Blecua Legal's Code of Ethics and Regulatory Compliance

The purpose of this Code is to raise awareness and instruct BLECUA LEGAL’s management, staff and collaborators on the company’s commitment to compliance with regulations and the guarantee of a corporate ethical culture.

Knowledge of and compliance with these regulations is binding on all BLECUA LEGAL personnel and collaborators involved, directly or indirectly, in the management of its affairs and in the conduct of its business.

I.- Anti-corruption policy.

The management wishes to make it clear that corruption is forbidden at all times and in any form whatsoever, ensuring through its Anti-Corruption Policy that all employees and collaborators of BLECUA LEGAL are aware of the company’s values and rules.
In order to prevent corruption, BLECUA LEGAL undertakes to comply with the following Anti-Corruption Policy:
Not to influence the will or objectivity of persons outside the Firm in order to obtain any benefit or advantage through the use of unethical practices or practices contrary to applicable laws.

Not to make or offer or accept, directly or indirectly, any payment, in cash or in any contractual form, or other benefit or advantage, to any natural or legal person in the service of any authority, entity, public or private, political party or candidate for public office, with the intention of obtaining or retaining business or other advantages.

Not to fund or otherwise support, directly or indirectly, any political party, its representatives or candidates.

Do not use donations to cover up improper payments.

Avoiding conflicts of interest that lead to negative consequences for the company, when private interests are placed above those of the Firm and decisions are taken that do not represent the best interests of the company.

Ensure that the administration and management of the Firm is organised in the social interest and not in the personal interest, thereby pursuing the creation of values and ensuring the fullest commitment to legality, security and proper risk management.

Promote and encourage its partners, suppliers, employees and collaborating companies to be aware of this policy and to adopt behavioural guidelines consistent with it.

Pay special attention to those cases in which there are indications of lack of integrity of persons or entities with which it does business, in order to prevent and avoid the laundering of money from criminal or illicit activities, complying at all times with BLECUA LEGAL’s Manual for the Prevention of Money Laundering and the Financing of Terrorism.

To faithfully and properly reflect all actions, operations and transactions of BLECUA LEGAL in the Firm’s records and systems.

To act in accordance with the principle of transparency of information, reporting all the Firm’s actions, operations and transactions in a truthful, clear and verifiable manner.

ii.- Industrial and intellectual property policy.

BLECUA LEGAL protects its industrial and intellectual property rights and respects the rights of third parties in this area, and undertakes to comply with the following guidelines:

The reproduction, use or distribution of third-party content or material protected by intellectual or industrial property rights by the directors, employees and collaborators of BLECUA LEGAL is prohibited, neither for their professional activity nor for personal or illegitimate gain.

Enhanced measures of diligence and care shall be adopted when handling information relating to the industrial and intellectual property rights of clients, collaborators or suppliers.

To protect against infringement of intellectual property rights, employees must not infringe copyright rights or licences to use software or any other material without due authorisation, and must at all times respect the intellectual property rights of products or goods provided by the company or by third parties with whom they have dealings in the course of their professional relationship.

All information and knowledge generated within the scope of BLECUA LEGAL is the property of the Firm under the terms provided for in current legislation. This information shall be handled with care and care shall be taken to ensure that BLECUA LEGAL’s industrial and intellectual property rights enjoy full legal protection.

BLECUA LEGAL encourages the information and knowledge generated in the company to flow within the organisation and among all its employees, in order to facilitate the management of the business and enhance the development of its employees. Employees have a duty to preserve the Firm’s information and knowledge by facilitating its dissemination to other employees who may have access to it by decision of the Firm, making it available to the systems set up within the structure for such purposes.

Managers, employees and collaborators acknowledge and accept the intellectual property rights and, where appropriate, the collective nature of all creations whose initiative and/or coordination and/or direction comes from BLECUA LEGAL, and therefore recognise the Firm as the owner of the industrial and intellectual property rights, undertaking to maintain and protect them during their professional relationship and to respect them once their relationship has ended.

iii.- Policy on confidentiality and secrecy of information and data protection.

The Firm, its staff and collaborators shall treat with due confidentiality and secrecy the existence and content of all documentation and information transmitted to them, disclosed to them or of which they become aware in the course of their business and the provision of their professional services, and undertake not to make any disclosure to third parties without due authorisation or without adopting the appropriate internal and legal measures.

The Firm, its staff and collaborators shall use such information and documentation solely for the performance of the work contracted and of BLECUA LEGAL’s business, so that it shall not be disclosed except to those employees and/or external collaborators who need to know it in order to perform the services contracted, and they shall be bound by the same obligations of secrecy and confidentiality.

In any event, BLECUA LEGAL shall not be liable for disclosing or using the information if it can be ascertained that it is in the public domain or that it has become public without any breach of its legal or contractual obligations.

Data and information are protected by technical security measures and against unauthorised access by third parties. The members of the firm comply with a strict protocol of data protection and security measures both in digital and paper form for the use of information systems.

iv.- Professional diligence, ethics and regulatory compliance.

The directors, lawyers, employees and collaborators of BLECUA LEGAL, in the performance of their respective work and activities, are obliged to act in good faith, respecting the most basic rules of professional diligence, the professional ethics rules of the legal profession, and the law in force, irrespective of their rank and scope of application.

In general, they shall fulfil the assignment conferred in accordance with the parameters and standards of quality that are required in accordance with the so-called “lex artis” in the understanding that it is an obligation of means and not of results; an obligation of means that not only imposes the rigorous observance of the corresponding procedural or extra-procedural law, but also a duty of special care and optimal execution of the contract of professional services.

The Firm shall be governed by strictly professional criteria, and its employees and collaborators shall be required to be serious, dedicated, of high quality, responsible and loyal.

BLECUA LEGAL undertakes to act within the framework of its ordinary activities in such a way as to comply with the provisions of national and EU antitrust and unfair competition legislation and, in particular, undertakes to avoid any actions that are considered by the legislator to be prohibited conduct.

v.- Work environment.

BLECUA LEGAL has a human resources policy that applies equality policies, guaranteeing equal access to work and professional development, without discrimination.

BLECUA LEGAL undertakes to provide all its executives and employees with decent and fair working conditions. Likewise, no abusive, hostile or offensive conduct or discrimination on grounds of race, sex, sexual orientation, belief, ideology, religion, social origin, disability, nationality, age or any other circumstance shall be tolerated among any member of the Firm, irrespective of rank or qualifications.

All employees shall enjoy the same opportunities for professional development, so that promotion decisions may only be based on objective parameters such as training, merit, effort and, if necessary, leadership qualities and skills. BLECUA LEGAL shall, to the best of its ability, help employees who so request to achieve their professional aspirations, provided that their behaviour or personal effort is consistent with the requests they make.

BLECUA LEGAL es consciente de la importancia que tiene en el desempeño correcto de las funciones de su personal, contar con una vida personal plena. Igualmente, BLECUA LEGAL conoce las dificultades de compaginar de forma satisfactoria el trabajo con la familia. Por ello, entre sus objetivos se encuentra fomentar, siempre dentro de las posibilidades del ámbito organizativo de la empresa, el equilibrio entre la vida personal y profesional adaptándose en la medida de lo posible a las situaciones y circunstancias personales y familiares de sus empleados y directivos.

BLECUA LEGAL prohibits any employee from starting work without being duly registered with the social security system or equivalent.

Work is guaranteed to be carried out in a health and safety environment in which occupational risks have been assessed and the necessary measures have been taken to combat them, by providing employees with the technical equipment necessary for the performance of their duties and any training courses necessary for the protection of workers.

In order to guarantee these labour rights, and as protection against any unlawful acts against workers, the Firm has procedures in place in the area of hiring and dismissals, and in the area of occupational risk prevention.

vi.- Prevention of criminal risks.

BLECUA LEGAL is committed to complying with the legal provisions and other rules of the legal system. To this end, it has approved a Regulatory Compliance Programme not only to prevent the risk of criminal charges, but also as the company’s internal protocol for strict compliance with the rules that apply to its business and legal relations, both internally, within its corporate structure and in its relations with its employees, and externally.

The Programme establishes the principles and guidelines that should govern the conduct of BLECUA LEGAL’s business activities and relations, in order to facilitate the conduct of day-to-day operations in an ethical, serious, professional and honest environment in accordance with the most elementary principles of contractual good faith and the law in force.

It is the responsibility of all managers and employees of the Firm to comply with the principles, guidelines and directives contained in the Programme and to ensure that they are properly complied with, so that if there is any suspicion of a breach of its contents, this must be reported through the channels established for this purpose, which shall always and at all times guarantee the confidentiality of the report, as well as the right to privacy, honour and self-image of all persons who participate or are involved, directly or indirectly, in the actions established.