Code of ethics and compliance

1. Purpose

Gómez & Molina Joyeros is aware of the need to attend to our social responsibilities with our collaborators, clients and suppliers. We have the firm intention of working for the excellence of our organization and its relations with all operators in general.

Willingness to serve, acting proactively, efficiently and effectively, focused on excellence, is the basis for the professional responsibility of all, based on integrity and individual and corporate responsibility.

To this end, we have adopted a code of ethics that aims to guide the behavior of all those who are within the scope of our organization, in order to reflect our alignment with the culture of compliance.

We work at all levels of the organization to detect, suppress and prevent situations that are contrary to regulations, including criminal ones, and our actions are therefore based on ethical and honest behavior above any other value.

Scope of application

Our code of ethics governs the actions and relationships of partners, administrators, managers, employees, in general for all personnel related for one reason or another with Gómez & Molina Joyeros.

We are also committed to transferring the ethical conduct guidelines that govern our organization to all those who interact with us in one way or another.

3. Principles and Values

Our behavior must always and at all times be upright, responsible and appropriate to the basic rights and strict regulatory compliance, whether we are part of Gómez & Molina Jewelers, as well as all those who act in its scope, especially suppliers and external collaborators.

4. Guiding principles of conduct and essential standards of behavior.

4.1. Respect for Human Rights

Gómez & Molina Joyeros firmly believes in and is committed to the full respect of Human Rights and public liberties, as well as basic ethical practices, as set forth in the Universal Declaration of Human Rights, adopted and proclaimed by the United Nations General Assembly on December 10, 1948, the Convention for the Protection of Human Rights and Fundamental Freedoms (Council of Europe, Rome, November 4, 1950) and the Tripartite Declaration of the International Labor Organization (ILO).

We pledge not to collaborate with third parties in the violation of any Human Rights norms, nor to participate in any action that compromises respect for the principle of legality.

4.2. Respect for essential standards

In our actions we are committed to always comply with current legislation and we adopt internal policies to avoid any non-compliance.

We also pay special attention to strict compliance with:

● The general provisions (laws, regulations, circulars of regulatory and supervisory bodies) that regulate the organization’s activity in any country.

The regulations, standards, protocols and internal procedures implemented in the organization; and especially this code of ethics.

The deontological principles and rules applicable to them, as well as the customs and good practices of the countries in which they operate.

● The obligations and commitments assumed by the organization in its contractual relationships with third parties.

● The rules contained in the Spanish criminal code and in particular those that affect in accordance with its article 31 bis to the legal person.

5. Basic framework of conduct.

5.1. Respect for the Basic Rights of Individuals

We work to provide an environment of professional respect, mutual collaboration and promotion of equity that governs our relationships, and therefore we work to promote non-discrimination and non-violence among all of us in the organization and even with third parties.

5.1.1. Respect and professional development

In Gómez & Molina Jewelers we are committed to training as a way of professional promotion. Equal opportunity, respect for diversity and equality are pillars of our professional relationships with our employees.

5.1.2. Occupational health and safety

We are concerned about implementing occupational health and safety policies, basic for the professional development of all members of Gómez & Molina Joyeros.

5.1.3. Privacy

The personal data and privacy of individuals are one of the main concerns of Gómez & Molina Joyeros, we follow the appropriate protocols to protect this privacy and work daily to improve our system and train members of our organization for their protection.

5.2. Respect for heritage, property, the market and free competition.

5.2.1. General, equity, fraud, property and foreclosures.

We are committed to protecting and respecting intellectual and industrial property, and to implementing policies aimed at promoting free competition and the market; to safeguarding consumer rights, protecting private property and facilitating compliance with administrative and judicial rulings.

5.2.2. The market, advertising, consumers and free competition.

We consider our suppliers and collaborators an indispensable part of the achievement of our objectives of growth and improvement of the quality of service and excellence in our activities. Our objective is to establish relationships based on trust and mutual benefit and to this end we promote compliance with the contractual conditions and obligations between the parties. In order to promote ethics in our relationships, we ask our suppliers to subscribe to this Code of Ethics.

5.3. General interests, taxation, social security, money laundering and means of payment.

5.3.1. General interests.

Gómez & Molina Joyeros is committed to society through, among others, its sustainable development, contributing to the maintenance of the social state, so we ensure the payment of our tax and social security obligations, providing the public administration with real information, both financial and fiscal, as well as that related to the field of social security. Likewise, we use the resources and grants for the purpose for which they were allocated.

5.3.2. Taxation and social security.

In the fight against money laundering we have implemented strict protocols consisting of limiting cash payments and collections, the identification of whoever contracts with Gómez & Molina Joyeros, the accreditation of the ownership of bank accounts, the assurance of the identity of the buyer-seller or customer-supplier as issuer or receiver of the invoice, as well as the relevant communication to Sepblack of suspicious transactions.

5.4. Public Safety

5.4.1. Environment.

Our commitment to the environment is the highest expression of respect for the future of our generations to come, therefore we implement the environmental management policies and systems appropriate to our activity.

5.4.2. Public health and drug trafficking.

We are concerned with avoiding any activity that compromises people’s health in the broadest sense. We ensure that no work is performed under the influence of alcohol or other legal or illegal substances that could affect the level of safety for the activity performed.

5.5. Against ethics, transparency, corruption, conflicts of interest, political party financing, bribery and influence peddling.

5.5.1. Transparency.

It is a principle of Gómez & Molina Joyeros to duly transmit the real image of the company, of its activities in the broadest sense. The information received from Gómez & Molina Joyeros by third parties, whether natural or legal persons, public or private, shall always be complete, truthful and understandable, and in no case misleading. Manipulation, falsification or fraud in such information is absolutely prohibited.

5.5.2. Corruption and bribery, bribery and influence peddling.

Contrary to influencing the will of individuals or legal entities to obtain any type of benefit, through practices that deviate from business ethics, we do not give, receive, offer or accept, directly or indirectly, gifts, presents or compensation of any kind that tend to improperly obtain any type of advantage or favorable or privileged conditions other than mere acts of courtesy and in any case under the supervision of the compliance officer.

5.5.3. Conflict of interest.

When the interests of Gómez & Molina Joyeros and any of those affected by this code collide directly or indirectly, whether due to professional, personal, family or any other type of interest, they will not intervene in the decision making process.

5.5.4. Financing of political parties.

We pledge not to make donations or contributions to political parties, state or foreign. Corruption with our political representatives attacks the axis of democracy and the basic ethics of relations with our institutions, hence such activities are absolutely forbidden.

6. Internal framework of conduct.

Determined to demonstrate the honorability of our internal structures and our own existence as an economic operator, we have established an internal framework of conduct.

6.1. Internal conflicts of interest.

We avoid collisions of private interests with those of Gómez & Molina Joyeros, especially if this affects decision-making. We extend the decision not to receive gifts directly or indirectly, whether in any form that is not considered a mere courtesy.

6.2. Inside information and confidentiality.

Confidentiality as part of the contractual good faith in the relations of Gómez & Molina Joyeros with its environment, implies the maintenance of professional secrecy of the information available, whether it is commercial, economic, strategic, use or use of operational processes, work systems and any other internal procedure, affecting individuals, companies, customers-suppliers and that are committed to preserve all those who act in our field.

6.3. Asset protection.

We facilitate and make good use of all the resources and means necessary for the development of the professional activities of Gómez & Molina Joyeros in accordance with the law and always for the benefit and in accordance with the business objective.

6.4. The use of the brand and image of Gómez & Molina Joyeros.

The use of the image and brand of Gómez & Molina Joyeros must always respect the good image of the Group, as well as the contents of this Code of Ethics.

6.5. Customer and supplier relations.

The treatment with the client or supplier shall always be exquisite but not ostentatious or showy, nor shall it be done in an overbearing or discriminatory manner.

The internal regulations of Gómez & Molina Joyeros guarantee transparency, equal treatment and maximum objectivity in relation to the contracting and selection of suppliers, as well as compliance with regulations and subscription to this code of ethics.

The extreme rigor in the treatment of personal data related to customers, is one of the highest commitments of Gomez & Molina Jewelers, which will only be justified by legal relationships.

6.6. Partner relations.

We provide the maximum information with absolute objectivity and transparency to our partners, for proper decision making and management. Likewise, it is from the Board of Directors itself that the organization is obliged to disseminate this code as a central axis of good practices and business ethics.

7. Acceptance, responsibilities and non-compliance with the code of ethics.

All those affected by this Code must comply with and disseminate its rules and principles; comply with the regulatory framework of laws, regulations, ordinances and rules in general that affect their specific activity; duly advise and seek advice regarding regulatory compliance and this Code; participate in training activities; report through the appropriate channels any possible non-compliance with regulations or the conduct contained in this Code; participate in the controls carried out to identify and correct deficiencies or failures in the detection of regulatory risks or malpractice of any kind.

The administrative and management bodies of Gómez & Molina Joyeros must set an example with their own behavior, of the highest integrity and honorability that is required of them as persons of reference for others affected by this code; transmit in all their actions the culture of regulatory compliance and honesty; support the knowledge of good practices, business ethics and social responsibility, and ensure that all persons affected by this code duly understand its contents and comply with and enforce compliance with its rules and contents.

Infringements, breaches, violations of the code of ethics by any of the affected parties may result in the imposition of sanctions with the adoption, if appropriate, of the corresponding legal actions, all in accordance with the CODE OF CONDUCT AND SANCTIONING PROCEDURE of Gómez & Molina Joyeros, all without prejudice to the criminal liabilities that may be legally enforceable.

8. The Compliance Officer and the functions of the Code of Ethics Committee.

The functions of supervisor of the Code of Ethics are assumed directly by the members of the compliance committee, who are indistinctly the persons of consultation who must ensure the dissemination, knowledge and compliance with the Code of Ethics; as well as interpret and facilitate the resolution of conflicts arising from its content.

9. Origin, validity and approval.

The Code of Ethics comes into force on the day of its publication and its validity will be indefinite, its revisions and updates will be periodic and approved by the administrative body at the proposal of the compliance committee.

Full text unanimously approved by the Board of Directors of Gómez & Molina Joyeros, S.L. on December 15, 2016.

10. Gómez & Molina Joyeros ethical communications mailbox.

Through the following link you can access the ethical communications mailbox of Gómez & Molina Joyeros in accordance with Law 10/2010 on the prevention of money laundering, the EU Directive 2019/1937 on the protection of whistleblowers, and the Compliance system of Gómez & Molina Joyeros.