MEYERACTION CODE OF

CONDUCT AND POLICIES

CÓDIGO

DE CONDUCTA

Y POLÍTICAS

MEYERACTION!

This code consolidates the culture of integrity and transparency we adhere to and that we consider the foundation of our success and growth. Our code of ethics reflects how we interact with our teamwork, clients, collaborators, the environment and each participant in our business processes.

We develop our activities in full compliance with existing legislations, established under ethical guidelines accepted to ensure human rights and fundamental freedoms. We reject any manifestation of physical, moral or psychological harassment, of abuse of authority or of discrimination. We also prohibit all forms of bribery, corruption and any conduct that could create an intimidating atmosphere or that could infringe individuals rights. We also emphasize our commitment to environmental efficiency and social welfare.

At MeyerAction we have the commitment to provide an open and inclusive work atmosphere, where each employee could reach the highest level of job satisfaction and professional development. The base of our success is teamwork, independent and motivated employees, and fostering a good relationship with each member of our staff.

We have adapted ourselves to the new global context, we adopted a hybrid modality of teleworking and coworking which has resulted in a flexible and collaborative working environment where learning and cooperation flow. Health care remains a priority for us.

Technological advancement in telecommunications benefits remote work, however, working in the office is essential for socialization. Therefore, it is crucial to make the right choice between both scenarios to achieve the ideal working equilibrium.

Compliance with this Code is mandatory for shareholders, advisors, employees and collaborators. It is their responsibility to observe and to make observe the provisions herein included. Any non-compliance shall be informed through the communication channels established for that purpose: suggestion box: www.meyeraction.com/buzon. Our company shall guarantee complete confidentiality of the report, the parts involved, the investigation or the case resolution.

Mission:

Our mission is to develop creative and efficient solutions that generate relevant results for our clients´ brands and that impact in a positive way in their consumers´ life, contributing to set up productive and long lasting relationships between the client and us.

Vision:

To be the strategic and creative partner every top brand would like to have, being a key collaborator in the development and growth of their business.

Values or Guiding Principles:

We base our relationships on respect, integrity, commitment, teamwork, responsibility, diversity, equality and non-discrimination, in order to achieve business and social value. We carry out our work in an honest, careful, professional, and impartial manner. We build long-lasting relationships based on trust.

ETHICAL PRACTICE

· With employees

We promote individual and professional development of every member of our team, we guarantee freedom, opportunity equalities, respect for their dignity and individuality, and we provide a safe and healthy atmosphere by adopting protective measures for their wellbeing and development.

· With shareholders and partners

We seek to provide reasonable profitability in a sustained manner, creating long-term value in order to continue growing and facing new challenges.

· With clients

We develop strategic partners, we engender confidence by providing a service based on high quality standards and creativity in order to foster mutual growth.

· With suppliers

Suppliers and collaborating companies are considered a building block in the development of MeyerAction!, hence we build honest relationships based on trust and mutual benefit to grow long-term relationships.

· With Governmental authorities

We comply with laws, we accept and are consistent with public order principles.

· With competitors

We compete in the market founding our business in creativity and qualified service, within a framework of integrity and respect.

· With the society

We promote universal ethical values and specific values of the environment where we develop our activities. We encourage our community's economic and social growth. We protect the environment.

HUMAN RIGHTS POLICIES

Communication: we appreciate and respect open and honest communication. Any concern raised by a member of our staff is confidential and anonymous. We guarantee that there will be no retaliation for filing a complaint, and that we will take remedial measures to give answer to the request.

Hygiene and safety: our work environment is safe and healthy, we tend to provide the best job conditions to boost productivity. Thanks to the characteristics of our business and to the conditions we offer, we have minimized the risks of accidents, injuries and any risk to health.

Harassment, abuse and non-discrimination: we guarantee work environments based on equal opportunities. Under no circumstances, we shall tolerate violence or abuse, in all its forms, or discrimination because of nationality, gender, color, religion, disability, age, sexual orientation, politic opinion, race, etc.

Child labor: we adhere to the legislation regarding minimum age of employment, consequently, we do not hire people under 18 for any position. We know and comply with child labor laws.

Remediation: we do not enter into business relationships with suppliers that use child labor. We support the implementation of remediation plans to guarantee children fundamental rights, particularly, their right to access education while not harming the family economy.

Forced labor: It is prohibited the use of any type of forced labor such as prison labor, debt bondage, military work, slavery and any type of human trafficking.

Regular work: our personnel are hired under a legal contract within a proper framework, regulated by a collective agreement. Any type of illegal contract is prohibited.

Compensation and benefits: MeyerAction human resources policy is based on the work for objectives. We encourage the development of individual capacities, giving job promotions and a higher salary. Wage increases are fixed by the industry labor market consequently, they are competitive.

Decent Wage: as stated in this Code, at MeyerAction, we comply and make our collaborators comply with -being a fundamental pillar in the management of our supply chain- providing decent wages, understanding this as an income that allows workers and their families to meet the basic and additional reasonable needs.

Working Hour: the development of the duties should be performed within the normal schedule and the time that states the law, under no circumstances exceeding 45 hours per week. Under exceptional circumstances, the sum of normal working hours and voluntary overtime working hours shall not exceed 60 hours per week. Our employees have 48 consecutive hours off in every 7-day period. We do not ask for extra working hours, in case of doing so, it is consented and compensated at a higher rate.

Trade union: At MeyerAction we respect the right employees have to form a trade union, and to join freely, without fear of reprisal, intimidation or harassment. And we assume the compromise of dialogue whether a trade union has been formed.

ENTERPRISE POLICY

Corruption: It is explicitly prohibited, for employees at all levels, to promote or engage in illicit behavior. The misuse of power, including any dishonest activity, has a negative effect on the interests of our business. Some of the misconducts referred to in this section could be: influence - trafficking, use of false information, improper hiring practices.

Bribe: MeyerAction does not give or receive directly or indirectly, through individuals or companies, bribes, gifts or other advantages in order to obtain benefits or profits. Any behavior of this nature shall be rejected and reported immediately.

Fraud: There is no tolerance with criminal behavior related to fraud, understanding by this the use of dishonest methods to take tangible or intangible goods from a person.

Accurate financial records: our books, accounts and financial records reflect accurately every commercial transaction carried out by the company, complying with the legal accounting requirements. None of the records shall hide or distort the true financial picture of the company.

Anti-Money Laundering: There shall be no tolerance with any activity related to properties or funds obtained from doubtful or illegal sources or related to money laundering. Our collaborators should never be engaged, under no circumstances, in the practice of illegal acts.

Conflict of interests: At MeyerAction we demand that employees´ and collaborators´ personal interests do not interfere with the interests of the company. All employees shall refrain from seeking to make personal benefit or benefit for third parties by abusive or illegal means that could interfere with the company's normal course of activities.

Gifts and courtesies: we do not request, offer or provide gifts, or any article of monetary value, which may, even if apparently, influence a personal or third parties decision in the future. We only accept or provide gifts and courtesies that are moderate in terms of value, frequency and quantity and that comply with ethics principles.

Privacy and confidentiality: every employee has the obligation to take care, to preserve and to keep confidential our company, our clients and our suppliers information. It will be considered a serious misconduct to disclose any relevant information to third parties. Personal data handling should comply with current legislation.

Intellectual property: intellectual property rights related to knowledge acquired in the workplace belong to MeyerAction, therefore, the company reserves the right to use them whatever and whenever considers it opportune complying with regional and international legislations. Intellectual property rights involve any activity developed or hired by the company.

ENVIRONMENTAL POLICY

PREVENTION AND IMPACT: our objective is to prevent and, when not possible, to responsibly manage to minimize our impact, inherent in MeyerAction operations, on the environment. At the same time, we boost a culture to promote environmental awareness among the staff and collaborators by becoming more conscious of the environmental impact of their day-to-day activities and of the implementation of measures aimed at minimizing the impact on the environment. By doing so, we are contributing to sustainable development. We identify and create opportunities to reuse, whenever possible, wastes or resources already used.

Resources optimization: energy consumption at an office is completely controllable and by adopting several practices at the workplace we could achieve significant savings. We open curtains to make maximum use of daylight. We turn off the lights when not necessary, even for short periods of time, also the computer, the printer and other electrical devices once the working day has finished. We turn off the computer screen during periods of inactivity (meetings, breakfast, etc.) The only screen protector that saves energy is black.

We don´t let water run, unnecessarily, while washing hands. We don´t waste water, we turn off the faucet correctly. In case of leaks we, immediately, contact maintenance service. We adjust gas heating due to ambient temperature suggested for energy savings . We only heat or cool rooms where there are people. We use proper clothes and avoid air leaks.

Noise also pollutes so we switch electric devices off when not being used. We intend not to raise the voice or to make unnecessary noise.

Efficiency and reuse: We print in an efficient way, intending not to print unnecessary documents. Before printing, we check the documents to correct mistakes, making use of ´preliminary view´, adjusting margins, using efficient paragraph division and reducing letter size. We print on both sides of the sheet of paper. We reuse each paper that has been printed in only one side to print drafts, to make notepads. Whenever it is possible, we work with digital files.

Recycle: we recycle the resources already used to build a new product. Recycling is a good option to avoid producing unnecessary wastes or buying new products. However, recycling should be a prior option to reducing and reusing.

Wastes classification: we pay careful attention to the wastes produced and to throw them in the right place, in order to make reusing easier and to curb environmental damage. We have bins for organic wastes and for recycling wastes. Toilet paper, wax paper and laminated paper shall not be put in the paper and cardboard bin as they cannot be recycled.

HYBRID ENVIRONMENTAL POLICY- HOME OFFICE AND COWORKINGwe are focused on providing working environments based on flexibility, quality of life, collaborative work, health, security and integrated with technology in order to adapt our culture to a hybrid model of home office - coworking, keeping our pillars of sustainability and environmental responsibility. That is why we keep making the most of our resources in order to reduce environmental impact. We know that making informed and conscious decisions are part of the solution.

HOME OFFICE

Good practices: to develop your job it is of vital importance to choose an office space in the house. It should be a comfortable, private and well-lit room. Adopt a right body posture while working. Create a daily routine establishing productivity hours and resting moments. Define daily goals. Don't use working hours for internet browsing, social media or applications, use them in your resting moments. Finally, It is also vital to know when to end the working day to give time to recreational activities, sports and, mainly, to the family. Adopting these practices guarantees not only comfort in the work space but also productivity.

ENVIRONMENTAL POLICY

Environmental protection:

Our houses are also part of the "new office". We know that from home a lot can be done to protect the environment and everything we do, although it seems few, contributes to its protection and is part of the solution. Practices:

Save energy at home, unplugged devices, turn off lights and screens when not in use, use natural light whenever possible.
· Adjust the thermostat in the workplace, raised in summer and lowered in winter. Take short showers to reduce water and energy consumption.
· Limit the use of cars and take public transport. Another excellent option would be walking or riding a bike. Not only do they help the environment, but they also are good for health.
· Do the shoppings in proximity stores. By doing so, you preserve employment and reduce logistic costs.
· Digitalise all the documents. Ask to receive digital invoices, bills, and use the modality " online payment " to cancel obligations.
· Introduce nature in the workspace. There are indoor plants that are an excellent option to keep air clean by reducing carbon dioxide and other polluters.
· Do not accept products made with 'single use materials' such as plastic or polystyrene. Whenever impossible, collect and take them to the recycling bins.
· Contribute with initiatives like “fill a bottle with love”, where single use plastics are transformed into furniture for solidarity purposes.
· Reuse. Give elements a second life: use cloth bags to do the shopping, use thermal containers for cold or hot drinks, etc.
· Donate those things, objects or clothes you don't use anymore. Not only are you contributing with somebody who needs it but also you are giving things a second life.
· Give advice to young or less experienced coworkers and collaborators, and encourage them to pursue a better future.
· Buy energy-efficient appliances to replace the old ones.
· Hang-drying clothes instead of tumble-drying. Do full load washings.

Coworking:

Environmental protection: bear in mind that we work in a flexible way, so, whenever you want or need it you have an office at your disposal to develop your work in a comfortable, agile and efficient way. Our objective is no matter where but keeping productivity and efficiency. Remember to focus on prevention and in reducing environmental impact!

· Be a responsible consumer by reducing energy consumption. Use eco-mode in devices, turn off displays, use LED lights and try to make the most of natural light.
· Reduce water consumption, adjust the thermostat following the temperatures suggested for energy savings. Use weather stripping and caulking to minimize air loss from windows and doors. Keep using resources consciously.
· Hire local suppliers and prioritize those who work to reduce environmental and social impact.
· Do not buy "single use products", choose those who are made and packaged with recycled materials.
· Logistic efficiency is a priority, choose always the option with lesser environmental impact.

ENVIRONMENTAL POLICY

· Digitalize all data that is possible such as invoices, administrative and financial records.
· Avoid using paper, when not possible, print in both faces using save -energy mode.
· Recycle everything that is possible, such as paper already used.
· Use electronic communication to exchange files and information.
· Replace single-use batteries for rechargeable ones. Dispose the old ones in specific containers.
· Classify non-hazardous waste in:
A) Organics: food waste.
B) Ordinaries: paper bags or dirty plastic bags.
C) Recyclables: card, newspaper and magazine paper, glass, can, etc.
D) Industrial Recyclables: cable, copper, etc.

HAZARDOUS WASTES

Due to our business characteristics, the production of hazardous wastes and those known as waste electrical and electronic equipment (WEEE) is low but not null. Consequently, it is important to be aware of the right mechanisms of disposal for those occasional situations. In those cases, we will dispose them in places designated for such purposes where they would be repaired and donated or recycled to reuse materials such as plastic, glass, metals, aluminum, etc. By doing so, we guarantee the correct treatment and traceability of the wastes. If for any exceptional circumstance we produce a higher amount of this type of wastes, we would hire a private company to manage the disposal of them, complying with the current legislations. Please contact hello@meyeraction.com. for any issue related to WEEE and hazardous wastes.