Ethical code

INTRODUCTION

Article 1. Origin and nature.

The Code of Ethics of HEMP RIDER, S.L. It has its origin in the principles and values ​​that make up its business spirit. It emanates directly from the administration, having a binding nature for all the subjects included in its scope of application, owing their conduct and procedures not only to the legal provisions, procedural rules, rules issued by the different regulatory bodies and conventional rules, but also to adjust to the orders and guidelines contained in this Code. Failure to comply with, ignore, fail to observe, disobey, omit or deviate from the Code of Ethics will entail real, effective, direct and immediate consequences for all subjects included in its scope of application, and may generate disciplinary responsibilities of a labor nature that may even entail the maximum labor sanction, that is, disciplinary dismissal, and all this without prejudice to the criminal, civil or administrative responsibilities that may be generated additionally.

Article 2. Scope of application

This Code of Ethics is applicable to all members of the administration, management, employees, and related third parties, regardless of the legal qualification that their relationship with the company deserves.

Article 3. Knowledge, compliance, duty of cooperation and dissemination of the Code of Ethics.

The subjects included within the scope of application must know and adjust their conduct to the Code of Ethics, as well as cooperate actively to facilitate compliance with it by all subjects included within the scope of application of the standard, thus guaranteeing the maximum legal security. The duty of cooperation of the regulated entities includes the obligation to notify the Compliance Officer of any situation of non-compliance of which there is knowledge or well-founded suspicion. Failure to comply with the obligation to report the existence of situations of non-compliance entails incurring in a situation of indiscipline and disobedience at work. The work of dissemination, training, knowledge and acceptance of the Code of Ethics will be carried out by the Compliance Officer, will be permanent, periodic and constant, and must be repeated and permanently updated in relation to all the obligated subjects. Attendance and participation in the training, dissemination, recycling and updating sessions of the Code of Ethics are mandatory for all subjects included in its scope of application, considering unjustified absence from said sessions as a situation of indiscipline and disobedience at work.

Article 4. Updating and revision of the Code of Ethics.

The Code of Ethics is an instrument whose usefulness is to show the behavior to be followed by the obligated subjects and included in its application, which is why this regulatory body must be constantly updated and revised to adapt it to the new realities that may arise, It must be avoided that it is outdated and does not adapt to the evolution of the times or to the constant changes in the state of the art.

ESSENTIAL PRINCIPLES AND GENERAL COMMITMENTS FOR ACTION

Article 5. Respect for values ​​and norms. Obligations of Prudence, Responsibility and Integrity. Those involved are obliged to behave guaranteeing respect for the values ​​and ethical principles of HEMP RIDER, S.L., committing to guide their actions and adjust their attitudes safeguarding respect for said principles and values. They must always respect the laws and regulations, as well as adjust their behavior and attitude to the regulations contained in this Code], as well as comply with its procedures and report attitudes contrary to any regulatory compliance. They must always govern their decision-making and their actions under the principles of responsibility, prudence and integrity, forcing themselves to ensure that their decisions and actions always pursue the interests of the company. If any regulated entity has any doubt as to whether an action or omission may violate the principles and values ​​contained in the Code of Ethics, laws, regulations, this Code of Ethics, policies or action procedures by which HEMP is governed RIDER, S.L., will avoid carrying out the action and will consult the hierarchical superior or the Compliance Officer. The obligation of prudence is imposed to prevent and avoid situations of non-compliance and conflict.

Article 6. Equality and non-discrimination.

The principle of equality must be present in all personal, professional and labor relationships. Any form of discrimination is expressly prohibited and will not be tolerated, whatever the cause (birth, race, sex, religion, sexual orientation, ideas, opinion) or any other personal and social condition or circumstance. In the selection, hiring, training and promotion processes, objective criteria linked to the principles of merit, capacity, profile analysis and evaluation of candidates must be applied, prohibiting arbitrary and discriminatory actions. The use of derogatory language or expressions or those that may denote contempt is expressly prohibited and will not be tolerated, as well as manifestations through any medium that may denote the existence of some form of discrimination. The obligations and orders contained in this article bind the members of the organization when they relate to each other or when they do so with third parties, whether or not these third parties have a relationship with HEMP RIDER, S.L.

Article 7. Respect for people: freedom, integrity, dignity and privacy.

Personal and professional relationships within HEMP RIDER S.L. They must guarantee the freedom of individuals in all its manifestations, as well as the maintenance of due consideration for dignity, respect for the right to privacy and physical and personal integrity. Actions of abuse, harassment (both moral and sexual), undignified treatment, denigration, intimidation, coercion, violation or interference in privacy, lack of respect or due consideration, aggression, threats, and any behavior contrary to respect and freedom of people are expressly prohibited and will not be tolerated by the organization, being considered unacceptable and contrary to peaceful coexistence. All those who make up the organization must adopt behaviors that make it impossible for situations appear contrary to respect for people in any of its aspects (freedom, integrity, dignity and privacy) and if they detect conduct contrary to these principles they have the duty to report it. Ensuring a good working environment is the responsibility of all members of the organization, prohibiting all attitudes, actions or omissions that lead to the breakdown of peaceful coexistence.

Article 8. Occupational Risk Prevention. Security and health.

All subjects included in the scope of application of this Code of Ethics will promote and adopt the necessary measures to achieve effective protection in terms of occupational health and safety. A permanent action will be developed in order to perfect and always improve the existing levels of protection and the necessary adaptations will be made in the workplace both as a consequence of the productive and technical evolution, and to ensure the protection of people especially sensitive to certain risks. There will be no tolerance for non-compliances that affect aspects of Safety and Health at work, and it is always necessary to inform those responsible of the existence of situations of lack of prevention, considering that someone who is aware of situations of preventative non-compliance does not report or communicate it. In any case, the guidelines and orders regarding the Prevention of Occupational Risks must be scrupulously complied with by all obligated subjects, as well as ensuring compliance with the preventive regulations.

9.- Commitment to the Environment and Sustainability.

The obligated subjects are committed to guaranteeing respect for the environment, favoring the adoption of initiatives in favor of environmental responsibility and promoting the development and diffusion of environmentally friendly technologies, so that in any case sustainability is not compromised. . All regulated entities undertake to avoid wasting resources or carrying out behaviors that, despite being initially legitimate, may generate an antisocial or abusive impact, especially if it causes social or environmental damage.

10.- General commitment to defend the reputation of HEMP RIDER S.L.

Behaviors that deviate from this Code of Ethics or any conduct in the performance of professional duties that may harm the reputation or good name of HEMP RIDER, S.L. will not be tolerated. The obligation of the obligated subjects is to always act under the orders and guidelines contained in the Code of Ethics as well as in accordance with the ethical values ​​that preside over HEMP RIDER, S.L. If there is any doubt about how to proceed, the immediate hierarchical superior should be consulted, or with the Compliance Officer.

11.- Dialogue and transparency.

The subjects bound by the Code must observe a position of open and frank dialogue, presided over by the principle of transparency and recip rocity, as an essence both to avoid conflicts and, in case they occur, to resolve them. In any dialogue situation, the participating subjects have the obligation to show respect and due consideration, rejecting the use of discriminatory, threatening, coarse, offensive and insulting language, as well as attitudes of aggressiveness or threats, both physical and gestural or verbal, both in relation to the direct interlocutors and in relation to non-intervening third parties.

12.- Good faith and due diligence.

The behavior of those bound by the Code of Ethics must at all times respect the rules of good faith and due diligence. If there is any doubt as to whether an action or omission may violate the principles of good faith or due diligence, the action will be avoided and the hierarchical superior or the Compliance Officer will be consulted. The requirement of good faith extends beyond compliance with legal regulations, and involves adapting the actions of the obligated subjects to the ethical values ​​and principles that govern HEMP RIDER, S.L., considering that it does not act in accordance with good faith. in those cases in which the result of the action or omission may be harmful or harm HEMP RIDER, S.L., any of the subjects bound by the Code or third parties.

13.- Non-competition, transparency and compatibility.

The subjects bound by the Code of Ethics, when they do not have an exclusivity commitment expressly signed with HEMP RIDER, S.L. Prior to initiating any provision of services for third parties or on their own account, they must communicate said situation with the Compliance Officer so that it issues a compatibility report, in order to avoid situations of illicit competition or conflicts of interest. In any case, all the subjects bound by the Code of Ethics, including those whose relationship is not of a labor nature, have the obligation to refrain from attending and providing services on their own behalf or for third parties, either directly or through interposed persons, to other entities included. within the same scope of market competition as HEMP RIDER, S.L. even when their relationship is not paid or of mere non-professional collaboration. Failure to comply with the duties of prior communication implies disobedience to directive orders and especially the duty of transparency, as well as may additionally entail the violation of the principle of contractual good faith. The duty of the obligated subjects is imposed to always offer clear, authentic and transparent information to clients, regulators, suppliers, customers and any third parties, as well as between the obligated subjects among themselves, especially to everything that affects contracting conditions, characteristics of the products, risks of the products and services, and the information provided must be adapted to the characteristics of the interlocutor so that they are always understandable by him. The omission of information will be considered, when it is relevant and affects the decisions that may be adopted based on it, as a breach of the duty of transparency.

SPECIFIC CONDUCT.

14.- Conflict of Interest Situations. The obligated subjects will always act guaranteeing the defense of the interests of HEMP RIDER, S.L., avoiding causing any damage to the entity. It is totally forbidden for regulated entities to give privileged treatment, favored treatment or treatment other than ordinary treatment to persons or entities with which they have, directly or indirectly, any economic, family, personal or private interest ties. The obligated subjects will always act avoiding causing injuries, of any nature, to HEMP RIDER, S.L., its clients, its partners and the market, applying the highest parameters of professional diligence and integrity. The obligated subjects must act with total responsibility and integrity and prevent their decisions from being motivated, oriented or conditioned by the defense of their personal, economic, family and particular interests or the defense of the interests of third parties unrelated to the interests of HEMP RIDER, SL (suppliers, friends, family, among others). Under no circumstances may the obliged subjects request preferential or privileged treatment due to the fact of having a relationship with HEMP RIDER, S.L. without prejudice to the fact that the special conditions generally approved for employees and related subjects are applicable to them. When there are situations of conflict of interest for reasons of economic, family, friendship or interest relationship that affect any obligated subject, they must refrain from participating or influencing the procedures for contracting products or services, and they will have the obligation to inform of said situation to their immediate hierarchical superior, or to the Compliance Officer. Yes Whenever there is a situation of conflict of interest, regardless of the information and abstention obligations, a written record of said situation must be left in the transaction file.

15.- Duty of secrecy, reserve and confidentiality. Use of strategic, privileged or confidential information. Data Protection.

Subjects bound by the Code of Ethics must use the information to which they have access as a result of their relationship with HEMP RIDER, S.L. exclusively to carry out its tasks and functions in relation to HEMP RIDER, S.L. so that it can never be used for different purposes. As a general principle, and in order to facilitate data protection and control, the regulated entities will only collect data that is essential for the exercise of their functions, refraining from collecting superfluous and unnecessary data. In any case, in the collection and processing of personal data, the obligated subjects must respect the legal and regulatory framework in this matter, without prejudice to the additional obligations derived from this Code of Ethics and other regulations applicable to HEMP RIDER, S.L. The responsible subjects must keep scrupulous confidentiality and secrecy regarding all information related to HEMP RIDER, S.L. its customers, suppliers, other obligated subjects and interested parties whose disclosure or dissemination may lead to harm or a situation of discomfort for both HEMP RIDER, S.L. like the rest of the subjects involved. In any case, special reserve and respect for the confidentiality of personal data, economic positions, interests and any information that affects the clients of HEMP RIDER, S.L. The obligations of secrecy, reserve and confidentiality oblige the obliged subjects both during the validity of their relationship with HEMP RIDER, S.L. as well as even after the binding is complete. The use, for their own benefit or that of third parties, of strategic, privileged or confidential information of which they have become aware as a result of their relationship with HEMP RIDER, S.L. is absolutely prohibited. Failure to comply with the duty of secrecy, reserve and confidentiality, as well as the use of confidential or privileged information, implies the breach of the duty of good faith that must preside over the relationship of the obliged subjects with HEMP RIDER, S.L. The obligated subjects will refrain from making any type of public communication or statement to the media on aspects related to the activity of HEMP RIDER, S.L. its strategic position, interests of the entity, customers, suppliers, related parties and any aspect that may affect HEMP RIDER, S.L. and their position in the market, unless they have the express authorization of the Management or the Compliance Officer. If any of the regulated entities have any doubts about what information is of a privileged, reserved or confidential nature, they will refrain from disclosing or using it, notwithstanding that they may contact their immediate hierarchical superior, or the Compliance Officer to comment on the case. concrete and dispel your doubts.

16.- Obligation of truthful registration of operations and documentary conservation.

The regulated entities, when they participate in operations due to their functions and duties, must account for, record and document these, in a complete, detailed, transparent and truthful manner, without omitting, altering or hiding data or information, so that the operations accounted for and/or or registered have full traceability and faithfully reflect reality. Precisely to guarantee control over the traceability of operations and to verify the faithful reflection of reality, the documentation relating to each of the operations must be kept in full.

17.- Duty to collaborate with all control areas, supervisory entities, regulatory entities and administrative and judicial authorities.

Collaboration with the control areas of HEMP RIDER, S.L. cannot be denied, and a quick, complete and exact response to the requests made by the control areas is required. The omission of data, total or partial, as well as ignorance or delay in responding to the requirements for a period longer than objectively reasonable, will be considered as a breach of the duty of collaboration and infringement of directive orders. When the regulated entities receive a requirement, summons, request, official letter, mandate or any request from the supervisory entities, supervisory entities or administrative or judicial authorities, they must simultaneously notify the hierarchical superior and the Compliance Officer, and fully collaborate effectively and quickly with the corresponding entity. The obligated subjects will collaborate with the adm authorities investigative and judicial in the application of their seizure orders and executive procedures protected by administrative and judicial resolutions. It is strictly forbidden for the obligated subjects to notify, warn or collaborate with the passive subjects of embargoes or executive procedures to avoid the application or reduce the effectiveness of said resolutions.

18.- Use of the entity’s resources. Intellectual and industrial property.

The resources available to HEMP RIDER, S.L. must be used in accordance with the principles of good faith and due diligence, guaranteeing that they are not used for inappropriate, illicit, irregular or other purposes than the performance of the functions and activities related to HEMP RIDER, S.L. Any private use of the means and resources owned by HEMP RIDER, S.L. is expressly prohibited. except those that are expressly authorized in the internal rules for the use of resources and means. The use of intellectual or industrial property rights, patents or manufacturing processes within HEMP RIDER, S.L. is also absolutely prohibited. owned by third-party companies of which HEMP RIDER, S.L. do not have permission or license to use. The means, resources, devices and apparatus made available by HEMP RIDER, S.L. to facilitate the performance and development of the functions and activities of the obligated subjects in their relationship with the entity, they must be used, maintained and preserved in accordance with the principles of good faith and due diligence, inappropriate uses being vetoed and especially those that may deteriorate or harm said resources. In any case, the return of said resources by the obliged subjects must be made immediately, without an express request being required, when the obligated subject’s relationship with HEMP RIDER, S.L. The communication devices provided by HEMP RIDER, S.L., in any of their forms, the means and computer resources, as well as email, must be considered work tools and must be used exclusively for a purely professional use, non-professional uses being prohibited. . Regarding the corporate email, it is necessary to indicate that to the extent that its ownership corresponds to HEMP RIDER, S.L. and it is a work instrument, the user of the same cannot expect from it the existence of a right of reservation or privacy in their communications, being able to be monitored for the exercise of control tasks that guarantee compliance with the norms and values ​​that govern HEMP RIDER, S.L. When the breakage, deterioration, loss, misplacement or any situation that affects the resources and devices, as well as the information contained therein, occurs, the hierarchical superior and the Compliance Officer must be immediately notified. The obligated subjects must respect the intellectual and industrial property of HEMP RIDER, S.L. and third parties, refraining from carrying out any type of action that entails breaking the intellectual and industrial property rights of HEMP RIDER, S.L. as well as any third party. The use of the trademark and distinctive symbols of HEMP RIDER, S.L. is expressly prohibited. outside the professional field, as well as breaking the rules on intellectual property both in relation to publications, materials, books, editions, computer programs, audiovisual elements, and any others that affect both HEMP RIDER, S.L. as to third parties.

19.- Selection and concurrence of suppliers.

Suppliers must be selected by the regulated entities avoiding incurring in conflicts of interest and applying in all cases the objective principles of: capacity, solvency, merit, market positioning, efficiency, price, quality, and any others of a similar nature. In any case, the obligated subjects must guarantee the dissemination and transparency of the needs to facilitate that the greatest number of suppliers can attend the selection and contracting processes.

20.- General prohibition of accepting gifts and personal benefits, both directly and indirectly.

Under no circumstances may the obligated subjects accept gifts, prizes, benefits, discounts or any advantages offered by suppliers, customers and any third party, except those that due to their low amount and quantity, or due to their reference to mere commercial attention, do not exceed 100 Euros in annual computation. Regardless of the amount, money or gift vouchers may never be accepted by the obligors. Whenever a gift, prize, benefit, discount or any other advantage is received from a supplier by the obliged subjects, whatever its amount, the Compliance Officer must be notified. The same treatment and consideration will have for the obligated subjects the assumptions in which the delivery of gifts, prizes, benefits, discounts or any advantages is delivered or facilitated to relatives, friends, people or entities linked to any of the obligated subjects.

21.- Obligations for the prevention of money laundering and financing of terrorist activities.

Subjects bound by the Code of Ethics assume the duty to prevent money laundering and financing of terrorist activities. In this way, they are imperatively obliged to pay the utmost attention and professional diligence to detect operations of illicit or suspicious origin that seek to use the financial activity of HEMP RIDER, S.L. for money laundering or illicit capital laundering as well as to facilitate the financing of terrorist activities. The regulated entities have the duty to notify the Compliance Officer immediately, urgently and without delay of the detection of any unusual, irregular or suspicious conduct or operation that could actually or potentially be considered to be facilitating or tending to facilitate the money laundering or illicit capital laundering as well as to facilitate the financing of terrorist activities.

22.- Absolute prohibition of corrupt conduct.

The effective delivery, promise or mere offer of any kind of payment, commission, gift, advantage, benefit or compensation to any authority, public administration, public official, political parties, members of any of the Powers of the State is absolutely and strictly prohibited. , employees or directors of companies, individuals, institutions or organizations of any kind, whether it is carried out directly or indirectly by any means. This prohibition refers to authorities, entities, political parties, companies, civil servants, workers and directors both in Spain and in any other country. If a regulated entity receives any proposal or approach of a corrupt nature, he must reject it and immediately notify the Compliance Officer. If a regulated entity has any doubt about whether or not he is facing a corrupt practice or conduct, he must immediately notify the Compliance Officer.

23.- Commitment to comply with tax obligations and with Social Security.

The subjects bound by this Code of Ethics undertake to avoid any type of action or omission that allows the evasion of the payment of taxes or the fulfillment of the collection obligations for Social Security. When the regulated entities detect operations that intend to evade the payment of taxes or facilitate the breach of the collection obligations for Social Security, they must notify the Compliance Officer immediately.

24.- Actions in the field of market competition.

The subjects bound by this Code of Ethics will carry out their operations in accordance with the principles of loyalty to the entity, transparency, good faith, due diligence and honesty, and refraining from entering into any situation of conflict of interest, as well as avoiding the use of confidential, strategic or reserved information of the entity or any of its related parties. If, as a result of the duties performed by the regulated entities, they become aware of operations suspected of generating market abuse or anti-competitive practices, they shall immediately inform the Compliance Officer. The regulated entities must refrain from participating, promoting, advertising or facilitating any practice that may unlawfully limit or restrict competition in the market, forcing themselves to immediately report the existence of such practices or any indications about them to the Compliance Officer.

25.- Diligence in the processes of elaboration and manufacture of products in defense of consumers and clients.

All members of the organization will ensure compliance with applicable laws and regulations on the manufacture, preparation or manufacture of products to maintain the health or safety guarantees of consumer protection. They will ensure the effective supervision of regulated health or safety processes.

COMPLAINTS, INVESTIGATION AND BREACH.

26.- Complaints. The duty of cooperation of the regulated entities includes the obligation to notify the Department in charge of receiving any type of information and, in any case, the Compliance Officer of any situation of non-compliance of which there is knowledge or well-founded suspicion. Failure to comply with the obligation to report the existence of situations of non-compliance entails incurring in a situation of indiscipline and disobedience at work. Complaints and information about non-compliance situations will be sent to the Compliance Officer, notwithstanding that without They are sent to other bodies or persons, they always communicate them to the Compliance Officer. The Compliance Officer will be in charge of receiving, registering and investigating the complaints, in any case guaranteeing the confidentiality of the complainant. In any case, it must be ensured that no complainant receives negative consequences or reprisals as a result of exercising their duty to cooperate and report. It should not be forgotten that, in any case, the principles of integrity, honesty and good faith must be applied, so that if the false nature of a complaint is proven, action will be taken against the complainant who has transgressed the values ​​indicated above. All complaints, without exception, will be processed so that their existence is recorded in a registry and the corresponding investigation is opened. Complaints will be communicated to the Compliance Officer, through one of the following procedures: -Existing ethical channel of HEMP RIDER, S.L. -By calling 938016493 -By postal mail addressed to the Compliance Officer, located at Viladomat 291, 8º 1ª (08029) Barcelona, ​​Spain -By email addressed to the Compliance Officer: cumplimientonormativo@thetreecbd.com -Oral or personal communication to the Compliance Officer: Francesc Galiano Molins
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