ETHICAL CODE

COMMITMENT PROFESSIONALISM QUALITY
Millennials Consulting SL
INTERNAL REGULATIONS
(hereinafter, the "Regulations")
INTRODUCTION

The drafting and elaboration of this Regulation is based on the following aspects:

The exponential growth of the company in the last year has led us to jointly draft and approve a Code of Ethics

II. GENERAL FEATURES

Article 1.- Legal regime

About us Millennials Consulting SL (hereinafter, the "Company"), will be governed by all current legislation, as well as by these Regulations and by all applicable regulations and collective agreements.

Article 2.- Purpose of the Regulation

This Regulation is integrated as one of the basic rules for the operation of the Company and its relationship with its employees, regulating essential aspects such as the structure of the Company or the obligations and rights of its employees and their responsibility. In any case, this Regulation will respect the provisions of labor legislation and, where appropriate, in the applicable collective agreement.

Finally, this Regulation will apply to the employees mentioned in Article 4 below.

Article 3.- Territorial scope of application

These Regulations will be applicable throughout the territory in which the Company carries out its activity in accordance with its Statutes and the agreements adopted within its administrative body.

Article 4.- Subjective scope of application

These Regulations will apply to all Company personnel, regardless of their level or position, seniority or type of contract.

Hereinafter, all personnel to whom this Regulation is applicable will be referred to as “Employees”.

Article 5.- Duration of application

The Regulation will enter into force on the following date: January 7, 2020 and will have an indefinite duration from that date.

Article 6.- Modification of the Regulations

The Company's management may review, modify, exclude or add new conditions or obligations to these Regulations at any time, provided that these modifications respect the provisions of labor legislation and the applicable agreement, and are made in writing.

These changes must be duly communicated to the Employees in writing according to the Company's usual channels of communication with them.

Article 7.- Interpretation of the Regulations

The interpretation of the Regulation will be carried out according to the principles that inspire it and according to its guidelines and the literal of its articles. The provisions of the same shall apply to the Employees who are bound in accordance with the provisions of article 4 unless different conditions are agreed in writing between the Company and the Employees who so wish.

Article 8.- Sole Agreement

This Regulation supersedes and replaces all other regulations or agreements, written or verbal, on the matters included in this Regulation.

In this way, the previous agreements on these points cease to be valid and effective from the date of entry into force set forth in Article 5.

Article 9.- Partial nullity

The possible declaration, either by a judicial or administrative body, of the illegality, invalidity, nullity or unenforceability of any of the articles of this Regulation, or part of them, will not lead to the illegality, invalidity or unenforceability of the rest. articles nor of the remaining parts thereof, which will remain valid in all that proceeds, all provided that the articles or part thereof declared illegal, null, invalid or unenforceable are not essential.

Article 10.- Applicable law and competent jurisdiction

These Regulations will be governed and interpreted in accordance with Spanish legislation and, in particular, according to the provisions of the Workers' Statute and all related labor regulations, as well as that indicated in the possible applicable collective agreement.

The Parties submit for the resolution of any disputes or claims arising from the interpretation or execution of the Regulations, including all those obligations arising or related to the Regulations, to the jurisdiction of the competent Courts and Tribunals according to law.

III. BUSINESS ORGANIZATION

Article 11.- Hierarchical structure of the Company

In order to guarantee the correct management and organization of the Company and allow its proper functioning, the following organizational structure is established:

I. The address of the Company

The address will correspond to the individual entrepreneur himself.

Hereinafter, the person or body in charge of managing the Company will be known as the “Management”.

II. The departments or areas of the Company

The remaining structure of the Company will be organized around the following departments or areas:

– Marketing Automation Area, organized as follows:

He is in charge of carrying out consultancies where the needs of the company are discussed for the optimal implementation of ZOHO. CRM and other applications of this way to create a business strategy that allows growth with all areas of the company digitized

- Area SEO, organized as follows:

He is the one in charge of carrying out a prior audit of the pages prior to the execution of any strategy according to the requirements of each of the clients.

From now on, each of the managers or team leaders who direct each area will be referred to as “Manager” or “Managers”.

IV. GENERAL PRINCIPLES

Article 12.- Equality in hiring

The Company is committed to guaranteeing equal access to employment for all Employees or all potential candidates, carrying out a human resources policy based on the principles of equality, non-discrimination and respect for the dignity of Employees.

This policy is applicable to both current Company Employees and future job candidates or applicants, and there is no discrimination in their selection and hiring for reasons of gender, race, religion, disability, marital status, age, ideology, pregnancy situation, identity or place of residence, among others.

This principle will inspire the entire human resources policy, as well as the Company's activities in relation to the hiring of personnel, including the receipt of resumes; carrying out the screening or selection of candidates; job interviews; the preparation and analysis of attitude and knowledge assessment tests; setting wages and supplements; and the establishment of the particular conditions to which the employment contract will be subject.

In this way, the selection process for new employees will be carried out following objective criteria of merit, experience, knowledge and ability according to the characteristics and needs of each position offered. All candidates will have the same opportunities and the final hiring will be made according to the aptitude and adaptation of the Employee to the position. The working conditions will be established in turn without any type of discrimination and there will be no discriminatory differences between the Employees and the future incorporations.

Finally, the Employees undertake to facilitate the incorporation and integration of new employees into the workforce, facilitating their training and adaptation as much as possible, and respecting in all cases the aforementioned principle of equal access and non-discrimination.

Article 13.- Prohibition of discrimination and prevention of harassment

The Company is committed to promoting and actively favoring the creation of an inclusive and respectful work environment, which faithfully complies with all current legislation on the prevention of discrimination and harassment, whether for reasons of gender, race, religion, disability, marital status, age, ideology, pregnancy, identity or place of residence, or for any other reason related to the above.

By virtue of the foregoing, Employees must provide their services in an inclusive manner, not allowing any type of discrimination or harassment of any kind, whether with their own colleagues, with their superiors or with their dependent personnel.

For the purposes of these Regulations, harassment is understood to be any conduct or act by any Employee or Management, whether verbal, visual or physical, against one or more Employees based on reasons of gender, race, religion, disability, marital status, age, pregnancy status, identity or place of residence, or any other possible related reason. This conduct will directly affect the Employee, either by creating a degrading work climate or environment, or by causing a mental or physical disorder, by forcing him to resign, or by preventing him from applying for possible promotions or improvements in his position or working conditions.

By way of example, and not exhaustively, off-tone comments or jokes, the use of denigrating stereotypes, threatening and/or authoritarian behavior or any non-consensual physical contact will be considered harassment situations. These behaviors will be punishable whether they take place in the workplace, during social events or business trips or through telematic means, such as through email, mobile phone, etc.).

Any type of discrimination or harassing behavior will give rise to the corresponding sanctioning procedure, and may lead, in serious situations, to the disciplinary dismissal of the employee in accordance with the provisions of the Workers' Statute.

Finally, the Employees have the right and the duty to report to the Management any form of discrimination that they may observe in the development of their activity before the Management. This communication must be carried out in accordance with the provisions of the Section on internal communication of the Company established in these Regulations.

Article 14.- Prohibition of child labor

The work of minors under the age of 18 is totally prohibited in all the Company's work centers. Only those under 18 years of age and over 16 emancipated or over 16 years of age who have the corresponding authorization from their parents or legal guardians will be allowed to work.

Article 15.- Internal promotion policies

Following the provisions of Article 12 on "Equality in hiring", the promotion and advancement of Employees will be carried out in accordance with the principles of non-discrimination, training and experience.

In this way, higher positions will be assigned to those Employees who demonstrate adequate training, who pass the corresponding tests and who have carried out their work diligently, complying in all cases with the provisions of these Regulations, and in the legislation and applicable collective agreements.

Article 16.- Occupational risk prevention policies

The Company undertakes to guarantee the safety of the Employees in accordance with the provisions of Law 31/1995 on the Prevention of Occupational Risks and other legislation related to this matter.

In this way, Employees will be provided with all the security and protection means necessary to carry out their activity. Specifically, the Company undertakes to comply with all occupational risk prevention measures established in labor legislation and the applicable collective agreement, providing the necessary material and training means to Employees to guarantee the correct development of their work. .

Employees, as well as future additions to the workforce, will receive the corresponding instructions on occupational risk prevention, and will be obliged to know all the risk prevention and safety policies implemented by the Company.

In addition, regular courses or training talks will be held in order to inform about new safety measures and policies will be established for the prevention of occupational accidents adapted to the activity carried out by the Employees.

Article 17.- Promotion of the professional development of Employees

The Company will seek, within its possibilities, the promotion of its Employees, providing them with the knowledge and instruction necessary to carry out their activity effectively and grow within the Company, following in all cases the internal promotion and hiring policy. established in these Regulations.

Article 18.- Protection of private information of Employees

The Company recognizes the importance of protecting all confidential information in relation to its Employees in strict compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons regarding the processing of personal data and the free circulation of these data (RGPD), as well as Organic Law 3/2018, on the Protection of Personal Data and guarantee of digital rights and its development regulations (LOPDPGDD), and /or those that could replace or update them in the future.

In this way, the Company undertakes to manage the Employee information files in accordance with the aforementioned regulations, and must request authorization from its Employees in order to carry out the correct processing of their data. The data of the Employees may be incorporated into a proprietary file, automated or not, for data collection in order to correctly execute the employment relationship and, eventually, allow the administrative and/or commercial management of the data that the Company may estimate. necessary.

Finally, the Employees may exercise all the rights of access, rectification, deletion, limitation of treatment, portability or opposition that they may have in accordance with the aforementioned legislation.

Article 19.- Reconciliation of professional and family life

One of the guiding principles of the Company's human resources policy will be the active promotion of measures to reconcile the professional and family life of Employees in all that is possible according to their activity.

Within the Company, the establishment of schedules that take into account the family situation of the Employees will be promoted, trying to adapt, as much as possible, the working day to their family needs.

Lastly, these Regulations include specific measures aimed at reconciling work and family life for Employees, inspired by this principle. In addition, in the future we will try to develop new measures according to the needs of the Employees.

Article 20.- Compliance with immigration regulations

The Company undertakes to comply at all times with the applicable legislation on the hiring of foreign workers, both those of community and non-community origin.

In this way, the Company expressly prohibits the hiring of employees who do not have a valid work permit, or who do not demonstrate that it has been duly granted by the administration.

In those situations in which it is desired to hire personnel who do not have a work permit, the corresponding procedure must be followed to carry out the correct processing of the employee's work permit before formalizing their hiring.

In any case, any Employee may notify the Management of possible breaches of the legislation on immigration that may be detected in the Company's hiring policy.

Article 21.- Integration of people with disabilities or at risk of social exclusion

The Management will establish the appropriate measures to facilitate the inclusion within the Company and the development of its activity of those people who are in a situation of physical or mental disability, as well as those who are at risk of social exclusion.

V. STANDARDS OF BEHAVIOR

Article 22.- Use of the Company's IT resources

The Employer will use the computer resources of the Company diligently and responsibly for the development of its activity. Within the computer media, all those telematic methods that can allow correct communication between Employees are inserted, including personal computers, mobile phones or tablets, Wi-Fi connections or corporate email accounts, among others.

Specifically, the following aspects must be respected in relation to the telematic means provided by the Company:

a. The installation of software or computer programs other than those provided on the Company's computer or tablet, as well as the use of software or computer programs without their corresponding license, is prohibited.

b. Corporate email may not be used for uses that go beyond what is considered necessary for the strict development of the activities of your position. In addition, responsible use of the email account must be made in accordance with the Company's guidelines, not being able to use it to defame or disqualify other colleagues or third parties, or use offensive language.

c. The Company will carry out the necessary control of the email accounts and computer means of the Employees. These control activities will be limited to verifying compliance with work obligations by the Employees and guaranteeing the integrity of the devices provided. In any case, the Employees will be notified in advance of the performance of these control activities.

d. Employees may not encrypt e-mails sent from the Company's corporate account or install any encryption software or application for this purpose.

In any case, the Company undertakes to respect the privacy of the Employees in the use of the telematic devices provided, following the provisions of the LOPDPGDD. In this way, control activities will be limited to verifying compliance with labor obligations by Employees, in accordance with the provisions of this Article.

Article 23.- Use of Company resources provided to Employees

Employees must take care with due diligence, just as they would with the property they own, and in a manner appropriate to their work, of all elements or property provided by the Company, such as laptops, mobile phones, tablets, company vehicle, among others.

The Employees will be responsible for the damages that may be caused by behaviors that go beyond the daily use of the elements or goods of the Company provided. The improper use or outside of its daily use of these goods will give rise to the corresponding disciplinary sanction.

Article 24.- Protection of the industrial and intellectual property of the Company

Given the importance for the activity of the Company of all its industrial property (patents, trademarks, etc.) and all its intellectual property (copyrights, computer programs, etc.), Employees must respect and protect this type of property of the Company actively.

Specifically, the Company's industrial property will include, among others, patents, utility models, trademarks, trade names and industrial designs owned by it. On the other hand, intellectual property will include all kinds of artistic creations, writings, videos, computer programs, know-how or the like created or owned by the Company.

The use of this type of property by the Employees will strictly adhere to the needs of their position and the instructions of their superiors or Managers, not being able to use any of this type of property for the development of activities other than those that correspond to them. .

Article 25.- Use of the personal mobile phone

In order to avoid possible distractions or accidents derived from inattention at work, prevent errors in their work and guarantee proper collaboration between colleagues for the development of the activity, the use of the telephone or any other Employees' personal mobile device during their working day (not including their corresponding rest periods).

The mobile phone may be used in the common areas during rest hours as long as it is done in a respectful manner with other colleagues and without disturbing the development of the activity.

Abusive, repetitive, or reckless use of the personal phone may result in serious disciplinary action.

Article 26.- Respect in intra-company relationships

The Employees undertake to carry out their activity and work in a diligent and respectful manner with all their colleagues, with their Managers or superiors and/or their dependent personnel and with the Management.

In this way, the Company will try to promote a good work environment, which encourages the development of the activity based on the principles of respect, cooperation, help, trying to avoid possible disputes that may arise within the activity and favoring its resolution of peacefully in the event that they arise.

Any discrepancy or dispute between the Employees must be communicated through the internal channel established for this purpose, and the Company must give a prompt and motivated response in order to resolve it and prevent it from happening again in the future.

Article 27.- Compliance with applicable legislation and internal regulations

Employees must observe all the rules of conduct contained in these Regulations, as well as the instructions of the Management and the applicable legislation.

Specifically, the Employees are obliged to respect and comply with the provisions of this Regulation, as well as all applicable current legislation. No breach of the aforementioned rules will be allowed, either personally or through the help or collaboration of third parties.

Likewise, Employees must inform the Management or their corresponding Manager of these possible breaches within the Company as soon as they become aware of them.

The Company undertakes to provide the Employees with all the information on the obligations contained in these Regulations, as well as on all applicable legislation in order to guarantee that they can effectively comply with all their obligations.

In the event that the Employees are unaware of the applicable regulations at a specific point, or have any doubts about their interpretation or application, they must contact their superiors, Managers or the Management to report said circumstance. The Company undertakes in these cases to provide all the corresponding information and to resolve any existing doubts.

Article 28.- Performance of other work activities

In the search for the development of their activity in the most effective way and the prevention of possible abuses in the use of the information acquired in the development of their work, Employees may carry out activities outside of their working hours as long as they do not imply a detriment noteworthy to the work they must carry out for the Company, and respect the possible clauses of exclusivity or non-competition that may be included in their respective employment contracts.

Employees may, unless specifically agreed otherwise in their respective employment contract, provide advice or services in favor of individuals or legal entities that are dedicated to a similar object or that may be considered the competence of the Company, either in employment contract regime, even if it is a special employment relationship, or under the leasing of services or internal advice, directly or indirectly through interposed legal persons, provided that the information obtained in the development of their work is not used. activity to compete unfairly with the Company.

Employees may also not carry out any other economic activity, in addition to the provision of their services to the Company, either on their own behalf or on behalf of third parties, directly or indirectly through interposed legal entities, if this activity may give rise to a possible situation of unfair competition with the Company.

Article 29.- Treatment of confidential information

The Employees assume that all the documentation, projects, files or information of any nature exchanged, facilitated, or created within the Company or entities and organizations with which it collaborates, that it may acquire or to which it may have access during the course of your employment relationship is confidential information owned exclusively by the Company.

Therefore, the employees undertake, both during and after the end of the employment relationship, indefinitely:

a) to safeguard, not reveal and not communicate to any person or entity, all or part of this information, acting with the greatest possible diligence;

b) not to exploit, directly or indirectly, on their own or for a third party, all or part of this information; Y,

c) not to make or keep copies of the information, in any format or medium, for purposes other than those required to carry out their work.

At the end of the employment relationship, the Employees will deliver to the Management and/or their Manager(s) all the documents and materials that contain confidential information.

Ultimately, the Company's reputation and continued success require that the secrecy of confidential information be maintained and safeguarded at all times. For this reason, the Employees will be responsible for all the damages that may arise for the Company as a consequence of the intentional or negligent breach of their obligation of confidentiality.

Article 30.- Compliance with data protection regulations

All Employees are obliged to strictly comply with the provisions of European Regulation 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (RGPD), as well as Organic Law 3/2018, on the Protection of Personal Data and guarantee of digital rights (LOPDPGDD) and its development regulations, and/or those that could replace or update them in the future.

In this way, the Employees undertake not to communicate to third parties the personal data known in the development of their activity. If it were the case that it was necessary to carry out some type of communication of personal data, they always undertake, and in advance, to request the express, informed, and unequivocal consent of the person who is the owner of said personal data, indicating the specific purpose for which the communication of your data will be made.

Article 31.- Care of materials, vehicles and tools

Employees will treat the materials and tools provided by the Company diligently and appropriately to the characteristics of their work.

In the event that certain means, vehicles or tools require a special qualification for their use (eg mechanical bulls, lifting cranes, driving licenses, etc.), they will only be handled by Employees who have the corresponding qualification. In the event that no Employee has the corresponding qualifying title, the Company will try to facilitate training to obtain the necessary permits.

Any inappropriate use, that does not follow the instructions provided or that is carried out without having the corresponding enabling title will give rise to a sanction in accordance with the provisions of the Workers' Statute.

SAW. PREVENTION OF CORRUPTION AND FRAUD

Article 32.- Conflict of interest situations

Employees are obliged to disclose any potential situation of conflict of interest during the development of their activity. Conflict of interest shall be understood as those situations in which the Employee competes in the same sector as that of the Company or those cases in which he may use confidential information or knowledge acquired in the development of his activity to compete with the Company, among others.

In this way, the Employees may not carry out any activity or transaction that could potentially harm the interests of the Company, unless expressly authorized by the Management.

In the event that any Employee detects a potential conflict situation, it must be communicated to their immediate superior, Manager(s) or the Board of Directors as soon as they become aware of it.

Article 33.- Recruitment of relatives

The Company will try to guarantee respect for the hiring principles based on equal access, experience and training established in these Regulations. In order to guarantee these principles and prevent possible situations of abuse of power or conflict of interest, the hiring of people with close affinity to the Employees and/or Manager(s) is prohibited, which includes family members, friends or people with those who may have romantic relationships, if they do not have the express consent of the Management.

According to these Regulations, the fathers, mothers, siblings, nephews, cousins, grandparents, grandchildren, great-grandchildren, brothers-in-law, sons-in-law, mothers-in-law and any other similar relative shall be considered family members of an employee.

On the other hand, all those with whom you have a friendship relationship, couples, boyfriends, or any other relationship that has been maintained for a period of time will be considered as people with affinity.

The Employees undertake to notify their hierarchical superior of any new incorporation of a family member or a person with an affinity, whether as a staff or freelancer, or as a supplier or collaborator of the Company.

In this situation, the Company may take the measures it deems necessary, and may even request the termination of the contract signed with the Employee's family member or person with affinity or even reject their candidacy.

Article 34.- Acceptance of gifts

In order to guarantee the proper functioning of the Company, and compliance with all criminal legislation on economic crimes, Employees may not accept any type of gift, advantage or gift from third parties that may have interests in the Company, such as be, among others, suppliers, clients or collaborators of the Company (hereinafter, “Related Persons”) who try, directly or indirectly, to influence them in the development of their work or in their decision-making process related to the Company.

Within the gifts or advantages, all kinds of concessions, donations, hidden commissions, aid and trips, among others, will be included.

Article 35.- Making gifts by Employees

Employees may not make any type of gift or gratuity in favor of related Persons that is intended to buy their will or receive an advantage from them and that go beyond what is considered appropriate or what is common in the sector. .

On the other hand, gifts or advantages addressed to public personnel or officials will be totally prohibited, regardless of whether or not they have the direct purpose of obtaining greater advantages or facilities from the administration.

In the event that any Employee becomes aware of these practices, they shall have the right, and the duty, to immediately notify the Management in order to help eradicate this type of conduct.

Article 36.- Treatment of clients

Following the image and principles of the Company, the Employees are obliged to treat all customers with total education, respect and seriousness. The Employees will provide clients with all the information that is requested of them, except for the information protected as it is confidential and that regulated by the legislation on data protection.

In any case, all information sent to customers about products and services must be truthful and precise, expressly prohibiting the provision of false information to customers in communications and promotional activities carried out by Employees.

On the other hand, following the legislation on data protection and what is established in this Regulation, the Employees will treat the personal data of the clients in a confidential manner.

Finally, Employees must follow the provisions of this Section on the prevention of corruption and fraud in all related activities that they carry out with clients.

Article 37.- Relations with suppliers

Employees will maintain an adequate, respectful and lawful relationship with all the Company's suppliers.

The hiring and management of suppliers by the Employees will be carried out in a transparent manner, according to the interests and needs of the Company, avoiding any possible situation of conflict of interest or personal benefit in relation to the hiring or management of the same. .

The knowledge by any Employee of an advantage received by his colleagues or superiors from current or potential suppliers must be reported as soon as possible to the Manager and/or Management.

Article 38.- Market practices

The Company undertakes to compete fairly in the market, complying with all regulations on unfair competition and free competition currently in force at both national and European levels. In this way, no type of misleading conduct that could threaten free competition or the issuance by the Employees of any malicious or false information about the Company's competitors will be accepted.

At this point, this type of fraudulent behavior is also prohibited in relation to any other market operator other than competitors or possible public regulators.

Article 39.- Compliance with accounting and tax regulations

Employees will carefully respect all applicable accounting, tax and Social Security regulations in each of the operations and transactions they carry out. Thus, customers must be billed in accordance with the provisions of current legislation and all expenses must be justified by means of the corresponding invoice or contract. These supporting documents must be sent to the personnel in charge of keeping and managing the Company's accounts as soon as they are available.

On the other hand, Employees are expressly prohibited from carrying out any activity or transaction that aims to breach applicable tax or Social Security regulations or evade the payment of any fee, levy or tax, whether of a state nature. , regional or municipal, to which the Company is obliged to pay.

In relation to the foregoing, the Company undertakes to respect at all times the applicable tax and Social Security legislation, keeping the accounting books clearly and in accordance with the applicable accounting and tax principles and obligations. The persons responsible for the preparation of these documents must guarantee the reliable collection of data and the correct preparation of all financial statements.

Article 40.- Compliance with environmental regulations

The Employees undertake to comply with all environmental, pollution prevention and environmental protection regulations applicable to the Company's activity, as well as all the Company's instructions or conduct guides in relation to the handling of materials, recycling and pollution prevention.

Article 41.- Compliance with the Regulations and instructions of the Company

The Employees are obliged to comply with all the provisions of these Regulations, as well as all the instructions they receive from the Management or their Manager(s).

In this way, the work procedure must be adjusted to what is established by the superiors in charge or Managers, as well as to the guidelines, work guides or manuals prepared by the Company. In the event that any doubt arises regarding said guidelines or instructions, the Employee must contact their Manager(s) or, if this is not possible, the Management, in order to resolve all possible existing doubts.

The Company undertakes to provide the necessary courses and training to guarantee the correct development of the work of the Employees and their adaptation to the new work procedures or to the new technical tools acquired by the Company. The Employee will be obliged in turn to attend all these courses or training sessions, as well as to pay all the attention and interest to guarantee the correct knowledge of it.

Finally, the Employees must allow and facilitate all the auditing tasks that the Management may carry out in order to analyze the current situation of the Company, establish the rate of compliance with the Regulations and evaluate the possibility of implementing new improvements that may be made. consider necessary.

Article 42.- Responsibility of Managers

All those Employees who have other employees or workers under their management, including all Managers, must faithfully respect the provisions of these Regulations and be an example of its application for their dependent employees.

In general, the Managers will act in a respectful and inclusive manner, with full respect for the principles of non-discrimination and equality, and the other principles contained in these Regulations, always ensuring the welfare of the Employees and the interest of the Company.

In addition, they will provide all their support to the Employees in everything they need for the proper provision of their services, resolving their doubts diligently and motivating them appropriately.

Regarding the performance of the activity, the Managers will provide their Employees with all the necessary information so that they can carry out their work effectively and in complete safety, as well as clearly know all their obligations.

On the other hand, they will control that their dependent employees respect the provisions of these Regulations at all times, as well as the other corresponding instructions or guidelines for action or behavior. In the event that any serious or repeated breach of the Regulations is detected, this situation must be reported immediately to the body or person in charge of supervising the same or to the Management.

VII. EMPLOYEE HEALTH AND SAFETY

Article 43.- Consumption of narcotic and psychotropic substances

The consumption of any narcotic or psychotropic substance during working hours or going to work under the influence of the consumption of this type of substance is prohibited.

For the purposes of these Regulations, alcohol, cannabis, methamphetamine, cocaine, opiates, and any other similar substance that alters the physical and mental conditions of the Employee will be considered narcotic or psychotropic substances.

The Company may carry out the appropriate analyzes on a regular basis to detect the consumption of this type of substance.

The consumption of this type of substance may be considered a serious offense, following in any case the provisions of the applicable collective agreement, and may lead to disciplinary dismissal of the employee in the event that the habitual consumption of this type of substance affects the development of your activity.

Article 44.- Security measures

Given the importance of safety and protection measures for the physical and mental integrity of the Employees, and in compliance with the provisions of Law 31/1995 on the Prevention of Occupational Risks and the other applicable legislation on this matter, the Employees are obliged to use all means of protection and act in accordance with the safety instructions provided by the Company throughout their working day.

Failure to comply with these measures will lead to the initiation of a disciplinary procedure in accordance with the provisions of the corresponding section of these Regulations.

Article 45.- Control of medical leave

Employees who are in a situation of medical leave due to illness must request the corresponding sick leave report from their corresponding doctor. This cancellation part will be sent to the Company's address in the shortest possible time.

The sick leave must include the medical condition of the Employee as well as the possible estimated duration of the Employee's recovery.

On the other hand, in cases of occupational accidents, Employees must go to their corresponding insurance company so that their clinical situation can be correctly evaluated.

Article 46.- Emergency plans

In order to guarantee the greatest safety for Employees in potential emergency situations, the Company undertakes to establish action and evacuation plans depending on the situation, in cooperation with the emergency services in the area where the emergency centers are located. worked.

These plans, and their subsequent modifications, will be duly communicated and instructed through the preparation of courses or training sessions for the Employees, who in turn will have the obligation to know them and to act in accordance with them in emergency situations.

Likewise, the Company may establish, when it deems it appropriate, possible drills to guarantee the correct implementation of the emergency plan in the Company.

VII. ACTIVITY CONTROL

Article 47.- Video surveillance

Following the current regulation established in the LOPDPGDD, the Company will expressly, clearly and concisely inform the Employees, and their legal representatives, about the existence of surveillance video cameras in the work centers or in the Company's vehicles.

In any case, this duty of prior information will not be necessary when an Employee is recorded committing an illegal act and the recording device is in a sufficiently visible place with a sign informing about the right of the Employee to be able to exercise their access rights, rectification, deletion and limitation of the information filmed.

The video surveillance devices will only be used for security measures and verification of the correct performance of the work and they will be located in the places where the service is provided, avoiding locations that may violate the privacy of the Employees, such as, by way of example, changing rooms, rest rooms, kitchens, among others.

Finally, sound recording devices may be installed provided that given the circumstances of the activity, or of the facilities where the activity is provided, it is necessary to establish these devices in order to control the activity of the Employees. In any case, as has been mentioned in reference to video cameras, the installation of this type of device must be duly notified to the Employees, as well as to their corresponding representatives.

Article 48.- Geolocation systems

The Company may use, if it deems it appropriate, geolocation systems in its vehicles or mobile devices for the sole purpose of ensuring and verifying the correct performance of the work activity by the Employees.

In any case, the Company will duly inform the Employees in advance, expressly, clearly and concisely, about the installation of these geolocation devices and their operation.

Article 49.- Control of compliance with security measures

The Company may establish the necessary measures to be able to verify and guarantee the correct compliance with the security measures established by the Company. These surveillance and control tasks will be carried out in order to guarantee the integrity and safety of the Employees.

In the case of establishing video surveillance or geolocation systems, what is established on these points in this Section must be followed.

Article 50.- Report of breaches of security measures

In the event that any Employee detects a failure or non-compliance with the necessary security measures established in these Regulations, as well as in the legislation on protection of occupational risks or the provisions of the applicable collective agreement in his case, he will have the right and the duty to notify said situation to their Manager(s) or the Directorate diligently following the provisions of the corresponding Section on internal communication.

IX. REMUNERATION POLICY

Article 51.- Remuneration

The setting of the amount corresponding to the remuneration of the Employees will be carried out in a fair and equitable manner, taking into account the position and level of each Employee, their responsibilities and training, their functions and the characteristics of the position, avoiding any type of discrimination, whether based on gender, race, religion, disability, marital status, age, ideology, pregnancy status, identity or place of residence, or based on any other similar factor or trait.

In any case, the Company undertakes to comply with the provisions on the remuneration of Employees in labor legislation, and above all, in the applicable collective agreement.

Article 52.- Payment of wages

The payment of salaries to Employees will be carried out as follows:

________

In the event that the payment day is a weekend or a national, regional or local holiday, the payment will be made on the immediately following business day.

Article 53.- Salary increases

Employees may receive, periodically or not, increases in their base salaries, supplements or incentives at the free decision of the Company. In any case, the realization of a punctual salary increase will not imply that it must be repeated periodically.

Finally, the Company will respect the salary increases agreed in the collective agreement applicable to it.

Article 54.- Allowances and travel expenses

The Company will establish compensation for the displacement of Employees outside their usual work center in accordance with the provisions of the legislation and the applicable collective agreement. These expenses will include the costs of maintenance, stay and transport necessary to carry out the activity.

Article 55.- Bonuses or economic incentives

Regardless of the supplements and extraordinary payments that correspond to the Employees according to their employment contract, as well as their current labor legislation and the applicable collective agreement, it is desired to establish the following bonus or incentive policy:

A bonus will be paid at the end of the month for each of the projects carried out by each of the employees, which will be 10%, not exceeding €50 per project.

Article 56.- Other salary supplements

Employees will receive salary supplements in accordance with the provisions of current legislation, and where appropriate, according to the provisions of the collective agreement applicable to the company.

Article 57.- Payroll request

Employees may access their corresponding payroll in the following manner:

Pay slips are sent monthly by mail from each of them, and if you have any questions you can go to our Human Resources department.

X. WORKING DAY

Article 58.- The working day

Employees will provide their services within the following hours:

Customer service will be from 9:00 am to 18:00 pm, always respecting meal times.

Article 59.- Work calendar

The Company will establish the working calendar of the Employees in accordance with their power to direct the activity contained in article 20 of the Workers' Statute, and in compliance with the legislation, and where appropriate, the applicable collective agreement.

Article 60.- Meal and rest times

In order to guarantee the cleanliness of the workplace and avoid possible distractions or accidents, food intake is prohibited during working hours, unless it is necessary for the Employee for health reasons.

Meals will be taken during the corresponding rest hours that will be established in the employment contract of each Employee.

Article 61.- Advantages in relation to lunch and/or dinner

The Company will enable an adequate area for meals and rest for employees, specifically with the following characteristics:

Article 62.- Punctuality of Employees

Employees may provide their services with flexible hours, only having to respect the following particularities:

Employees must carry out an 8-hour day of work, which can be done from home if they wish.

Article 63.- Extra and/or complementary hours

Unless otherwise agreed in the employment contract, Employees may work overtime or complementary hours according to the needs of the Company, respecting in all cases the requirements and limits established in current legislation, and the applicable collective agreement.

Employees will be paid for all overtime or complementary hours they perform in accordance with the provisions of current legislation, and in the applicable collective agreement, where applicable.

Article 64.- Registration of the working day

The Company undertakes to comply with the current regulation on the control of the working day, making the corresponding time control sheet available to the Employees.

Employees must complete these workday control sheets, truthfully indicating the start and end times of their workday, as well as the corresponding breaks.

Article 65.- Geographical and functional mobility of Employees

Employees must have the necessary flexibility to perform their work outside the workplace in situations where it may be necessary for the Company.

On the other hand, some of the functions or tasks of the Employees may be modified or altered in cases where it is necessary due to operational, procedural or organizational aspects of the Company. In any case, it will be your hierarchical superior or Manager who will justify this punctual change of functions, respecting labor legislation, and if applicable, the provisions of the applicable collective agreement.

XI. HOLIDAYS AND CONCILIATION OF PROFESSIONAL AND FAMILY LIFE

Article 66.- Period of vacation enjoyment

The enjoyment of vacations must be carried out in compliance with current labor legislation and the applicable collective agreement.

Failure to comply with the above instructions may imply that the enjoyment of the vacations is not fully adapted to the dates interested by the Employee.

Article 67.- Distance work and telework

In order to facilitate the reconciliation of the work and family life of the Employees, the Company will promote, whenever it is technologically and economically possible, and the Employees so wish voluntarily, the performance of their work through telematic means.

On the other hand, following the provisions of article 38.8 of the Workers' Statute, Employees may request, as part of their right to reconcile work and family life, the provision of all or part of their services electronically. . In these cases, the Company will attend to the request and will try to facilitate as much as possible the provision of these services telematically within its possibilities and as permitted by its activity.

Employees subject to this type of work will provide their services with the same rights and obligations as other Employees. In addition, they will be provided with the necessary training so that they can provide their services through the appropriately facilitated telematic means.

The Company may maintain control over the activity carried out by the Employees as long as the requirements mentioned in the previous articles are observed and the privacy of the Employees is respected.

Finally, the Company undertakes to promote the right to digital disconnection of Employees in order to guarantee the reconciliation of their work and family life. In this way, the Employees must only be connected and active during their working day to the telematic means provided. Employees may not be forced to remain connected outside said hours or once the objectives set by the Company have been achieved.

Article 68.- Maternity leave and nursing leave

One of the inspiring principles of the Company's relationship with its Employees is to facilitate and promote the compatibility of the Employees' professional life and family life. In this way, the Company undertakes to comply with the provisions of the Workers' Statute and other applicable regulations or collective agreement in order to facilitate the corresponding periods of sick leave necessary for the Employees and the enjoyment of the nursing permits that are thus established. request.

Article 69.- Requests for leave of absence

The Company will attend to all requests for leave (whether they are voluntary leaves of absence, for family care, etc.) that are sent to it by the Employees, resolving in accordance with the provisions of the applicable legislation, as well as the provisions of the collective agreement in your case.

In the event that the Management denies a leave of absence at a certain time, provided that the applicable legislation or collective agreement allows it, said denial will be duly justified based on objective reasons by the Company.

Article 70.- Adaptation of the working day

The Company undertakes to negotiate with the Employees who so request possible changes or adaptations to their working hours based on their personal needs. The request for this change would imply reducing your working hours within the possibilities of the Company.

The Company will respond in writing to the Employee's request, justifying the possible acceptance or rejection of the Employee's request, and, if applicable, propose an alternative change to the one requested by the Employee based on a series of objective reasons for the activity or of organization of the Company.

XII. INTERNAL AND EXTERNAL COMMUNICATION

Article 71.- Communication of situations of discrimination and harassment

As mentioned above, Employees have the right and, in turn, the duty to report any type of discrimination or harassment situation against themselves, against any colleague or against any superior or dependent personnel, which they may know or witness. No Employee shall be exempt from this obligation.

In any case, the existence of this channel does not prevent the communication of these situations through any other type of means previously established or habitual for the representatives of the Employees.

Given the importance for the Company of preventing all these possible situations of harassment and discrimination, they will be communicated immediately. The Directorate undertakes to initiate the corresponding internal investigation in order to establish the facts and apply the corresponding sanction in its case.

In any case, if the Employee or Employees who report a situation of discrimination or harassment consider that the Company has not acted completely diligently, they may take the legal actions they deem appropriate in order to eliminate this situation and prevent it from becoming to reproduce in the future.

Article 72.- Communication of other breaches of the Regulation

Likewise, the Employees have the right, and in turn, the duty to report any possible breach of the provisions of this Regulation that they become aware of.

In any case, the existence of this channel does not prevent the communication of these situations through any other type of means previously established or habitual for the representatives of the Employees.

The communication will be made as soon as the situation of non-compliance is known and it will not prevent the Employee from adopting the judicial measures or communication to the representatives of the Employees that he deems necessary.

Article 73.- Communication of any other circumstance

In the event that Employees wish to communicate any aspect related to their work or any personal circumstance (such as the impossibility of going to their position due to illness, the request for a personal day, etc.) that may affect their activity, they may go directly to your immediate superior or Manager(s) in writing.

Article 74.- Participation in conferences and congresses

In respect of the right to personal and family privacy, Employees may participate in those conferences and congresses to which they are invited as speakers without the need to obtain prior authorization from the Company.

In any case, the Speaker Employee must respect their obligations in reference to the disclosure of confidential information of the Company and data protection contained in these Regulations as well as in their corresponding employment contract.

Article 75.- Communication policy

The Company wishes to guarantee the establishment of an effective external communication policy that guarantees and protects the integrity of its image and reputation. .

External communication shall be understood as any information addressed to the media, clients or social networks of the Company, including all promotional and advertising campaigns.

Any contact received by any Employee from any journalist or media outlet to deal with matters directly related to the Company and its activity must be forwarded to this body immediately.

Article 76.- Use of social networks

The Company is part of various platforms in order to maintain effective communication with its customers, and to effectively communicate and promote the activity that is carried out. For information purposes, the Company has the following social profiles:

Millennials Consulting Spain Linkedin

Millennials Consulting Facebook

@millennials.consulting Instagram

In any case, along with these profiles, new corporate profiles may be created in the future (hereinafter, the "Platforms").

In this way, the Employees undertake to respect the prestige and image of the Company on these Platforms, committing to make appropriate use of the Company's social networks, and not to defame, insult or pour confidential information through profiles of Employees on said platforms.

Regarding the corporate profiles of the Company, the Employees undertake to interact with other users and clients in a cordial, polite and professional manner, without falling into insult or disqualification at any time, and providing adequate information to the customer needs. In any case, the guidelines of the people in charge of managing these profiles will be followed.

On the other hand, the confidentiality of the data that the clients may share with the Employees through these Platforms will be respected at all times, in accordance with the provisions of these Regulations, in their employment contract, in the possible confidentiality agreements signed , and in current data protection legislation.

In addition, the use of the Platforms for the publication of any type of dishonest or offensive video with Employees or with third parties is prohibited, giving rise to the corresponding sanctions where appropriate.

Finally, Employees may have personal profiles on social networks without the need to obtain prior authorization from the Company. In any case, the Employees must comply with all the protection regulations of the confidentiality and data protection regulations of all the information that is revealed in relation to the Company.

XIII. COMPLIANCE WITH THE REGULATION AND DISCIPLINARY REGIME

Article 77.- Supervisory body

In order to guarantee that the measures included in these Regulations will be duly followed and applied by all the Employees as well as by the Management, it is agreed that their control will be carried out by: Jesús Garcia Gil (hereinafter, the “Supervisor »).

The functions of the Supervisor will be limited to the control and management of the correct functioning of the Regulations, as well as to receiving suggestions from the Employees regarding possible incidents or aspects that must be regulated in the same, to the preparation of periodic reports on the application of the Regulation or to the preparation of proposals or recommendations for modification or expansion of the content of the Regulation. In any case, the decision on its modification or inclusion of new aspects in the Regulation will correspond solely to the Management.

Finally, this body may act at the request of any Employee who suffers or detects a breach of any of the rights or rules contained in these Regulations, as well as on their own initiative in the event that they deem it necessary.

Article 78.- Sanctions for non-compliance with the Regulations

Failure to comply with the obligations contained in this Regulation will give rise to the establishment of a sanction that will depend on the seriousness of the breach and its possible consequences.

The seriousness of the non-compliance will be evaluated by the Supervisor and/or the Management, truthfully describing the facts, the evidence that justifies the facts, the unfulfilled precepts of the Regulations and the possible consequences thereof.

In any case, this possible sanction will be adjusted to the provisions of this Regulation, and above all, to the provisions of the Workers' Statute, and where appropriate, to the provisions of the applicable collective agreement.

Article 79.- Content of the complaints of non-compliance

Any complaint sent to the Supervisor for study must contain the following information:

• name of the person or persons filing the complaint;

• Description of the facts or possible situation that gives rise to a breach of the Regulations; Y,

• data of the possible non-compliant person.

The presentation of any complaint without the aforementioned information will not be valid and will be sent again to the complainant so that within a maximum period of 15 calendar days he can resubmit the complaint, complying with all the previous requirements.

Article 80.- Penalty procedure

The sanctions for non-compliance with any of the aspects set forth in these Regulations will be established by the Supervisor or the Directorate following their operating rules set forth in the previous Section.

The Supervisor or the Directorate will conduct the corresponding investigation of the reported facts, so that the necessary testimonies and evidence can be collected. After data collection, the Supervisor will hear the parties and finally, with all the information collected and the testimonies, the Supervisor will adopt the decision in accordance with the provisions of the previous Section.

In any case, this procedure will guarantee the participation of the potential defaulter and the possible decision adopted must be duly substantiated and proven, following in any case the provisions of the legislation and the applicable collective agreement in your case.

OUR TEAM

OUR TEAM

jesus garcia team

Jesus

García

Manager

bernar team

bernar

García

Business consultant

Commercial Department

alexander trujillo team

Alejandro

Ttrujillo

Consultant, Implementer

HR Department

michael team

Michael B.

Anton

ERP specialist

ERP Dept.

irene team

Irene

Bernardini

ERP specialist

ERP Dept.

jessica team

Jessica

Assaf

Consultant, Implementer Marketing Specialist

Marketing Department

damian team

Damian

Melendrez

Consultant, ADS Specialist Implementer

Marketing Department

eliana team

Eliana

Pérez

Consultant, Implanter Specialist in Design

Marketing Department

estiven team

Stow

Gallant

Video Specialist

Marketing Department

venus arias team

Venus

Arias

Design Specialist

Marketing Department

dartboard team

Diana

Hernández

Consultant, Implementer

Operations Department

esther team

Esther

Martínez

Consultant, Implementer

Analytical Department

tony team

Tony

Owen

Consultant, Implementer

Operations Department

jose team

José

In this

Consultant, Implementer

Operations Department

marten team

Marta

Mateo

Consultant, Implementer

Operations Department

julian team

JULIAN

Sanchez

SEO Analytics Specialist Manager

Dept. SEO

alexander sanchez team

Alejandro

Sanchez

SEO                    On Page Specialist

Dept. SEO

ivan team

Ivan

Simon

SEO                    Off-page specialist

Dept. SEO

alvaro team

Álvaro

Poveda

SEO                    Content Specialist

Dept. SEO

jesus cazorla team

Jesus

Cazorla

Consultant, Developer 

IT Department

frank team

Fran

More

Consultant, Developer 

IT Department

sheila team

Sheila

Shopkeeper

Commercial Consultant

Commercial Department

team valentine

Valentina

Medina

Commercial Consultant

Commercial Department

gaspar photo team

Gaspar

Gilabert

Business consultant

Commercial Department

anna team

ANA

Vallejo

Consultant, implanter

diego garber team

Diego

Thomas

Developer

jorge fernandez team

George

Fernandez

Developer

jesus garber team

Jesus

García

Developer

team ignatius

Ignacio

Del Val

Developer

julian vicente team

Julian. v

Fernandez

Developer

Vincent Ares

Vicente

Ares

Specialist in legal requirements and subsidies

dawn mastic

Alba

Martinez

Grant Specialist

xavi agut

Xavi

Agut

Web Consultant

ferdinand photo team

Fernando 

Lopez

legal specialist

mariana photo team

Mariana

Hernandez

PR

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