Code of Ethics

Modified on Mon, 6 Oct at 6:10 PM

CODE OF ETHICS

Version	Date	Approving Body	Author	Summary of Changes
1.0	08/12/2022	Sole Administrator of Bitcoinforme S.L	Compliance Department	Update

TABLE OF CONTENTS

1. INTRODUCTION
2. PURPOSE AND SCOPE OF APPLICATION
3. PRINCIPLES OF CONDUCT
4. RULES OF CONDUCT
5. BREACH OF THE CODE OF ETHICS AND REPORTING OF ILLEGAL CONDUCT
6. APPROVAL AND VALIDITY

1. INTRODUCTION

Since the incorporation of BITCOINFORME, S.L. and the company DEVTEAM S.L., (hereinafter Bit2Me), integrity, honesty, fair dealing, and full compliance with all legislation, regulations, and rules affecting Bit2Me have guided her practices and actions. Since then, the administrators, management, and other employees of Bit2Me have upheld and fulfilled this commitment in their daily responsibilities, helping her reputation to remain one of her most important assets.

The CODE OF ETHICS of Bit2Me is, therefore, the living document that reflects the ethical principles of the beliefs, values, and behaviors of all the members who are part of Bit2Me, serving as a guide when making business decisions and guiding our conduct at work.

It is a document that must be known, respected, and complied with by all members of BIT2ME, being available to each of them, assuming the commitment to its compliance.

The application of the Code of Ethics cannot suppose a violation of a current legal provision; however, it is binding and has priority over any internal rule that exists and that could contradict what is stated in this CODE OF ETHICS.

2. PURPOSE AND SCOPE OF APPLICATION

The purpose of Bit2Me's CODE OF ETHICS is to establish the guidelines that must govern the ethical behavior of all its administrators, directors, employees, collaborators, and those other persons whose activity is expressly subject to it (members of Bit2Me, its scope of application), with respect to the relationships and interactions that Bit2Me maintains with all its stakeholders (ownership, directors, employees, collaborators, clients, suppliers, public administrations, public and private institutions, and society in general).

Bit2Me's CODE OF ETHICS reflects the principle of due diligence applied by the company for the prevention, detection, and elimination of irregularities related to breaches of legislation, regulations, and norms in all areas affecting Bit2Me, including its internal rules.

Therefore, this CODE OF ETHICS is part of the Organization and Management Model for the Prevention of Legal and Criminal Risks that BIT2ME possesses, under the supervision of the Compliance Department and more specifically of the Criminal Regulatory Compliance Body (Criminal Compliance Committee).

The nature of this CODE OF ETHICS is not intended to cover all possible situations that may occur at Bit2Me, but to provide a frame of reference against which to measure any activity. In this sense, the different stakeholders of the Company should seek advice from the aforementioned Body if they have any doubts regarding its content.

3. PRINCIPLES OF CONDUCT

The company expects all persons affected by this CODE OF ETHICS to comply, at all times, with the following values and principles of ethical conduct:

INTEGRITY: Ethical, loyal, honest, and good faith conduct in the company.
HONESTY: Rejection of corruption in all its forms, public and private, active and passive.
RESPECT: Tolerance and defense of the diversity of people in any aspect.
TRANSPARENCY: Providing access to stakeholders, in a timely, reasonable, proportionate, and adequate manner, to relevant, truthful, clear, and complete information about the company's activities, policies, and management, to foster relationships based on trust and good faith.
REGULATORY COMPLIANCE: Comprehensive observance of any regulatory provision, including internal rules, and requirement for suppliers and collaborators.
HEALTH AND SAFETY AT WORK: Commitment to protecting the health and safety at work of employees, making the prevention of occupational risks the supporting tool for it.
SUSTAINABILITY: Promoting the continuity of the company over time, reinforcing our commitment to environmental protection and social welfare, maintaining relationships with stakeholders based on ethics and transparency.
CONTINUOUS IMPROVEMENT: Promoting the development and retention of talent and knowledge and establishing efficient measures for the sustained progress of the company.
SOLIDARITY: Working as a team, always seeking the global interest, through collaboration between areas and with clients/suppliers.
EXCELLENCE IN INNOVATION: Having the opportunity to make modifications in terms of innovation in the company.
COMMITMENT: Getting the members of the team to acquire commitment, need, and desire to grow with the company. Making everyone a participant in the company's achievements and processes.
CONFIDENTIALITY: Bit2Me will comply with the Organic Law on Data Protection.
QUALITY: Bit2Me works to make its services optimal, efficient, and of high quality for all its clients and suppliers.
FAIR COMPETITION: Immoral attitudes towards the competition will not be tolerated.

4. RULES OF CONDUCT

4.1. Compliance with legislation, regulations, and norms

All members of Bit2Me undertake to comply with the applicable laws, regulations, and normative provisions, both international, national, generic, and specific to the sector, as well as internal rules.

The foregoing commitment is integrated into the Value Chain of Bit2me.

4.2. Work environment, discrimination, and harassment

Since we spend a large part of our lives at work, it is essential to enjoy a work environment based on mutual trust, and in which mistakes are considered part of learning.

We encourage teamwork, and successes and mistakes are shared by all, as there is no fear of making mistakes at Bit2Me, and we recognize and value the ideas and contributions of others.

Our attitude towards work must be one of active cooperation and respect for others, seeking excellence in its performance.

Likewise, Bit2Me promotes a corporate culture based on loyalty, trust, and solidarity among all.

Bit2Me respects the personal dignity, privacy, and personal rights of each employee and is committed to maintaining a workplace free from discrimination or harassment. Therefore, employees must not discriminate based on origin, nationality, religion, race, gender, age, political ideas, or sexual orientation, nor engage in any type of verbal or physical harassment.

4.3. Confidentiality and professional secrecy

We value and protect our confidential information and respect the confidential information of third parties.

Confidential information is information that is not in the public domain at any given time. This includes trade secrets, business plans, unique elements of products and services, knowledge of customer behavior, business ideas, designs, unpublished economic and financial data, and any information about Bit2Me's strategy and operation whose disclosure to third parties could be a source of harm to Bit2Me and any of its members.

We must ensure, at all times, the proper use of the company's internal information and its protection.

4.4. Conflicts of interest

We should all avoid situations in which the personal interests of Bit2Me members conflict with the company's interests. The best way to deal with a conflict or a potential conflict is to communicate what is happening to the Criminal Compliance Committee as soon as possible, which allows the conflict to be analyzed and resolved. Therefore, we should not participate in negotiations with clients, suppliers, and other entities with whom we have a family relationship (spouse, children, siblings, parents, uncles, etc.), where a situation of influence may be exerted from which personal benefits other than those of Bit2Me may be derived.

4.5. Use and protection of company assets

The company provides its members, affected by this CODE OF ETHICS, with sufficient resources to carry out their professional activity, committing to their correct and appropriate use, and observing due diligence in their custody.

Therefore, the aforementioned resources may not be used for personal, non-professional purposes, or for the performance of activities that are not related to the interests of Bit2Me.

In this sense, the persons affected by this CODE OF ETHICS:

Must use Bit2Me resources such as the telephone, internet access, email, or any other application for the performance of the functions proper to their job. Bit2Me reserves the right to audit their proper use.
All documentation generated in projects is the property of Bit2Me and may not be extracted or disclosed, in whole or in part, outside the work environment.
Bit2Me will provide each employee with a computer system with protection against malicious code. At no time is it permitted to modify the configuration or disable it. Only authorized Bit2Me personnel will be responsible for executing any code for use on users' workstations.
The information that Bit2Me makes available to employees will be treated in accordance with the procedures established by the organization, with the storage of any type of Bit2Me information on local equipment, external storage devices (USB drives, USB keys, and any other type of device) and its sending by electronic networks or other means being expressly prohibited. The information must be stored in the folder structure created for such purposes on Bit2Me's servers.
The equipment provided to employees is the property of Bit2Me, so the installation of any unauthorized software is expressly prohibited. The software that is desired or needed to be installed must be authorized by the Bit2Me Cybersecurity Department. Only authorized personnel can perform software installations, uninstallations, and configurations.
They may not use the brand, logo, or any other industrial or intellectual property right of Bit2Me for personal benefit.
They may not disclose, save, disseminate, download, or distribute material that is threatening, false, defamatory, obscene, or that may in any way constitute a crime or negatively affect the reputation and good image of Bit2Me, without prejudice to freedom of association.

4.6. Relatives and work-life balance

Bit2Me wants to ensure that the workplace is fair for everyone and not affected by any type of favoritism. In this way, decisions made regarding personnel hiring will be fair and objective. Direct relatives and partners of employees may be hired as employees, consultants, collaborators, or contractors only if their selection is based on their qualifications, performance, skills, and experience, and provided that this does not give rise to a conflict of interest.

These principles of fair hiring, which may not contradict the provisions of the Workers' Statute or the applicable Collective Bargaining Agreement, will apply to all aspects of the employment relationship, including remuneration, promotions, and transfers, as well as in the event that the relationship develops after the respective employee has joined Bit2Me.

Furthermore, Bit2Me will actively develop policies and programs to facilitate the work-life balance of its employees.

4.7. Bribery and corruption

Bit2Me repudiates all forms of bribery and corruption. Corruption is illegal and therefore unacceptable, so Bit2Me's policy is one of zero tolerance in all matters relating to it.

Employees, directly or through intermediaries, must not offer or promise an improper personal or financial favor or other type of favor to obtain or secure a business or other advantage from a third party, whether public or private.

Nor should they accept such an advantage in exchange for preferential treatment from a third party, and they must refrain from engaging in any activity or conduct that could give rise to the appearance or suspicion of such conduct or an attempt thereof.

Employees should be aware that offering or giving direct or indirect benefits (indirect benefits can include anything of value to the recipient) to influence the recipient's decision, whoever they may be, can not only lead to disciplinary sanctions but also result in criminal charges.

4.8. Business favors, gifts, and the like

Employees may not be influenced by receiving favors nor will they attempt to improperly influence third parties by giving favors.

A business favor is a gift (whether in cash or in kind) that we have provided to someone or that has been given to us by someone in our professional environment and context and that has the basic objective of modifying or influencing decisions or behaviors.

Exchanging gifts and invitations can help Bit2Me's business relationships and even, if between colleagues, improve labor relations, but they can also cause a conflict of interest between personal interests and professional obligations. Therefore, the exchange of gifts or favors must not have the purpose of improperly influencing the decisions of our clients or suppliers, just as we require that employees' decisions are not affected by having received business favors.

When receiving or offering gifts or invitations, the most important thing is to communicate it openly to Management, act sensibly, and think about how other people will perceive it.

In this regard, employees may only offer or accept reasonable and symbolic favors and gifts that are appropriate under the circumstances and will not accept them if such behavior could create the impression that it constitutes an improper influence on the corresponding business relationship.

Therefore, we must:

• Ensure that all gifts and invitations we offer or receive are symbolic, appropriate, and do not damage the company's image.

• Inform our clients and suppliers of our gift policy, and in turn, be aware of their policy regarding these matters.

• Always inform our superior of any favor we have received.

On this point, the company regulates a specific anti-corruption procedure.

4.9. Occupational Risk Prevention

BIT2ME is committed to complying with its obligations regarding occupational risk prevention, with the aim of protecting and preserving the occupational health and safety of its workers.

This commitment translates into having zero tolerance for negligent behavior in matters of occupational health and safety, and in the implementation of an adequate model for organizing preventive activity.

We must all know and comply with the rules for protecting health and safety at work and for preventing occupational risks, and ensure our own safety, as well as that of other colleagues, clients, and suppliers who visit our facilities.

4.10. Prevention of Money Laundering and Terrorism Financing

Bit2Me is committed to avoiding any collaboration with individuals or entities whose purpose may be money laundering or terrorism financing.

The persons affected by this CODE OF ETHICS will refrain from proposing, promoting, or facilitating Bit2Me's intervention in mercantile, commercial, or any other type of operations when they know or have well-founded suspicions that their purpose is to introduce into the economic system funds from criminal activities by concealing their origin.

Bit2Me will refrain from possessing, using, or transmitting goods that originate from criminal activities and will not participate in activities whose purpose is to collect, distribute, or supply funds to finance terrorist acts and/or organizations.

4.11. Environment

The company develops its activity with a deep respect for the environment, complying with the requirements of environmental legislation and minimizing the possible impact on the environment.

Bit2Me is committed to sustainable development as the only way to safeguard the planet for future generations.

4.12. Human Rights

Bit2Me assumes the commitment to respect and promote Human Rights, as set forth in the Universal Declaration of Human Rights of December 10, 1948, and in the UN Guiding Principles on Business and Human Rights of June 16, 2011.

4.13. Management with clients and third parties

We must offer the client truthful, transparent, and clear information. When Bit2Me communicates with any client, supplier, or intermediary, this communication will be fluid and transparent. It will be very important to know the clients' opinions to improve the services we provide and to solve problems as quickly and efficiently as possible. Every person who will have direct contact with the client will have received the relevant training on customer service. For Bit2Me, this commitment is essential.

Communication with clients will always be based on the same values and will be clear and concise, always complying with the contractual commitments that have been agreed upon between the third party and the company.

Ensuring quality service is essential for BITCOINFORME SL and DEVTEAM SL.

4.14. Equality

Article 46 of Organic Law 3/2007, of March 22, for the effective equality between women and men, establishes that companies are obliged to respect equal treatment and opportunities in the workplace and, for this purpose, must adopt measures aimed at avoiding any type of labor discrimination between women and men, measures that must be negotiated, and where appropriate, agreed upon with the legal representatives of the workers in the manner determined by labor legislation.

To achieve the set objectives, equality plans may include, among others, matters of access to employment, professional classification, promotion and training, remuneration, organization of working time to promote, in terms of equality between women and men, the reconciliation of work, personal, and family life, and prevention of sexual harassment and harassment based on sex.

5. BREACH OF THE CODE OF ETHICS AND REPORTING OF ILLEGAL CONDUCT

At Bit2Me it is very important to maintain the values, ethical standards, and transparency that have been established throughout this Code of Ethics, which is an essential value in the life and work of the organization.

Absolutely all the people who make up this company and all the relationships and actions carried out by it will be within the parameters established in this protocol.

To try to control that these applied rules are complied with, different protocols have been created in order to mark the correct path when working and relating at Bit2Me, and that is why the WHISTLEBLOWING CHANNEL has also been made available to the members of the company and to third parties. This channel constitutes a very important and fundamental part of regulatory compliance since it makes it possible to guarantee the application of the rules and to resolve more quickly any situation that violates internal rules or legal provisions.

It is the responsibility of each employee to ensure full compliance with the content of this CODE OF ETHICS.

Any practice or action that they believe to be inappropriate or even illegal, by virtue of this CODE OF ETHICS, must be communicated through the appropriate channels, their immediate superior -if this is possible, provided that the superior is not the future subject of the investigation- or directly to the Criminal Regulatory Compliance Body.

Complaints or communications will be made confidentially, using the COMPANY'S WHISTLEBLOWING CHANNEL, an element that is part of its COMPLIANCE MODEL or PROGRAM, through an email published on the web.

6. APPROVAL AND VALIDITY

This CODE OF ETHICS has been approved by the Administrative Body, on August 12, 2022, coming into force on the indicated date, and will be reviewed and updated periodically, with the aim of meeting the needs within the continuous improvement process of BIT2ME.

To all workers and collaborators of BITCOINFORME, S.L., and DEVTEAM S.L.

CODE OF ETHICS OF BITCOINFORME, S.L AND DEVTEAM S.L.

Letter of communication of existence and availability

To all workers and collaborators of BITCOINFORME, S.L. AND DEVTEAM S.L.

Through this letter, I inform you of the existence and entry into force of our company's new CODE OF ETHICS, dated August 12, 2022, a document that includes the principles and values of our entity, which must be respected by all its members.

This CODE OF ETHICS is at your disposal and is part of our Organization and Management Model for the Prevention of Legal and Criminal Risks, being mandatory for all members of the company.

Thanking you for your attention, receive a very cordial greeting,

Kind regards,

Leif Ferreira Ponce