The General Code of Conduct and Prevention of Criminal Risks (hereinafter, the “Code” or “Code of Ethics”) includes the directory of ethical principles and rules of conduct which govern the behaviour of all the professionals and third parties associated with lyntia Networks, S.A.U., and the companies in its Group set out in Schedule 1 (hereinafter “lyntia”).

In relation to the Group, this Code of Ethics is applicable to the following: (1) members of the various management bodies; (2) directors; and (3) employees (including interns and personnel on work experience) regardless of (i) the position or post they hold, (ii) the place where they work, (iii) the powers given to them, or (iv) their professional relationship; (hereinafter, the “Code Subjects”); and (4) all relationships lyntia has with third parties, by way of example but not of limitation, suppliers, sub-contractors, collaborators, investors, public authorities and customers (hereinafter, the “Interested Third Parties”).


The specific PURPOSES of the Code are as follows:

    • To prevent, by following the Code, any Code Subject from committing any offence which may affect lyntia.
    •  To ensure the effectiveness of the rules and control procedures which minimise the risk of unlawful conduct by the Code Subjects.
    •  To inform the Code Subjects of the consequence which may arise in the event that they behave unlawfully.
    •  To state clearly that lyntia condemns any conduct which is against the Law.
    •  To seek the exercise of due diligence when carrying out its business activity and, in this way, comply with the requirements included in the Criminal Code.
    •  And, in the last instance, give coverage and support to new, effective measures for improved detection and control of offences.


The Code Subjects are under the obligation to:

    •  Be familiar with and comply with the Code and collaborate in facilitating its implementation at lyntia.
    •  Attend and take part in all training events called by lyntia for good understanding and application of the Code of Ethics.
    •  Notify the Compliance Committee of any breach or any indication of a breach of the Code of which they become aware.
    •  Make the Code of Ethics known to the Interested Third Parties they work with.
    •  Use lyntia’s Speak Up platform to report any failure to comply with regulations.


Given its nature, the Code of Ethics does not cover all possible situations; rather it establishes the criteria to guide the Code Subjects’ behaviour in their relations with lyntia and with third parties due to their connection with lyntia.



lyntia considers that the trust of its shareholders, customers, suppliers and external collaborators, along with the social environment in which it carries out its business, is based on the integrity and responsibility in the professional performance of each one of its experts and directors.


Integrity is understood to be ethical, honest, transparent behaviour in good faith.


Professional responsibility is understood to be proactive and efficient behaviour, focussed on excellence, quality and the willingness to serve.


lyntia requires all its experts and directors to behave with integrity and responsibly when performing their duties.


Furthermore, lyntia also requires the Interested Third Parties to behave in accordance with these criteria.



The ethical principles set out in this Code are the pillars on which lyntia’s business is founded. All actions taken by the Code Subjects, as a result of their association with lyntia, must be guided by them.


3.1   Respect for the law and human rights

lyntia declares its commitment to compliance with the law, respect for human and labour rights as recognised under Spanish and international legislation, rejection of child labour and forced labour, and its commitment to respect freedom of association and collective bargaining.


The Code Subjects must:

    •  Comply with the Law and lyntia’s internal regulations which are applicable to their work, with full respect for the human and labour rights recognised in Spanish and international legislation.
    •  Be familiar with the legislation which is applicable to their work, requesting, as appropriate, the necessary information from their superior.
    • Avoid any conduct which, even though it is not in breach of the law, may harm lyntia’s reputation and/or negatively affect its interests.
    •  Avoid conscious collaboration with third parties in breach any law, or taking part in any action which may compromise respect for the principle of legality.


3.2   Respect for people. Conduct with colleagues

lyntia seeks to promote a working environment which facilitates its employees’ professional and personal development. The diversity of abilities and experience is one of lyntia’s sources of success.


3.2.1 Responsibility and teamwork

The Code Subjects must make decisions within the scope of their responsibilities, respecting the applicable rules and procedures and lyntia’s criteria governing conduct, and must exercise their responsibilities in accordance with its style of management.


In lyntia’s style of management, trust and team value are important. This involves respect, mutual support and fluent communication. lyntia encourages a cooperative environment and teamwork for the best use of all abilities and resources.


The Code Subjects must work (i) in cooperation, for the best use of all abilities and resources, and (ii) efficiently during the working day, capitalising the time and resources lyntia makes available to them, and endeavouring to give the maximum value to all the processes they take part in.


3.2.2 Zero tolerance for discrimination, bullying and intimidation

Bullying, abuse, intimidation, lack of respect and consideration or any other kind of physical and verbal aggression are unacceptable and will not be allowed or tolerated in the workplace. Code subjects in charge of personnel in lyntia’s organisational units must advocate and ensure, with all available means, that such situations do not occur.


All Code Subjects and, in particular, those performing management duties, will promote, at all times, and at all professional levels, relationships based on respect for the dignity of others, participation, equity and reciprocal collaboration, fostering a respectful working environment with the aim of achieving a positive working climate.


There must be no discrimination, or discrimination be allowed, on the grounds of gender, race, age, nationality, religion, sexual orientation, disability, family origins, language, political ideology, political or union membership or any other quality which is not objectively related to working conditions, or the consideration of which, for these purposes, is prohibited by the applicable legislation.


3.2.3 Work/Life Balance

In order to put into practice lyntia’s commitment to corporate social responsibility to improve the quality of life of its employees and their families, the Code Subjects will promote a working environment that is compatible with personal development, helping the people in their teams to balance, in the best possible way, the requirements of the job and their personal and family life needs.


3.3 Personal development and equal opportunities

Providing the equal opportunities for access to work and professional promotion is a basic principle of lyntia’s way of working.


Recruitment and promotion of lyntia’s employees are based on skills and the performance of professional duties, and on the criteria of merit and ability. As a result, the Code Subjects taking part in the recruitment, hiring and/or professional promotion processes will act with objectivity in their actions and decisions, with the aim of identifying the people who best fit the profile and needs of the job to be filled, fostering equal opportunities at all times.


The people with management or leadership posts at lyntia must act as facilitators for the professional development of the people they are in charge of, in such a way that enables their professional growth at lyntia.


lyntia’s Code Subjects, for their part, undertake to actively take part in the training plans that lyntia makes available to them, getting involved in their own development and committing to keeping the necessary know-how and skills up-to- date, in order to foster their professional progress and give value to customers and shareholders.


3.4 Health and safety in the workplace

lyntia considers the Code Subjects’ health and safety at work to be fundamental to achieving a comfortable, safe working environment, with a priority target being permanent improvement to working conditions. For this reason, lyntia will impel the adoption of health and safety in the workplace policies and will take the preventive measures provided for in current legislation.


Furthermore, it will procure the application of its rules and policies for health and safety in the workplace by the collaborating companies and suppliers it works with and will give its employees the resources and know-how needed to be able to perform their duties safely in a healthy environment.


The Code Subjects will, at all times, respect the applicable preventive measures for health and safety at work, using the resources set up by lyntia and ensuring that the members of their teams carry out their activities in safe conditions.


3.5 Use and protection of assets

The Code Subjects will always act in lyntia’s best interest, making suitable use of the means made available to them and avoiding actions which may result in damage to the company. They will abstain from using business opportunities that are of interest to lyntia for their own benefit.


For its part, lyntia will make the resources needed to perform their professional activity available to its employees and undertakes to provide the means to protect and safeguard them.


The Code Subjects must make suitable, efficient use of the resources made available to them by lyntia to carry out their professional work. They may not be used for private purposes, unless this involves an occasional use which is moderate, proportional to the circumstances and is not detrimental to lyntia. Furthermore, internal rules and policies must be applied to their use and the necessary measures taken to prevent their loss, theft, damage or waste. If in doubt, speak to Human Resources.


All materials belonging to lyntia must be returned to lyntia when their return is requested, when they are no longer needed to carry out the professional work and, at any event, on termination of the employment or professional relationship.


E-mail and computer tools are working tools which must be used to carry out jobs.


In accordance with its internal privacy policies, lyntia may monitor communications and files sent by users using lyntia’s resources and systems, in the event that there is reason to suspect that improper use is being made of lyntia’s resources, or there are indications of a possible breach of this Code, lyntia’s internal rules or the Law. Monitoring or access will, at all times, respect the users’ right to privacy, and be in compliance with current legislation.


The Code Subjects will ensure prevention and control of such offences as may be committed using information technology and, amongst them, spreading viruses, denial-of-service attacks or industrial espionage.


3.6 Corruption

lyntia will not tolerate an act of bribery or corruption in any form whatsoever.


Corrupt behaviours are those that include possible unjustified economic advantages or benefits, both if (i) they are received or accepted by lyntia employees, executives and/or the Board of Directors, as well as if (ii) they are the ones offering, giving or promising said advantages or benefits, whether to or from the private or public sector.


The Code of Ethics Subjects must:

    • Abstain from requesting or accepting any kind of payment, commission, gift or remuneration in relation to their professional work at lyntia from customers, suppliers, agents, or any other third party, or profiting, in any other way, from the position they hold at lyntia for their own benefit. This restriction does not include gifts which are in line with the gifts, invitations, meals and travel policy included in Schedule 2.
    • Abstain from making, either directly or indirectly, or accepting payments, gifts or considerations of any kind which are not considered to fall within the normal course of business, in order to exercise undue influence on commercial, professional or administrative relations, whether with public or private entities.


The common theme of corruption is obtaining an unjustified benefit or advantage, of any kind, for the offender or for a third party, with the purpose of unduly favouring them.


In order to fight corruption, the members of the different governing bodies, executives and employees must avoid the following conduct:

    • Corruption in business or corruption between individuals: Under no circumstances will we offer, receive, accept or request any unjustified benefit, payment or advantage of any kind to unduly obtain a contract, sell goods or obtain favour of any kind.
    • Corruption in business – Corruption in international trade transactions: In no case will we attempt to have any civil servant or national or international public authority act illegally in favour of lyntia or against a third party by offering them money or gifts of any kind.
    • Bribery of a public official: We may not reach an advantageous agreement with or receive preferential treatment from the Administration or public employees by making offers and/or promises, whether directly or through intermediaries, of personal or financial favours (money, loans, monetary benefits, etc.).
    • Bribery: We may not offer or give gifts or payment of any other kind to an authority, public civil servant or person who exercises public functions so that they act against the duties of their position or so that they do not perform or delay a duty that they must perform.
    • Influence peddling: We may not influence a public authority or civil servant in any way by taking advantage of a personal relationship with said figure or with another civil servant to obtain a resolution that could directly or indirectly create any type of direct or indirect benefit for lyntia.
    • Extorsion: We may not force others, through violence or intimidation, to carry out or omit an act or legal transaction to the detriment of their assets or those of a third party, whether motivated by profit or not.
    • Money laundering: If it is known or suspected that assets are of a criminal origin, we may not acquire them, possess them, use them or transfer them. lyntia will comply with all national and international provisions to prevent money laundering. Code Subjects must remain alert for situations in which there may be indications of a lack of integrity of the people or entities with which lyntia deals.
    • Gifts: The provisions of Schedule 2 of this Code of Ethics shall apply.
    • Conflicts of interest: The provisions of section 3.9 of this Code of Ethics shall apply.
    • Financing of political parties: lyntia prohibits donations to political parties and organisations associated with political parties, and shall not sponsor any event whose exclusive purpose is political propaganda.
    • Donations: Donations to other entities, including any charitable organisations, should be exceptional, and shall always require the prior approval of the Compliance Committee, after notifying the Financial Director, pursuant to the provisions of Schedule 3.


3.7 Corporate image and reputation

The Code Subjects must take the greatest care to preserve lyntia’s image and reputation. Whenever they appear or present themselves as lyntia’s employees, experts or directors on any social media network they must ensure correct, suitable use of lyntia’s image and respect for this Code.


The Code Subjects must be particularly careful with any public appearance, and must have the necessary authorisation to appear before communications media, take part in professional workshops or seminars and in any other event that may be broadcast publicly, wherever lyntia’s employees appear. At any event, the information communicated must be transparent, accurate and coherent.


lyntia carries out its business activities respecting political pluralism. lyntia does not make contributions to election campaigns or donations to political parties. Any other donation must be in line with the provisions of Schedule 3.


If the Code Subjects exercise their legitimate right to take part in political activities, they must do so in a personal capacity, without using lyntia’s resources, outside working hours, avoiding any reference to lyntia and without compromising their professional objectivity or affecting lyntia’s commitment to political neutrality in any way.


3.8 Loyalty to lyntia and conflict of interests

A conflict of interest arises in circumstances where the personal interests of the Code Subjects, either directly or indirectly, are contrary to, or impact, the company’s interests, interfere with upright performance of their professional duties and responsibilities, or personally involve them in any of the company’s financial transactions or operations.


lyntia considers that its relationship with its employees should be based on loyalty, which arises from communal interests.


Code Subjects must inform lyntia of family, economic or other ties that they may have with clients and/or suppliers that could generate a conflict of interest, as well as their participation and that of their family members in the governing bodies of other companies that may have a conflict of interest with lyntia.


When carrying out their professional duties, the Code Subjects must act with loyalty and defend lyntia’s interests. Furthermore, they must avoid situations which may give rise to a conflict between personal interests and lyntia’s.


To that end, lyntia employees, executives and/or the Board of Directors must abstain from representing lyntia and partaking in decision-making in any situation in which they have a personal interest, whether directly or indirectly.



3.8.1 General guidelines for preventing conflicts of interest

In order to prevent conflicts of interest, the people bound by this procedure must, in all cases, follow the below general action principles:

    • When performing their professional activities, the people bound by this procedure must maintain upstanding, diligent behaviour, always respecting the law and internal regulations.
    • People bound by this procedure must guarantee equal treatment of clients, employees and third parties who have an interest in lyntia, and always avoid unduly favouring some over others due to their condition or position at lyntia or with respect to lyntia.
    • People bound by the procedure must always act such that their personal interests do not prevail over lyntia’s interests.
    • People bound by the procedure must always safeguard lyntia’s legitimate interest.


3.8.2 Prohibited activities

Examples where there may be a conflict of interest include, but are not limited to, the following:

    • Participating in hiring a candidate with whom there is a connection.
    • Participating in selecting a supplier when you have an interest in a company that may compete in the process, whether directly or through family members.
    • Giving or receiving gifts, commissions or any type of economic compensation related to your activity in the organisation, beyond those established in Schedule 2 of the Code of Ethics, which establishes the guidelines for gifts, invitations, meals and travel.
    • Participating in activities or carrying out business contrary to lyntia’s interest or which compete with lyntia and/or could negatively affect your full dedication to and fulfilment of your duties.
    • Communicating information about new products, new developments, sales strategies and any other confidential information from the company in a self-interested way to people who may have interests in lyntia’s competitor companies.


3.8.3 Managing conflicts of interest

The people in charge of monitoring potential conflicts of interest on their teams are executives, who must bring their decisions on this matter to the Compliance Committee for their validation, recording and monitoring.


People who are in any situation that may pose a potential conflict of interest should report it to their direct supervisor and they, in turn, to their manager and to the Compliance Committee.


If a conflict of interest is confirmed, the person involved will not participate in the decision-making process, nor will they have access to the confidential information that affects said conflict.


In the case of unfair competition, any such activities must cease immediately; otherwise, the lyntia Disciplinary System shall apply.


Recording conflicts of interest


The lyntia Compliance Committee must design a register of existing conflicts of interest. Said register must contain at least the following information:

    • Person involved in a conflict of interest
    • Date the company became aware of the conflict of interest
    • How the company became aware of the conflict of interest
    • Department and supervisor of the person involved
    • Description and nature of the conflict of interest
    • Resolution of the conflict of interest and measures taken
    • Date the conflict of interest was resolved


The conflicts of interest register must be duly updated as conflicts of interest evolve and as new cases of conflicts arise.


3.8.4 Oversight bodies

According to current legislation, lyntia’s exercise of due diligence requires the implementation of ongoing oversight mechanisms, as well as the designation of internal oversight bodies to monitor the controls implemented and potential criminal risk.


The Board of Directors has entrusted the Compliance Committee with this oversight and monitoring task. The Committee has been given the sufficient independence both in terms of oversight power and initiative.


lyntia reserves the right to carry out oversight within the scope of current legislation, with the purpose of verifying application of the Procedure to Manage Conflicts of Interest and preventing activities that may affect compliance with said procedure and applicable legislation.



3.9 Information processing


3.9.1 Correct, accurate information

lyntia considers that information and know-how are one of its main assets, and essential for company management, for which reason they should be subject to special protection.


lyntia undertakes to provide precise, complete and accurate information as a basic principle in all of its actions, and therefore Code Subjects must truthfully, correctly and accurately transmit all information that they must communicate, both internally and externally, and under no circumstances will they knowingly provide incorrect or inexact information that may mislead the person receiving it.


All Code Subjects inputting any kind of information into lyntia’s computer systems must ensure that it is meticulous and reliable.


3.9.2 Confidentiality

The Code Subjects must: (i) keep all confidential information they access as a result of carrying out their professional work strictly confidential; (ii) store it in compliance with the applicable legislation, existing confidentiality agreements and lyntia’s internal rules on privacy, and (iii) abstain from using it improperly for personal gain or that of third parties. In the event of any doubt about the nature of the information, the Code Subjects should consider it to be confidential, unless otherwise indicated.


The confidentiality undertaking endures once the association with lyntia ends.


3.10 Intellectual property

lyntia encourages the information and know-how created in the company to flow smoothly amongst its employees and organisational units, to facilitate task management and boost personal development.


The Code Subjects have the duty to retain lyntia’s know-how, facilitate its dissemination to other lyntia employees and make it available to the know-how management systems which are activated within the company.


All information and know-how, understood to be the conceptual result of the integration of diverse information, inventions, discoveries, developments, concepts, ideas or work relating to the business generated within the company, are lyntia’s property, under the terms referred to in current legislation.


The logo, trademark, image, corporate identity and the name lyntia should only be used for the proper performance of professional work.


Furthermore, the intellectual and industrial property of third-party products and services should be respected.


3.11 Data protection

lyntia will process personal data in such a way as ensures privacy and, in all cases, in compliance with current, applicable legislation.


The Code Subjects must comply with the Law and lyntia’s internal rules on privacy including, but not limited to, the Employee Handbook.


3.12  Defence of competition

The Code Subjects must respect the principles and rules on fair competition and must not breach competition laws.


3.13 Relations with customers

lyntia’s purpose is to provide the highest quality services to its customers.


The Code Subjects must interact with customers in an upstanding manner, with the aim of achieving the highest possible levels of quality, and in such a way that they (i) ensure fulfilment of all the commitments made to customers;


(ii) resolve, promptly and diligently, their requests, complaints and claims, and (iii) do not carry out, or collaborate in, unlawful acts to defraud the legitimate rights of creditors or third parties.


3.14 Relations with collaborating companies and suppliers

lyntia considers that its suppliers and collaborating companies are an indispensable part of achieving its targets for growth and improving service quality. It seeks to establish relations based on trust and mutual benefit with them.


lyntia commits to promoting practices in line with the guidelines included in this Code of Ethics amongst its suppliers and external collaborators, without prejudice to the performance of contractual terms, and under the premise of respect for the authority to manage.


The Code Subjects and, in particular, those taking part in decisions about the procurement of supplies or services, or setting their financial terms, will avoid any kind of interference which may affect their impartiality or objectivity in that respect.


lyntia’s suppliers are selected in accordance with lyntia’s purchasing guidelines, which are available to all Code Subjects.


3.15 Relations with public authorities, regulatory bodies and administrations

Relations with public authorities, regulatory bodies and administrations will be framed within the principals of lawfulness, loyalty, trust, professionalism, collaboration, reciprocity and good faith, without prejudice to legitimate disputes which, respecting the foregoing principles, may arise with the authorities in relation to the applicable regulations.


3.16 Respect for the environment

Conservation and respect for the environment is one of lyntia’s basic operational principles.


The Code Subjects must (i) act in accordance with applicable environmental legislation; (ii) strive, with preventive measures, to minimise the environmental impact arising from their work and the use of the facilities, equipment and operational resources made available to them, seeking to use them efficiently.


3.17 Compliance with accounting and financial regulations

lyntia’s economic and financial information will present a true image of its economic, financial and equity situation, in accordance with generally accepted accounting principles and international rules on financial information which may be applicable.


The Code Subjects will not hide or distort information on lyntia’s accounting records and reports, which will be complete, precise and accurate. For this purpose, all transactions, income and expenditure must be accounted for, recorded and suitably documented, without omitting, hiding or altering any data or information, in such a way that the accounting and operational records present a true image of the current situation and can be verified, as appropriate, by the auditors.



lyntia’s exercise of due diligence requires, according to current legislation, implementation not just of continuous control mechanisms, but also the appointment of internal control bodies to monitor the controls put in place and the eventual criminal risks.


The Board of Directors has entrusted the Compliance Committee with this oversight and monitoring task. The Committee has been given the sufficient independence both in terms of oversight power and initiative.


lyntia reserves the right to carry out controls within the current rule of law, for the purpose of checking use of the Code of Ethics and preventing activities which may affect compliance with the provisions contained in it and in the applicable legislation.



lyntia has named an Internal Reporting System Manager to appropriately manage the Internal Channel (Speak Up) and the system itself, as well as to ensure compliance with the guarantees established in Act 2/2023, of 20 February, regulating the protection of people who report regulatory infractions and the fight against corruption.


Non-compliance or indications of non-compliance of the lyntia Code of Ethics and applicable regulations may be reported in good faith through the following channels:

    • Email: [email protected]
    • Post: Avenida de Bruselas, 24 planta 1, 28108 – Alcobendas (Madrid) ATT. Compliance Committee


The Internal Reporting System Manager will ensure that all communications they receive are handled in a timely manner, and will notify the whistleblower of the resolution.


Questions, as well as any queries or recommendations regarding lyntia’s internal regulation should be sent to  [email protected].



All Code Subjects and Interested Third Parties must comply with the provisions of the Code of Ethics that are applicable to them.


Breach of the Code by lyntia’s employees will be penalised in accordance with the disciplinary procedure in the Collective Agreement and, where not provided for therein, the disciplinary procedure provided for in the consolidated text of the Workers Statute Act (Royal Legislative Decree 2/2015, of 23 October) or in applicable business or employment law shall apply.


Penalties imposed by lyntia will be supplementary to any legal proceedings which may be taken against the Code Subject and any penalty or consequence that may arise from such proceedings.


Breach of the Code by Interested Third Parties may result in, among other consequences, the termination of the existing services relationship.


The consequences of breaching this Code of Ethics will not only affect the party in breach, but may also affect Code Subjects who, by action or omission, have allowed the breach.


lyntia will communicate and disseminate the content of the Code of Ethics amongst all its employees, and all employees joining lyntia must expressly accept the rules of conduct provided for in this Code.


Nobody, regardless of their level or position, is permitted to request a Code Subject to contravene the provisions of this Code of Ethics. No employee may justify misconduct by relying on an order from a superior or on ignorance of this Code.


Schedule 1. List of companies

    • Global Fontibre, S.L. (matriz)
    • Gunalta ITG, S.L.
    • lyntia Networks, S.A.U.
    • Tower Net Infraestructuras, S.L.
    • Servicios Digitales Codinet, S.L.


Schedule 2. Gifts, invitations, meals and travel



In its commercial practices and relations with suppliers, clients and collaborators, lyntia will only allow gifts and invitations that comply (both in their giving and receiving) with the following principles:

    • The purpose of the gift or invitation is not to obtain an unfair advantage or influence an official action (especially in the context of tenders).
    • The gift or invitation is authorised by a superior with the sufficient authority.
    • The value is reasonable and suited to the recipient’s situation, the circumstances and the occasion.
    • The frequency of the gifts is appropriate (i.e. annual, biyearly).
    • Gifts or invitations with a value over 200 euros (calculated annually) are not allowed and must be rejected.


Therefore, lyntia prohibits under all circumstances gifts, tokens of appreciation or invitations that involve:

    • Offering or accepting gifts, hospitality or expenses that may be illegal.
    • Offering or accepting cash or equivalents (gift cards, charges to debit/credit cards, loans, shares, stock options, cheques, traveller’s cheques, money orders, investment securities or negotiable instruments).
    • Offering or accepting gifts, hospitality or tokens of appreciation during tender processes for contracts.
    • Generating an expense in a client’s name when it is not correctly recorded in the company’s books.
    • Offering, accepting or requesting something (regardless of its value) as part of an agreement to do something in exchange for gifts, hospitality or tokens of appreciation.
    • Using your own money or resources to pay for gifts, hospitality or tokens of appreciation for a client, vendor or supplier.
    • Participating in an activity that makes the person giving or receiving gifts,hospitality or tokens of appreciation violate their employer’s rules.


In any event, lyntia will allow gifts that are:

    • Propaganda objects of little value.
    • Normal invitations that do not exceed reasonable limits in terms of usual social customs or courtesy.
    • Occasional tokens of appreciation for specific, exceptional causes (such as Christmas or wedding gifts), provided they are not in cash and are within the limits set forth in the above paragraph.


Gifts include: travel, courses, conferences, technical presentations, technological objects or any other service or thing with commercial value.


If there are questions about the origin of a gift or invitation, the consultation will be sent through [email protected]



Although it is still common practice to talk business during meals arranged by clients, suppliers or collaborators, these meals will only be acceptable (both the invitation and accepting the invitation) when the following conditions are met:

    • The meal is organised in a purely professional context, i.e. it is designed to allow the attendees to discuss business matters.
    • The amount paid for the meal is reasonable.
    • The invitation should never include the companions, such as spouses, partners, family members, etc. of the person being invited.
    • Employees should consult with or request authorisation from the Compliance Committee if they have any questions as to the pertinence or suitability of the invitation. In particular, employees should always consult the Committee prior to the invitation if there are questions regarding the following aspects:
      • The recipient of the invitation (due to their authority or capacity to make decisions that affect lyntia’s business).
      • The timing of the invitation (for example, due to proximity to signing contracts or agreements).
      • The nature of the invitation.
      • The relationship between the person receiving the invitation and the lyntia employee.
      • If the invitation is allowed under local legislation and if it complies with lyntia’s policies and procedures.
    • Any invitation must be correctly recorded, and will require the prior authorisation of the director of each department.



lyntia employees are only allowed to take part in trips organised by clients, suppliers or collaborators (as well as those organised by lyntia) the purpose of which is to:

    • Attend the necessary training courses to obtain technical knowledge about new products or services, or new features thereof
    • Learn firsthand about products or technology that may be acquired by lyntia and which cannot be presented or offered in lyntia offices
    • The duration of the invitation will extend only to the duration of the training event
    • lyntia cannot reimburse lodging and travel costs under any circumstances
    • Said payments must be made directly from organisation to organisation (never directly to the professional invited)
    • lyntia cannot pay for expenses other than travel and lodging
    • lyntia cannot pay for lodging or travel expenses for the spouse, partner, family member, etc. of the professional invited


Any trip organised by a client, supplier or collaborator that is not carried out in accordance with the provisions of the above paragraph will require the prior approval of the Compliance Committee.


If there are questions about the origin of a gift or invitation, the consultation will be sent through [email protected]


The request for authorisation to make or accept any gift, invitation or token of appreciation must be accompanied by the following information:

    • Identity of the third party who is offering the gift, invitation or token of appreciation.
    • Description of the relationship between the third party and lyntia (indicate if they are a supplier, partner, client, etc.).
    • Description of the gift, invitation or token of appreciation.
    • Economic value (if unknown, you must give an approximate value and indicate that it is an estimate).
    • Preliminary assessment of whether the gift/invitation/token of appreciation is acceptable or not.


Schedule 3. Donations

lyntia forbids donations to political parties and organisations associated with political parties and will not sponsor any event exclusively aimed at political propaganda.


Political contributions are defined as any payment in cash or in kind or provision of services free of charge or below market rate, as well as any other type of advantage.


However, lyntia recognises the right of each professional to make contributions to political parties individually. In these cases, the professional must take the necessary precautions to ensure that there is no doubt that this contribution has been made personally.


Donations to other entities, including any charitable organisations, should be exceptional, and shall always require the prior approval of the Compliance Committee, after notifying the Financial Director.


Facilitating payments are small quantities given in exchange for ensuring or speeding up a procedure or necessary action to which the maker of the facilitating payment has a right by law or otherwise. In other words, the purpose of the facilitating payment is to influence the speed of the procedure, but not the result itself.


However, facilitating payments are considered a form of bribery and, as such, are prohibited.

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