning our practices with the ethical standards embraced by our customers and partners, we strengthen our business relationships and contribute to a more responsible business environment.

This framework is a living document that will evolve as we grow and as best practices develop. We welcome feedback from our stakeholders and are committed to continuous improvement in our governance practices. Through ongoing dialogue, monitoring, and adaptation, we will ensure that our Work Governance framework remains relevant and effective in guiding our business conduct.

We invite all our employees, clients, suppliers, and other stakeholders to join us in upholding these principles, creating a business ecosystem characterized by integrity, respect, and shared prosperity. Together, we can demonstrate that business success and ethical conduct are not only compatible but mutually reinforcing.

This Work Governance framework was approved by the executive team of WITH Madrid and is reviewed annually to ensure its relevance and effectiveness.