Code of Ethics and Conduct

1. The Code

The Code of Conduct (Code) is a declaration of commitment on the part of everyone to do the right thing at all times and to establish themselves as a reliable partner. It is a tool to support your decisions and actions in an ethical and judicious manner in the most diverse situations that may arise in your day-to-day work The Code reflects what is expected of people and businesses. It sets out guidelines so that everyone can act with integrity and in accordance with the best principles, applicable laws and regulations. Since it is not possible to foresee every situation, and because we always represent log.oscon, the Code is also a declaration of trust in everyone's good judgement.

2. Objectives

This Code of Conduct identifies log.oscon's values and enshrines the most important rules of professional conduct.

3. Scope

This Code applies to all employees of log.oscon and its associated companies, including members of the management and supervisory bodies, and to all service providers to whom it is communicated. The Code is an integral part of the system of internal rules, and does not exempt its observance from knowledge of and compliance with the other rules in force, as well as the applicable legal and regulatory provisions.

4. Disclosure

Internally, this Code will be disseminated to all employees by email, as well as through training programmes deemed relevant. Externally, it will be publicised on the website. The Management will adopt the measures it deems necessary, in the light of the issues reported to it, in order to put an end to the breach and, whenever justified, to promote the reparation of damages and minimise the risk of similar events occurring again.

Management draws up and submits to the supervisory body, on an annual basis or when justified by its relevance, a report describing situations of non-compliance with this Code.

5. Values

1. ethics, transparency, rigour and competence

log.oscon and its employees work to the highest standards of ethics, transparency, rigour and professional competence. They also observe the duties of respect, courtesy, tolerance, urbanity, zeal, diligence, discipline and loyalty in their daily dealings with peers and third parties.

2. Compliance

log.oscon and its employees carry out their activities in strict compliance with the applicable legal and regulatory provisions, as well as professional and ethical standards and practices, internal and statutory rules, rules of conduct and customer relations, the guidelines of the governing bodies and the recommendations of the National Regulatory Authorities.

3. Security, Prudence and Independence

log.oscon and its employees analyse and make decisions on matters involving risk management with the aim of satisfying the needs of clients, with total independence, coupled with high levels of prudence and safety and full respect for client guidelines, internal and external standards and legal and regulatory provisions.

4. Non-Discrimination And Equal Treatment

log.oscon and its employees do not discriminate in any way in their dealings, particularly on the grounds of age, gender, race, nationality, territory of origin, religion, political or ideological convictions, respecting equal treatment at all times with all clients or other entities with whom they have dealings.

5. Acceptance of Benefits or Rewards

Considering the independence that all employees are obliged to maintain, they must not request or accept any benefits or rewards that are in any way related, directly or indirectly, to any specific business.

6. Reconciling Professional, Private and Family Life

In order to promote the quality of life of employees and their families, log.oscon provides a working environment that takes into account the personal development of employees and the reconciliation of the demands of work with the needs of personal and family life.

7. Behaviour towards colleagues

Relationships between employees must be collaborative, with each one proactively reflecting their respect and tolerance for others and the utmost urbanity in their treatment. Each employee must treat others in the way they would like to be treated, namely with loyalty, honesty, professionalism and impartiality in order to contribute to the appropriate balance in the professional relationship and conflicting interests.

8. Social Responsibility

log.oscon and its employees favour economic progress at the service of customers and the community, pursuing sustainable growth from an economic, social and environmental point of view, supporting families, economic agents and entrepreneurial and innovative projects.

6. Duties to Customers

1. Equal treatment and correct relationships

log.oscon and its employees, in their dealings with clients, must act with politeness, diligence, loyalty, discretion and conscientious respect, always bearing in mind the interests entrusted to them, and not discriminate in any way in the provision of services.

2. Information and Transparency

When dealing with clients, log.oscon and its employees must make clear the characteristics of the products and services offered, as well as the associated risks and respective conditions. The above-mentioned elements should enable customers to make judicious, informed and well-founded decisions.

3. Conflicts of interest

Any employee who identifies a conflict of interest should report the situation to their line manager or to management. The above-mentioned information is provided on a confidential basis and may only be used within the scope of management to resolve a situation of conflict of interest (potential or actual).

4. Prevalence of the Client's Interests

In the event of a conflict of interest, log.oscon ensures that clients are treated transparently and fairly and prioritises clients' interests.

5. Duty of Confidentiality

In its activity, log.oscon strictly observes the provisions of the General Data Protection Regulation. Employees may not reveal or use information about facts or elements concerning the life of the company, or its relations with its clients, which they become aware of in the course of carrying out their duties or providing their services. This duty does not cease with the end of their duties or services.

The facts or elements of the customer's relationship with log.oscon may only be disclosed to third parties with the customer's authorisation or when required to do so by law, court decision or order of a supervisory authority.

6. Accepting suggestions or complaints

Suggestions or complaints are seen as opportunities for continuous improvement of the activity and performance of all employees.

7. Duties to the Market

1. Commercial Probity

In carrying out its activity, log.oscon and its Employees must demonstrate a behaviour of high commercial probity, refraining from participating in business or carrying out other acts that could distort the regularity of operation, transparency and credibility of the market.

2. Market defence

In carrying out its business, log.oscon and its employees fully comply with legal and regulatory standards, aligning their performance with the best market practices. The dissemination of false, incomplete, exaggerated or biased information or the execution of any fraudulent or fictitious practices, namely those aimed at artificially altering the regular functioning of the market, is prohibited.

3. Co-operation with supervisory bodies

In strict fulfilment of the obligations arising from the law, log.oscon and its Employees must collaborate diligently and professionally with supervisory bodies and other public bodies with competence in this activity.

8. Duties Towards the Environment

1. Diligence and Social Responsibility

The members of the Management must carry out their duties with the diligence of a judicious and orderly manager and take into account the interests of clients, shareholders and other interested parties.

The members of the Board of Directors must also promote the provision of adequate means for the personal and professional development of employees and, as far as possible, develop support for initiatives in society in a wide range of areas of interest to the community, from culture to social solidarity and entrepreneurship.

2. Relationship with the environment

In its activity, log.oscon and its employees must ensure the conservation, maintenance and efficient use of the resources made available to them, in line with the best environmental practices.

3. Asset Protection

All employees must refrain from using log.oscon assets for their own personal benefit or that of a third party other than log.oscon. They must also act in such a way as to preserve the value of these assets.

log.oscon's resources may only be used for professional purposes, unless personal use is in accordance with the rules in force, but always in a sensible and judicious manner, not interfering with the normal running of the business or its diligent performance, either by itself or by third parties.

9. Monitoring Compliance with the Code

Management is responsible for monitoring the application and observance of this Code. All occurrences, in any area, relating to non-compliance with this Code, regardless of other procedures that may be necessary, namely for disciplinary or criminal purposes, must be immediately reported to Management, who will ensure their confidentiality.

10. Organisation

log.oscon has adopted a well-defined, transparent and perceptible organisational structure, which supports the development of the business and the implementation of an adequate and effective internal control system, in order to ensure that the management and control of the business is effective and carried out in a prudent manner. Employees must contribute to internal control, considering their role in the system implemented.

11. Entry into Force

This Code comes into force on 1 January 2020