SOCIAL RESPONSABILITY POLICY

The Management of WOTTOLINE is committed to compliance with the requirements established in international standard SA 8000: 2014 as well as the principles of the global agreement while continuously improving our Social Responsibility Management System through the following values and principles:

1. Compliance with current national and international labour legislation applicable for corresponding activities in each workplace, requirements and voluntary observance of international agreements as regards International Labour Organisation, Universal Declaration of Human Rights and other applicable international requirements.

2. Ensured protection of Human Rights in all activities carried out and along the supply chain.

3. Assurance of no child, forced or compulsory labour.

4. Promotion of diversity and gender equality, equal opportunities in the organisation, establishment of mechanisms to ensure non-discrimination in any form; gender, religion, ethnicity, social origin, participation in labour activities, marital status, disability, among others.

5. Treatment of all employees with dignity and respect through proper management and progressive disciplinary policies with express renunciation of physical or mental abuse.

6. Guarantee of health and safety for internal and subcontracted personnel through continuous monitoring and training procedures.

7. Respect for freedom of association and the right to collective bargaining and promotion of continuous social dialogue with stakeholders, particularly employees.

8. Proper remuneration for personnel and establishment of work schedules that, while in observance of at least current legislation, foster reconciliation of work and personal life.

9. Promotion of a preventive culture in the organisation and assurance that all operations are always carried out in a safe manner, through proper planning of activities and provision of necessary resources.

10. Development of suitable training plans aimed at the development of the skills for internal and subcontracted personnel.

11. Establishment of communication channels with personnel, employee representatives and stakeholders as a means of continuous improvement and prevention of occupational risks and health and safety in the workplace.

Social Responsibility and health and safety in the workplace is a commitment and responsibility of all WOTTOLINE personnel who actively participate in the maintenance and continuous improvement of our Social Responsibility Management System.

Management is committed to providing the organisation with the necessary human and material resources to continuously improve the performance of our Social Responsibility Management System. This Social Responsibility policy is reviewed annually to ensure effectiveness and adaptation to the context of the organisation and its strategic management. The program is now available to relevant stakeholders.

WOTTOLINE management,
1 June 2018

SOCIAL RESPONSIBILITY CODE

1. Social Responsibility Management System

This Social Responsibility Policy, which is inspired by international standard SA 8000 as well as the principles of the Global Agreement, is intended to reflect the corporate values ​​and basic principles that must guide the actions of WOTTOLINE and company personnel.

The Management of WOTTOLINE is committed to compliance with the requirements established in international standard SA 8000 as well as the principles of the global agreement while continuously improving our Social Responsibility Management System.

As part of the management of the organisation, Wottoline is committed to social responsibility through implementation of the requirements established in Standard SA 8000.
The system is based on compliance with legal regulations, accords, contractual agreements and other requirements subscribed by the organisation, while observing international instruments and corresponding interpretation.

The corporate management system is structured around the Social Responsibility Policy , with mandatory compliance for all personnel, regardless of position and/or level.

1.1. Purpose.
The purpose of this social responsibility policy is to establish the guidelines to be followed by WOTTOLINE personnel and companies carrying out work for or on its behalf, in order to perform activities under the criteria of social responsibility.

1.2. Scope of application.
The social responsibility policy is applicable to all WOTTOLINE members, regardless of hierarchical level, geographical or functional location and existing contractual position.

1.3. Compliance.
Personnel included within the scope of application (employees and suppliers) are obliged to understand the social responsibility policy, accept the content in its entirety and act under the principles contained therein.
There is a clear commitment from Management to provide all necessary resources to facilitate compliance.
WOTTOLINE undertakes the commitment to establish and disseminate to all personnel of the organisation said social responsibility policy, which shall be published on the corporate website www.wottoline.com.

2. Corporate Values

WOTTOLINE Management undertakes the commitment to comply with the following corporate values:

> Customer orientation
> Management based on professional criteria
> Ethical business behaviour
> Social and environmental responsibility
> Promotion of personal development
> Respect for persons

3. Social Responsibility Code

3.1. Corporate and company image.
WWOTTOLINE considers that its most important assets include its corporate image and its corporate reputation.

> All personnel must ensure that their actions damage neither the image and reputation of WOTTOLINE nor any of its customers.
> All personnel must place the interests of the company, customer and stakeholders above those their own, in any action undertaken on behalf of WOTTOLINE.
> No personnel may use the WOTTOLINE name and/or brand for uses other than those permitted by the company.
> No personnel shall provide false or misleading information to interested parties.

3.2. Respect for persons.
WOTTOLINE believes that respect for others must be a basic element of employee conduct and social responsibility of the company.

> All employees have the obligation and responsibility to treat their colleagues, superiors and subordinates respectfully, and must contribute to maintaining a harassment-free work environment.

3.3. Child, forced or compulsory labour.
WOTTOLINE does not directly or indirectly employ child labour or personnel who perform compulsory labour.
WOTTOLINE is committed, through its Social Responsibility Policy, so that children are not used in the activities that it carries out. WOTTOLINE shall not require maintenance of identity and/or personal documents from its personnel.

3.4. Health and safety and prevention of workplace accidents.
WOTTOLINE undertakes the commitment to promote and maintain a safe and healthy work environment, and shall take appropriate measures to prevent accidents and injuries caused during work or work related activities, by limiting, to the extent possible, the inherent causes of hazard in said work environment.

> All WOTTOLINE personnel must understand and comply with all health and safety regulations established in the company.
> All personnel have the right and duty to communicate, through established internal means, any situation which jeopardises the health and safety of personnel.

3.5. Freedom of association and right to collective bargaining.
WOTTOLINE is committed to observance of the right of association and collective bargaining of its personnel.

3.6. Equal opportunity and non-discrimination.
WOTTOLINE undertakes the commitment to promote a suitable work environment in order to prevent discrimination, based on the attributes of race, gender, ideology, religion, sexual orientation, age, nationality, disability or any other personal, physical or social condition, and in which diversity is respected and valued. WOTTOLINE shall not permit behaviour, including gestures, language, or physical contact, construed as sexual, coercive, threatening, abusive, or exploitative.

> All personnel must promote, through participation and action, work environments where the equality policies established by WOTTOLINE are observed.
> All personnel with professional supervision over other persons must be objective as regards selection and promotion, as well as in the establishment of corresponding conditions for remuneration, with respect to training and evaluation, all actions must be carried out within a framework free of any type of discrimination, and based exclusively on individual effort, professional worth and employee performance.

3.7. Disciplinary measures.
WOTTOLINE shall not use, nor shall it support the use of corporal punishment, mental or physical coercion, or verbal abuse.

> No withholdings shall be enacted as regards remuneration.

3.8. Work schedule.
WOTTOLINE is committed to respecting employee agreements as regards work schedules in order that employees are utilised rationally while respecting requirements for breaks and work resources.

3.9. Remuneration.
WOTTOLINE shall guarantee that salaries comply, at minimum, with legal regulations and/or corresponding agreements, in order to sufficiently cover the basic needs of personnel.
WOTTOLINE shall guarantee that no financial deductions shall be imposed as a disciplinary sanction in and of itself.

3.10. Reconciliation of work and personal life.
WOTTOLINE believes that professional development and work-personal life balance is the basis of social responsibility. WOTTOLINE establishes different measures aimed at achieving a balance between family, personal and professional responsibilities of its personnel.

> All personnel must respect the privacy of others and facilitate the social responsibility actions established by the organisation.

3.11. Relationships with suppliers and subcontractors.
WOTTOLINE’s professional relationships with suppliers and subcontractors must be based on product and service quality, and in accordance with our Social Responsibility Policy for Suppliers and Subcontractors, ensuring compliance with international standard SA 8000 and principles of the Global Agreement.

> Selection and procurement of products or services must be carried out according to technical, experience, delivery and economic criteria, without compromising customer requirements or the interests and requirements of WOTTOLINE.
> Relationships with suppliers in violation of the law or the basic principles contained in this policy shall not be established.
> No WOTTOLINE personnel may receive or be offered commissions or gratuities in the form or gifts or favours of any nature for actions carried out on behalf of WOTTOLINE (with the exception of courtesy gifts of symbolic value, etc.).

3.12. Confidentiality of information and protection of personal data.
WOTTOLINE has established an Information Security Policy with the objective of preserving the confidentiality, integrity and availability thereof. WOTTOLINE information is property of the company and essential for the development of its activity.

> Security of information is the responsibility of all WOTTOLINE personnel, who must protect company information and carry out activities in accordance with corresponding rules and legislation.
> WOTTOLINE information regarding its activities, customers, shareholders, etc., shall be considered as confidential and processed in accordance with corresponding legislation.
> Processing of personal data must be carried out in accordance with legal terms.
> Personnel may not use any accessible information, during development of activities, for purposes other than that established contractually and for purposes contrary to corresponding legislation.

3.13. Functional regime.
Any personnel with doubts as regards interpretation and/or application of this policy, or who observes a situation that may involve unlawful behaviour, irregularity, breach or violation of any of the principles of conduct established in this policy, shall notify the Social Responsibility Committee, through the established communication channel.

There is a communication channel available for personnel and interested parties through the website, www.wottoline.com and/or email consultasrs@wottoline.es Information shall be managed by the Social Responsibility Committee, complying with all legal requirements as regards data protection and confidentiality. The Social Responsibility Committee, within the scope of its functions, shall analyse the information and implement all necessary corrective and/or preventive actions while informing the interested parties of the result.

The Social Responsibility Committee shall be comprised of the General Director the Social Responsibility Management Representative and theemployee representative. The Social Responsibility Committee has the following functions:

  1. To define and approve Social Responsibility Policy and procedures.
  2. Periodic revisions of the efficiency of the Social Responsibility Management System.
  3. Approval of improvement objectives and plans for the Social Responsibility Management System.
  4. Analysis and decisions as regards breaches of the Social Responsibility Policy.