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Code of Conduct

Index

Foreword

1. Scope of validity

2. General requirements of conduct

a) Responsibility regarding the reputation of Wiseplay

b) Responsibility regarding social principles and rights

c) Equality of opportunity and mutual respect

3. Integrity

4. Responsible relationships with third parties to the clients

a) Customers

b) Suppliers

c) Transparency

5. Treatment of information

a) Data protection

b) Intellectual and industrial property

c) Security of computer systems

6. Occupational and health protection

7. Protection of the environment

8. Treatment of the Code of Conduct

a) Validity of the Code

b) Compliance responsibility

c) Disciplinary measures

 

Foreword

Dear partners:

The trust of customers and stakeholders in Wiseplay and its services is our most precious asset. For this reason, we have a common responsibility to reinforce this trust on a daily basis with honest and honest conduct.

This includes that all of us know the internal regulations as well as the applicable legislation.

The Wiseplay Code of Conduct serves as a guide to encourage appropriate behaviors by providing guidance and support in our daily work.

With this initiative we jointly take another decisive step to assume our responsibility as a company before society.

If we know that something is not going well, if we make an error or we detect that mistakes are made elsewhere, we must address them and react appropriately, even if it is not comfortable and pleasant. Looking the other way can never be the right solution.

In case of doubt we should seek advice and request adequate help.

From Wiseplay we are convinced that our Code of Conduct is a fundamental key to further increase the success of the application in a lasting manner.

Therefore, we ask you to read this document carefully. And we encourage you to join us to work together so that Wiseplay is not only synonymous with excellence in its services, but also integrity and honesty.

We are committed to a respectable, honest performance that complies with the rules and we are committed to this Code of Conduct.

Eduardo Olmeda Zafrilla

CEO

1. Scope of validity

The Code of Conduct is valid for all employees and members of Wiseplay.

2. General requirements of conduct

a) Responsibility regarding the reputation of Wiseplay

The image of Wiseplay depends to a large extent on the image, performance and behavior of each employee. Inappropriate behavior, even from a single employee, can seriously harm the application.

Each employee must ensure that their behavior does not harm the reputation of Wiseplay. This principle must be taken into account in all matters related to the fulfillment of tasks.

b) Responsibility regarding social principles and rights

We respect internationally recognized human rights and support their compliance.

We act in accordance with the standards of the International Labor Organization. We recognize the basic right of all employees to form unions and worker representations. We reject the intentional use of forced and forced labor. Child labor is prohibited. We respect the minimum working age established by the regulations of each country.

The remuneration and benefits paid correspond, as a minimum, to what is established by national legal regulations or by the respective economic sectors.

c) Equality of opportunity and mutual respect

We guarantee equal opportunities and equal treatment, regardless of ethnic origin, skin color, sex, handicap, ideology, religion, nationality, sexual orientation, social origin or political tendency, since it is based on democratic principles and tolerance towards those who think differently.

Employees are selected, hired and promoted, basically, based on their qualifications and capabilities.

All Wiseplay members are obliged to avoid any type of discrimination (for example, through prejudice, harassment, mobbing) and to facilitate respectful and collaborative treatment.

3. Integrity

The members of Wiseplay will adjust their behavior to the criteria of professionalism and integrity:

  • Professionalism is a diligent, responsible, efficient act and it is focused on excellence, quality and innovation.
  • Integrity is a fair, honest, in good faith act, objective and aligned with the interests of the company and society in general.
  • Self-control in actions and decision making, so that any action taken takes into account four basic premises: that is an ethically acceptable performance, that is legally valid, that is desirable for society and for the company and, finally, that the professional is willing to assume the responsibility that comes with it.

4. Responsible relationships with third parties

a) Suppliers and customers

Wiseplay will adapt the contracting processes of suppliers and clients to the principles of equal treatment and transparency, and will avoid any discriminatory treatment between bidders or candidates.

Wiseplay will not disclose the information that its suppliers or clients have declared confidential; this character affects, in particular, technical or commercial secrets.

Wiseplay professionals who access personal data of suppliers and customers must maintain the confidentiality of the data and comply with what is established by the legislation on the protection of personal data.

b) Transparency

Relations with authorities, regulatory bodies and public administrations will be established in accordance with the principles of cooperation and transparency, strictly complying with the provisions of Laws 19/2013 and 19/2014 on Transparency, Access to Public Information and Good government.

The economic and financial information of Wiseplay, especially the annual accounts, faithfully reflects the economic, financial and patrimonial reality in accordance with the principles and criteria established in the General Accounting Plan and with the applicable financial information standards. For these purposes, no professional will hide or distort the information of the accounting records and reports, which must be complete, accurate and truthful.

5. Treatment of information

a) Data protection

There are special legal rules that protect privacy in the field of the use of personal data. As a general rule, to collect, save, process and make any other use of personal data you need the authorization of the affected person, a contractual agreement or any other legal instrument.

Wiseplay protects the personal data of its professionals, former employees, customers, suppliers and affected third parties.

Wiseplay collects, uses, processes and saves personal data always in accordance with legal stipulations.

Wiseplay professionals must ensure that the collection, storage, processing or any other use of personal data is done with the authorization of the person affected, under a contractual agreement or any other legal instrument.

All aspects related to the processing of information must be ensured in such a way that the confidentiality, integrity, availability, verifiability and reliability of the information that requires protection is guaranteed and that an unauthorized internal or external use is avoided.

b) Intellectual and industrial property

Our Intellectual Property Policy explains how we preserve the rights of third parties in this field.

We respond to notifications of alleged infractions of copyright and cancel the accounts of users who commit repeated infractions in accordance with the process established in our Policy.

In addition, Wiseplay has installed a complaints channel (info@wiseplay.tv) available to all users of the App who want to make any kind of observation regarding possible breaches of intellectual or industrial property rights.

c) Security of computer systems

Information technology (IT “Information Technology”) and electronic data processing (EDP) systems have become an integral part of Wiseplay’s daily life. At the same time, they involve numerous risks, among which the most important ones are damage to data processing systems through malicious programs (viruses), loss of data due to program failures or fraudulent use of data (for example due to “Hackers”).

Wiseplay respects computer security (IT) and electronic data processing systems (EDP) and complies with current regulations.

6. Occupational and health protection

We assume our responsibility for the safety and health of employees. We guarantee labor and health protection within the framework of the national provisions in force, as well as based on the policy of labor protection and health of the members of Wiseplay. Through continuous improvements in the workplace and different preventive measures and health protection, we maintain and promote health, productivity and job satisfaction of workers.

All professionals must contribute to take care of their health and must comply with the requirements of labor protection and health.

7. Protection of the environment

Wiseplay is committed to developing its activities in a manner that minimizes negative environmental impacts and assumes the commitment to efficiently use energy in its facilities and activities with the purpose of preserving natural resources, reducing atmospheric emissions and contributing to mitigate the effects of climate change.

At Wiseplay we are aware of the importance of valuing the environment; Therefore, we feel responsible for the environmental impact of our activities and we try to maintain the global ecological balance in order to go beyond our legal obligations. We work to incorporate best management practices and make good use of available resources.

8. Treatment of the Code of Conduct

a) Validity of the Code

The present Code, and any modifications or updates to it, will come into effect thirty days after its approval by the Administration Body.

b) Compliance responsibility

All professionals must comply with the laws, prescriptions and mandatory internal regulations in their work environment, and must guide their actions according to the values ​​of Wiseplay and the Code of Conduct.

c) Disciplinary measures

Failure to comply with the Code of Conduct and the applicable regulations that create a criminal risk may result in the disciplinary sanctions established in the Collective Bargaining Agreement that links Wiseplay and its professionals.

All of the foregoing, without prejudice to administrative or judicial sanctions (including, where appropriate, criminal penalties) that may result from the actions under investigation.