Ethical Code

1. INTRODUCTION

One of HCP’s objectives is to define and implement actions to improve the quality of our services, which also implies an exercise in improving our corporate communication. In this respect, this Code, together with the rest of HCP’s corporate documents, implies a commitment to good governance, responsibility and transparency with respect to the ethical and legal standards that govern our activity and our relationships.

2.PERSONS, GROUPS AND INSTITUTIONS

The principles and rules of conduct included in this Code of Ethics establish the way in which HCP faces its social, ethical and legal responsibilities as a company dedicated to architecture and engineering. Therefore, they concern all our stakeholders: members of the Management Committee, internal team, direct and indirect collaborators, suppliers, clients, public organisations and the local, regional and national communities in which HCP operates or may operate.

Likewise, HCP will encourage all professionals linked to the company to adopt conduct that is in line with the principles that govern this Code.

3.VALIDITY

This Code of Ethics was approved on 1 December 2023 by the HCP Management Committee. Its validity is indefinite, without prejudice to the fact that it may be updated and revised as often as considered necessary.

Likewise, as HCP is an architecture, engineering and urban planning firm that carries out projects both in Spain and in foreign countries, it should be noted that this Code of Ethics is valid at national and international level, always taking into account the cultural, social, economic and linguistic differences of the countries in which we carry out our activity.

4.ETHICAL STRUCTURAL PRINCIPLES

All actions of HCP, its employees and the professionals with whom it collaborates shall respect the law, human rights and public freedoms. To this end, all necessary measures will be taken to guarantee respect for the principles set out in the Universal Declaration of Human Rights and the United Nations Global Compact in the areas of human rights, labour rights, the environment and the fight against corruption.

4.1 QUALITY

One of HCP’s basic principles is to satisfy and defend our clients, which is why we aim to achieve excellent quality standards in our services.

4.2 PROTECTING OUR PEOPLE

At HCP we promote both the safety and the professional development of our employees, encouraging continuous training and the improvement of the skills and abilities of our entire team. For this reason, at HCP we do not tolerate behaviour that could cause damage to people and/or installations.

4.3 CONFIDENTIALITY AND TRUTHFULNESS

HCP is committed to transmit information related to its company and its projects in a truthful way, although it will always do so respecting the possible confidentiality agreements established.

Likewise, all HCP professionals undertake not to disclose sensitive information about the company, the projects we develop or our clients, minimising the risks derived from its improper use both internally and externally.

4.4 ANTI-MONEY LAUNDERING PREVENTION

The entire HCP team will remain vigilant for any indications of lack of integrity of persons or entities with whom we have relationships, including payments not reflected in a contract.

4.5 RESPECT AND NON-DISCRIMINATION ON THE BASIS OF GENDER, SEXUAL ORIENTATION, RELIGION, RACE, DISABILITY OR CULTURAL DIFFERENCES

At HCP we understand diversity as something positive, being free of prejudice and developing relationships governed by tolerance and respect.

4.6 RESPECT FOR THE ENVIRONMENT

HCP is firmly committed to environmental protection. Therefore, we develop our work trying to minimise the negative environmental impact, as well as promoting innovation to improve production processes.

5.RULES OF CONDUCT

5.1 CONFLICTS OF INTEREST

HCP professionals, their related persons (spouses, children or dependent relatives) and the entities or companies they may direct or manage, must avoid situations that give rise to a direct or indirect conflict between their personal interests and the interests of HCP.

In the event of a situation of potential conflict of interest, the HCP professional must inform his or her hierarchical superior or the Management Committee in writing prior to the occurrence of the conflicting event, in order to take the appropriate measures and prevent his or her impartiality from being compromised.

5.2 CLIENT RELATIONS

Relations with our clients are governed by the principles of responsibility, commitment and professional honesty. This implies that HCP will respect the agreements established with clients, promoting transparency in our relations, and will also ask our clients to behave in a way that is guided by business ethics.

5.3 RELATIONS WITH SUPPLIERS AND OTHER PARTNERS

From HCP we aim to develop professional relationships with other studios, collaborators or service providers that are beneficial for both parts, although we will only maintain relationships with companies that carry out their activity in compliance with the applicable regulations.

5.4 RELATIONSHIP WITH PUBLIC ADMINISTRATIONS

HCP is committed to strictly comply with the applicable legal regulations, paying special attention to the applicable tax, social security and money laundering prevention regulations.