Code of Ethics

Company details

Company name

POLITEIA SOFT, S.L.U.

Tax ID (CIF)

B21966023

Registered office

Urb. Parque Jacaranda 18, 11405 Jerez de la Frontera (Cádiz)

Governing body

Sole Director: Beatriz Campos Bereginal

Contact

info@politeiasoft.com

1. Purpose and scope

The code is binding on the Sole Director, on all Politeia Soft employees, whatever their type of contract, and on anyone acting on its behalf. Politeia Soft will ask its collaborators, subcontractors and suppliers to act, insofar as it concerns them, in accordance with these same principles when providing services related to the company’s contracts.

The code supplements, and in no case replaces, the applicable legislation, the tender specifications and contracts entered into with clients, and the obligations arising from the collective agreement. In case of doubt, the option that is most respectful of the law and of people’s rights always prevails.

2. Integrity and regulatory compliance

Politeia Soft complies with the legislation in force and, when contracting with the public sector, with the Spanish Public Sector Contracts Act (Ley 9/2017, de 8 de noviembre, de Contratos del Sector Público, LCSP), the specifications of each tender and the principles of equal treatment, transparency, free competition and non-discrimination.

• Anti-corruption: we do not offer, promise or give, directly or through third parties, payments, advantages or favours to authorities, public employees or people at private companies in order to obtain or retain a contract or a favourable decision, nor do we accept them. We reject bribery, influence peddling and any form of corruption in business.
• Conflicts of interest: anyone with a personal, family or financial interest that could influence, or appear to influence, a company decision or a procurement procedure must report it immediately and refrain from taking part. We cooperate with contracting authorities in preventing, detecting and resolving conflicts of interest, in accordance with Article 64 of the LCSP.
• Gifts and invitations: gifts, invitations or hospitality are neither offered nor accepted unless they are courtesies of symbolic value, occasional and transparent. Nothing is ever offered to people involved in a procurement procedure in which Politeia Soft is taking part or in the performance of a contract with it.
• Truthfulness: the responsible declarations, bids, certificates, invoices and other documents we submit are truthful, complete and supported by the corresponding documentation.
• Exclusion from contracting: Politeia Soft takes care not to fall within any of the grounds for exclusion from contracting set out in Article 71 of the LCSP and to be up to date with its tax and Social Security obligations.

3. Relations with clients and public authorities

• We state clearly what our software does and does not do, its limitations and the terms of the service, without making promises we cannot keep.
• We perform contracts as agreed, in accordance with the tender specifications and the special performance conditions, and we report without delay any issue that may affect the service.
• We only subcontract on the terms permitted by the contract and by the LCSP, and we pass on to subcontractors the confidentiality, data protection and security obligations incumbent upon us.
• We cooperate with contracting authorities, with contract managers and with oversight bodies, and we provide the information they request in compliance with transparency legislation.
• We treat all clients impartially and with respect, without placing private interests above the interest of the contracted service.

4. Data protection and confidentiality

• We process personal data in accordance with the GDPR (Regulation (EU) 2016/679) and the Spanish Organic Law on the Protection of Personal Data and Guarantee of Digital Rights (Ley Orgánica 3/2018), applying the principles of lawfulness, data minimisation, purpose and storage limitation, accuracy, integrity and confidentiality.
• When we act as processors, we process data only on the documented instructions of the controller, we do not use it for our own purposes and we return or delete it when the service ends, in accordance with Article 28 of the GDPR and the data processing agreement.
• All information on clients, public authorities and third parties to which we have access is confidential: it is known only to the people who need it for their work and is neither disclosed nor used for other purposes. This duty continues after the employment or contractual relationship has ended.
• We respect the rights of data subjects and cooperate with the controller in responding to them.

5. Information security

Politeia Soft holds certification of conformity with the National Security Framework (Esquema Nacional de Seguridad, ENS, Royal Decree 311/2022) at MEDIUM category, number ENS-2026/0141. Maintaining that conformity is the responsibility of the whole organisation.

• Each person accesses only the information and systems they need for their role and protects their credentials and devices.
• The company’s security policies and procedures are followed, and any security incident or personal data breach, or suspicion of one, is reported immediately so that it can be managed and notified within the legal time limits.
• Security is taken into account by design in software development and in the choice of suppliers and infrastructure.

6. Responsible use of artificial intelligence

Our products use artificial intelligence techniques. We undertake to use them lawfully, transparently and under supervision, in accordance with the AI Act (Regulation (EU) 2024/1689) and data protection legislation.

• We explain to our clients what artificial intelligence does in our products, its limits and the need for a person to review the results before using or publishing them.
• We do not use clients’ documents or data for purposes other than providing the contracted service.
• We assess the quality of the results and correct any errors and biases we detect.
• Politeia Soft staff do not enter confidential information or clients’ personal data into third-party artificial intelligence tools that have not been authorised by the company for that use.

7. Fair competition

• We compete solely on the quality of our products and services, in compliance with the Spanish Competition Act (Ley 15/2007, de Defensa de la Competencia) and the Spanish Unfair Competition Act (Ley 3/1991, de Competencia Desleal).
• We do not enter into agreements or exchange information with other bidders to fix bids, share out contracts or otherwise alter the outcome of a tender.
• We do not spread false or misleading information about competitors, and we respect intellectual and industrial property rights and the licences of third-party software.

8. Working conditions, equality and non-discrimination

• We apply the Spanish national collective agreement for consultancy, information technology and market and public opinion research companies, as well as employment and Social Security legislation.
• We guarantee equal treatment and opportunities for women and men, in accordance with the Spanish Organic Law on Effective Equality of Women and Men (Ley Orgánica 3/2007), and we do not tolerate any discrimination on grounds of sex, origin, age, disability, sexual orientation or identity, religion, ideology or any other personal or social circumstance.
• We do not tolerate workplace harassment, sexual harassment or harassment on grounds of sex, and we protect anyone who reports it.
• We comply with occupational health and safety legislation, we support the balance between personal, family and working life, and we respect the right to digital disconnection.
• We pay our employees and, where there are any, our subcontractors and suppliers on time, in accordance with late payment legislation and the LCSP.

9. Environment

• We seek to reduce the environmental impact of our activity: efficient use of cloud infrastructure and energy, extending the useful life of equipment and proper management of electronic waste.
• We give preference to remote working and remote meetings where they avoid unnecessary travel, and to electronic documents over paper.
• We take environmental criteria into account when choosing suppliers where the alternatives are equivalent.

10. Breaches

A breach of this code by employees may give rise to the disciplinary measures provided for in the collective agreement and in employment legislation and, in the case of collaborators and suppliers, to the appropriate contractual measures, without prejudice to any legal liability that may arise.

11. Channel for reporting breaches

Anyone, whether from within the company or a client, supplier or public employee, may raise questions about this code or report possible breaches of it or of the law by writing to info@politeiasoft.com, stating “Code of Ethics” in the subject line. Anonymous reports are accepted.

• Reports are received and handled by the Sole Director. If a report concerns her, the reporting person may contact the competent authorities indicated below directly.
• Receipt will be acknowledged within a maximum of seven calendar days and a response will be given within a maximum of three months.
• The confidentiality of the identity of the reporting person, of the persons concerned and of the facts is guaranteed, as is the processing of their data in accordance with data protection legislation.
• Anyone may also contact the competent authorities, including the Independent Whistleblower Protection Authority (Autoridad Independiente de Protección del Informante), under the terms of the Spanish Whistleblower Protection Act (Ley 2/2023, de 20 de febrero).

Prohibition of retaliation

Politeia Soft prohibits any form of retaliation, including threats and attempted retaliation, against anyone who in good faith raises a question or reports a possible breach, or who assists in investigating it. Retaliation in itself constitutes a serious breach of this code.

12. Approval, entry into force and review

Version

1.0

Approved by

Beatriz Campos Bereginal, Sole Director of POLITEIA SOFT, S.L.U.

Date of approval

20 October 2026

Entry into force

Upon approval

The code will be reviewed at least once a year and whenever regulatory or organisational changes, or changes in the company’s activity, make it necessary. Each new version will be approved by the governing body, communicated to everyone bound by it and published on this page.