Code of Ethics

Introduction

The Code of Ethical Conduct is our guide to proper conduct, together with the established working rules and procedures, to ensure that the right thing is done and that as a logical consequence no offence is committed within the company.

The Code constitutes a guide for all employees of CALM ISLAND PROPERTIES MALLORCA SL in their professional performance in relation to their daily work, the resources used and the business environment in which it takes place. It provides guidelines that clarify the basic principles of all management and interpersonal relationships with colleagues, collaborators, bosses, suppliers, clients, shareholders and in general any person with a direct or indirect interest in the activity carried out by the company. Our actions are based on respect for our corporate values, and employees will adapt their actions to principles of respectful behaviour with regard to business ethics and with professionalism, with the aim of being a benchmark in these terms and being recognised as such.

Scope of application

This Code is aimed at all employees of CALM ISLAND PROPERTIES MALLORCA SL, regardless of the type of contract that determines their employment relationship, the position they occupy or the place where they carry out their work. There is an obligation on those related to the company to inform their main suppliers of the existence of this Code, which will be available for consultation on the company’s website https://calm.remax.es/.

Values

Our values represent our identity as a group. We are different because the people who work at CALM ISLAND PROPERTIES MALLORCA SL make this company a unique and differentiating project. We are fast, we know how to listen, we seek innovation, we are helpful and we work as a team in a thorough and transparent way.

• We make quick decisions and act quickly and dynamically.
• We swiftly focus on the solution to a problem by proposing realistic, quality and viable alternatives.
• We quickly adapt to changes and the demands of the professional environment.
• We listen carefully to our internal and external customers in order to know exactly what their needs are and to propose appropriate solutions.
• We have the eyes and ears of the customer in any operation we carry out, continually asking ourselves about their satisfaction.
• We listen actively, with an open attitude and respect for the opinion of all parties involved in a situation.
• We actively seek opportunities to improve products and services and create new business opportunities.
• We take advantage of opportunities and problems to provide innovative solutions.
• We constantly update our technological knowledge in order to be pioneers in innovation.
• We understand our customers’ needs and expectations in order to develop and apply solutions that increase their satisfaction.
• We attend to our clients in an efficient manner, maintaining at all times an agile and resolute behaviour that enhances the credibility and reputation of the company and its professionals.
• We attend to our clients with the utmost interest and strive to accomodate their demands, this being the priority characteristic of the attitude of all our professionals.
• We know how to work in multidisciplinary teams, from different units, companies and countries, generating a climate of trust and mutual respect.
• We cooperate with the rest of the organisation, assuming commitments aimed at achieving common objectives.
• We direct our efforts towards the same result, taking into account the contribution of each member, however small it may seem.
  • We respect differences, opinions and diversity.
  • We are respectful of the environment and sustainability policies.

Principles of ethical behaviour

The ethical behaviour that governs this company is based primarily on:

Good faith

We always act in accordance with the principles of loyalty and good faith towards the company, our superiors, colleagues and collaborators with whom we have dealings. The pursuit of achievement and the spirit of self-improvement are emphasised. The concern for achieving the objectives set must be constant and continuous. We encourage optimistic versus pessimistic attitudes. We subordinate personal objectives to the Company’s general objectives. We ensure that there is no conflict between the two, and we act giving priority to the interests of the company over personal interests or those of third parties. We do not engage in outside interests that divert our time and attention from responsibilities or require work during dedicated time.

Honesty

All employees of CALM ISLAND PROPERTIES MALLORCA SL undertake to declare any personal or professional relationship that could condition our behaviour as employees of the Company. Furthermore, as employees of CALM ISLAND PROPERTIES MALLORCA SL, we do not accept undue compensation or advantages. We instil honesty and professional ethics in our normal commercial and professional relations in the performance of our work, both in the private sector and in our relations with the Public Administrations. We do not offer gifts or promise undue favourable treatment to third parties, whether public or private, in order to obtain an advantage. We promote trust in order to declare any gifts or advantages we may obtain from third parties and make them available to the company. Any personal or professional relationship that affects the interests of the Company is reported to the manager. We do not allow personal or family relationships in direct dependence or within the same organisational unit.

We avoid conduct that is contrary to free competition or that constitutes an act of unfair competition. In advertising campaigns, we provide clear and truthful information.

Respect

Each and every one of us is responsible for creating an atmosphere of cordiality and friendliness in our environment. We promote respect and trust between people. We appreciate diversity in opinions, training and culture as a source of knowledge and competitive advantage. We are careful about the language we use when talking about third parties and we encourage the non-existence of defamatory guidelines and comments inside and outside the organisation. We promote respect for real equality of opportunity between men and women, avoiding any scenario of direct or indirect discrimination. No person employed at CALM ISLAND PROPERTIES MALLORCA SL is discriminated against in the professional sphere due to race, physical disability, religion, age, nationality, sexual orientation, sex, political opinion or social origin. We maintain a working environment free of any form of discrimination and any conduct involving harassment of a personal nature, and we do not accept any form of physical, sexual, psychological or verbal harassment or abuse. We respect the environment and collaborate with the sustainable development of society.

Confidentiality

We refrain from providing, internally or externally, confidential data on people and/or activities carried out in the Company. We do, however, provide the data that is necessary for other employees of CALM ISLAND PROPERTIES MALLORCA SL to carry out their duties correctly, with strict respect for this duty of confidentiality. We avoid conduct that is contrary to free competition, or that involves an act of unfair competition. In advertising campaigns we offer clear and truthful information.

Principles of ethical behaviour, respect, confidentiality and use of information

We comply with the regulations on the protection of personal data to which we have access due to our job. The employees of CALM ISLAND PROPERTIES MALLORCA SL are characterised by a markedly proactive attitude in the treatment of confidential information. Information is the property of the Company and must be shared whenever it is beneficial and necessary for the Company. We conduct ourselves accordingly:

We provide those in charge with accurate, necessary, complete and timely information about the progress of the activities of our area; and to our colleagues, that which is necessary for the proper performance of their duties.

We maintain the professional secrecy of the data, reports, accounts, balance sheets, strategic plans and other activities of CALM ISLAND PROPERTIES MALLORCA SL and its people, which are not of a public nature, and whose publicity may affect the interests of the company. We will not provide information about them, except when we are expressly authorised to do so.

We obtain information from third parties in an ethical and legitimate manner, rejecting any information obtained improperly or that involves a breach of company secrecy or confidentiality.

In the event of any doubts about the appropriate treatment of the information, we request the assessment of our manager about the correct cataloguing of this information.

We may not use the programmes, computer systems, manuals, videos, courses, studies, reports, etc., created, developed or perfected by CALM ISLAND PROPERTIES MALLORCA SL for our own purposes or those of third parties, nor for profit or gain, given that the company retains the intellectual property of these at all times.

In general, we maintain the strictest confidentiality in the use of internal knowledge outside the company, preserving our know-how.

We will only use computer systems, software, material, reports, etc. for which CALM ISLAND PROPERTIES MALLORCA SL has acquired the corresponding licence, respecting at all times the intellectual and industrial property of these.

The use of computer equipment is subject to the information security policy of CALM ISLAND PROPERTIES MALLORCA SL in order to avoid damage to third parties and/or the company itself.

We will not use access to the systems to act fraudulently or for our own benefit.

Decalogue of questions to ask before making a decision

Asking yourself these questions will help you decide on the behaviour to follow.

• Is it against the work rules?
• Does it seem the right thing to do?
• Is it legal?
• Will it have a negative effect on my reputation or that of the company?
• Who else might be affected by this (other people in the organisation, customers, suppliers)?
• Would I be embarrassed if others knew that I had decided to act in this way?
• Is there an alternative solution that does not pose an ethical conflict?
• How would I look if it were published in the newspapers?
• What would a reasonable person think?
• Will I be able to rest easy?

PRINCIPLES OF PROFESSIONAL BEHAVIOUR

Passion for the client

All the employees of CALM ISLAND PROPERTIES MALLORCA SL aspire to offer our clients a product of the highest quality and to have an excellent level of service. Excellence and quality of service are constant guidelines for action, promoting a healthy concern for continuous improvement. The resources provided by the company seek to promote innovation and the development of customer services, with profitability criteria. All of us, regardless of the functional area in which we work, are committed to customer satisfaction. We promote honest attitudes towards the customer.

Efficient management

The employees of CALM ISLAND PROPERTIES MALLORCA SL work efficiently during the working day, making the most of the time and resources that the company places at our disposal in a rigorous and rational manner. We all give the dedication required by the performance of our duties, aspiring to achieve results in the best and most productive way possible. The Company provides us with all the resources necessary to carry out our work and improve our performance by optimising our time and access to the information we need to fulfil our responsibilities. We must therefore make appropriate and reasonable use of them according to our professional needs. We do not engage in personal activities during working hours that interfere with or prevent you from fulfilling your work responsibilities.

We use the Company’s e-mail, internet access and, in general, the Company’s computer systems for work-related purposes and purposes only, and their use for personal use is expressly prohibited. We expressly authorise the Company to monitor their use. Unacceptable use of Company communications systems includes processing, sending, retrieving, accessing, viewing, storing, printing or otherwise disseminating materials and information that is fraudulent, harassing, threatening, unlawful, racial, sexist, obscene, intimidating, defamatory or otherwise inconsistent with professional conduct. In terms of occupational health and safety, we will comply with the preventive measures, using the individual and collective means of protection that the company has at its disposal. In the event of having a team under their responsibility, those in charge will ensure that the members of said team carry out their activity in safe conditions.

Team attitude

As employees of the company, we encourage teamwork and recognise the contribution of others in achieving common results. As members of a team we contribute with equal commitment both inside and outside our area. The teamwork attitude dominates and outshines any performance at the individual level. An outstanding individual is also an outstanding team player, and therefore there is no conflict between this behaviour and individual excellence. Individual interest does not take precedence over team interest. We avoid passive attitudes: we do not get carried away and we do not stand on the sidelines. We encourage enthusiasm and commitment to the group and therefore to the organisation. We act in a spirit of cooperation, providing the other areas and departments of the organisation with the knowledge and resources that facilitate the achievement of the company’s objectives.

Reputational care

We consider the company’s image and reputation as one of its most valuable assets in order to maintain the trust of its customers. We monitor the respect and correct use of the corporate image and reputation by everyone in the company’s environment. The brand image is visually embodied in our company logo, for which there are rules of use that protect its use and which we must respect. We are especially careful in any public intervention, and must have the necessary authorisation to speak to the media, participate in professional conferences or seminars and in any public media, as long as they appear as employees of CALM ISLAND PROPERTIES MALLORCA SL. We are all part of the corporate image and therefore we assume an ethical and responsible conduct that allows us to preserve the image and reputation of the company. At no time will we act in a way that could damage the company’s image. The way we communicate, conduct ourselves and our own personal image will be in line with the professional context in which we operate.

Professional development

Our professional growth and that of our teams is our key to being competitive. As employees, we are responsible for our professional growth, and therefore it is our duty to be constantly updated with the knowledge and techniques necessary for the efficient performance of our work. People in charge of teams must pay attention to the motivation and professional development of their collaborators, committing themselves to provide them with development opportunities based on merit and their professional contribution. To this end, they will encourage their continuous learning, recognise their efforts in a specific way and objectively assess their achievements, drawing up the necessary action and support plans for their development.

INFORMATION SYSTEM (COMPLAINTS CHANNEL)

In compliance with the provisions of article 25 of Law 2/2023, of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption, we hereby inform you that, in accordance with the essential principles of this channel, all information received will be analysed independently and confidentially. In all cases, the utmost confidentiality and, where appropriate, anonymity will be guaranteed in the process of investigating the information received, in order to protect the identity of the informant and the persons concerned and their reputation. Only persons strictly necessary to the process shall be informed. Where appropriate, the competent authority shall be notified of facts that may constitute a criminal, administrative or labour offence.

The absence of reprisals of any kind against the whistleblower is also guaranteed. If such reprisals are confirmed, the perpetrators will be investigated and, where appropriate, punished.

Any fraudulently false, malicious or abusive information may give rise to proportionate action against the whistleblower.

We also inform you that, for the management of the internal information system (complaints channel) of CALM ISLAND PROPERTIES MALLORCA SL, the COMPLYLAW ETHICAL CHANNEL solution is used, which complies with the privacy and data protection requirements set out in the aforementioned regulation. This management tool also complies with the legal requirements of acknowledgement of receipt of the communication to the informant within 7 days; and a maximum period of 3 months to respond to the investigative actions, except in cases of special complexity that require an extension of the period, in which case, this may be extended up to a maximum of three additional months.

Entry into force of the code of conduct, interpretation and monitoring

The Code of Ethical Conduct came into force after its approval on 10/01/2024. The present Code of Ethics has been implemented and approved and was ratified and approved on 10/01/2024.

The Code will be communicated to all members of the Company. It will remain in force until its modification or cancellation is approved, which will be duly communicated.

Each of us is responsible for reviewing and following this Code, and we comply with all applicable laws, policies and guidelines. This Code attempts to address many of the situations we face on a day-to-day basis, but it cannot address every circumstance.

Try to get help from:

• Your manager
• Your HR manager
• Your service coordinator if you are an external collaborator.

All professionals must report to our manager any conduct that we believe, in good faith, to be a breach of the Code of Ethical Conduct.

If any of the above three is involved in the situation we wish to report or cannot or has not adequately addressed our concerns, we will inform a more senior manager or the person responsible for HR in the area or the company’s criminal compliance officer, and all personnel are informed that an Ethics Channel is available to all personnel through which it is possible to report, in complete confidentiality, any behaviour or facts contrary to ethics, to the law in force, to this Code of Ethical Conduct or to the good corporate governance practices that govern our Company, with special emphasis on those that could have criminal implications.

We do not discriminate or retaliate against employees for reporting, in good faith, actual and proven violations. The Nomination and Remuneration Committee will ensure compliance with this Code, resolve any incidents or doubts about its interpretation and take appropriate measures to ensure compliance.

Failure to comply with this Code may give rise to disciplinary measures, including the possibility of dismissal and, where appropriate, legal action.