The present document sets out the set of general principles and regulations or corporate governance and professional conduct which are applicable to all staff, employees, advisors, individuals or corporate bodies who perform the duties of representation, administration, management or control of Ibérica Semiconductores de Potencia S.L., henceforth called ISP, as well as all the staff hired on a permanent or casual basis.

The Code of Conduct has been drawn up with the following main aim in mind:

• To engender trust in the context of its business activities. Trust which extends both to the company’s own staff and to those individuals or corporate bodies who are related therewith.
• Integrity, honesty, fair treatment and full compliance with all the applicable laws have guided the trading practices thereof. All staff support and comply with this undertaking in terms of their daily responsibilities, making its reputation one of its most important assets.

Employees must always be guided by the following basic principles:

• To avoid any conduct which may harm or jeopardise the company or its reputation.
• To act legally and honestly.
• To prioritise the interests of the company with regard to personal or other interests.

General Regulations and Conduct.

1. ISP and its employees are subject to the law. Compliance with all the applicable laws and regulations must never be compromised. What’s more, employees must abide by the internal regulations and standards applicable in any given situation. Said internal regulations are specific to the Company and may go beyond the requirements of the law.
2. A Conflict of Interest occurs when the personal interests of an employee or the interests of a third party compete with the interests of the Company. In this situation, it could prove hard for the employee to act fully in line with the best interests of ISP Whenever possible, the employees must avoid any Conflicts of Interest. If there has been a Conflict of Interest or if an employee is facing a situation which may give rise to a situation which may give rise to a Conflict of Interest, the employee must notify the compliance committee thereof.
3. Everyone forming part of the company constitutes a vital factor for its success and hence their personal development is promoted, bearing in mind the possible balance between the objectives of the company and the needs and expectations of the employees.
   A priority aspect for the company are the preventive controls implemented: Occupational Risk Prevention, Adaptation to the GDPR, Prevention of Money Laundering and the Financing of Terrorism, Equality Plan, Criminal Risk Prevention as well as those controls applicable to the legislation in force.
4. Confidential information is that which is not in the public domain. It includes trade secrets, business plans, marketing and services, data bases, designs, records, financial aspects etc. The constant success of the company depends on the use of its confidential information and its non-disclosure which constitutes an obligation for anyone forming part of said company. An obligation which shall remain in place even after the working or any other relationship has ceased to exist.
5. Any information conveyed to clients, suppliers, public administrations etc. shall be truthful, complete, up-to-date and shall properly reflect the position of the company. This maxim shall be particularly adhered to as regards financial information.
6. The employees of ISP may not be influenced by receiving special favours nor shall they seek to influence third parties in an inappropriate manner by providing them with favours. Employees may only accept or offer reasonable entertainment and symbolic gifts which are appropriate in light of the circumstances and they shall not accept or offer any presents, meals or entertainment if said behaviour may create the impression that it constitutes improper influence. No employee may offer third parties nor accept from them any gifts, whatever their value, consisting of money, loans, bribes and monetary perks.
7. The company employees shall notify the Compliance committee about any practice or action which they believe to be improper, illicit or criminal. The company shall, in any case, guarantee the confidentiality of the notifying party. Communications must be investigated in an appropriate manner and in accordance with the stipulations of the Criminal Risks’ Prevention Manual. And it is strictly forbidden to take any reprisals against the person who carries out the communication provided that he/she has acted in good faith. In the event that the notifying party has acted in bad faith, the appropriate disciplinary and/or legal actions shall be taken against him/her.
8. All the employees of ISP have at their disposal a communications’ channel via which they must confidentially communicate any behaviour or activity which runs counter to the Code of Conduct or the legislation. The communications’ channel is the following: comitedecumplimiento@ibersp.com
9. Transparency and integrity are values which must be assumed by all company employees. Any attitude suspected of breaching these principles must be informed to the compliance body via the aforementioned communications’ channel.
10. ISP shall always compete, complying with all the regulations applicable in terms of the protection of competition, antitrust and fair trading. Hence, the commercial policy and pricing shall be determined independently and they shall never be formally or informally agreed with competitors.
11. It is the responsibility of all employees to ensure full compliance with all the provisions of this Code. Said responsibility cannot be delegated. Any breach thereof may give rise to the application of disciplinary measures, including dismissal and, where applicable, the commencement of legal actions.

Financial Integrity of the company.

12. Company accounting must be carried out pursuant to the principles of clarity and transparency. Furthermore, any tax settlements shall be undertaken in accordance with the tax legislation in force.
13. The accounting and auditing staff must keep and safeguard all the documentation used in the relevant file in order to carry out their work for such time as the company determines.
14. Any action is prohibited which obstructs or impedes monitoring and evaluation tasks by the company responsible for the Audit or Inland Revenue staff in any type of audit which may have been requested.

Relations with Public Administrations.

15. Any employees of ISP who have relations with the Public Administration must be specifically designated by the company to act on behalf of the latter. Any procedures carried out shall be pursuant to the legislation and the Code of Conduct.
16. Any agreements undertaken with the Public Administration shall be drawn up in writing, specifying all the terms thereof.
17. Any documentation and information exchanged with the Public Administration must be safeguarded and must contain real information.
18. Any meetings held with the Public Administration shall be presided over by the principles of propriety and transparency and any illicit behaviour is strictly forbidden.
19. It is forbidden to falsify documentation in order to promote or harm the company.
20. Payments shall not be made in cash to Public Administration staff unless their procedures do not allow any other form of payment. Should this be the case, there must be appropriate documentary support.

Relations with clients.

21. Any relations with clients must be presided over by a commitment to professional responsibility and honesty.
22. Any contracts entered into by ISP with clients must be clear and direct and in strict compliance with the applicable regulations in force.
23. Misleading or false advertising shall never be deployed.
24. Any complaint lodged by a client shall be welcomed by the company and it shall undertake to deal with it and sort it out as far as proves possible.

Relations with suppliers.

25. The supplier selection procedures shall be characterised by a search for quality and competitiveness, ensuring equality of opportunities. Under no circumstances shall it be denied to a supplier that by meeting the requirements requested it may compete for the contracting of products or services.
26. The formalisation of a contract must always be based on clear, objective relations and avoiding any forms of dependence.
27. The purchase of goods or services shall be carried out in line with a totally independent decision and so any economic, family or other link must take into account the stipulations of Article 2.

Relations with the employees of ISP

28. When hiring staff, any type of discrimination shall be avoided.
29. ISP shall always respect the right to equality between men and women, actively promoting the absence of any type of discrimination.
30. In professional promotion and hiring processes, the decisions adopted by the company shall be based on the adaptation of professional profiles to the post.
31. The company shall promote a flexible labour organisation which fosters the work-life balance.
32. Employees must never offer nor promise – directly or through an intermediary – any personal favour in order to achieve a business deal or any other advantage from a third party, whether it is public or private.
33. Employees must not accept advantages of any type in exchange for preferential treatment, refraining from carrying out any activity or conduct which may give rise to the appearance or suspicion of said situation.
34. The actions described in the two previous paragraphs may give rise to the application of disciplinary sanctions and furthermore they may constitute criminal offences.

Managing cash transactions.

35. It is forbidden to carry out conducts which may jeopardise the prevention of money laundering and the financing of terrorism.
36. It is not permitted to make payments in cash unless no other form of payment is allowed in which case payment must be properly documented.

Commercial operations.

37. The employees of ISP are affected by the principles of transparency and clarity and they must see to it that none of their actions may be interpreted by third parties as deceitful.
38. All commercial operations shall be carried out with total transparency, avoiding any preferential treatment.
39. No negotiations shall be carried out on behalf of ISP unless there is relevant authorisation to this end.
40. Action may not be taken on behalf of clients without the prior authorisation thereof.

Dissemination and use of information.

41. It is forbidden to disseminate any false or misleading information.
42. No employee may use privileged information to which they have had access owing to their activity in the company.
43. It is mandatory to comply with all regulations pertaining to the processing of information in the context of professional development.
44. It is forbidden to incorporate within ISP any kind of information or physical or electronic document which belongs to another company without the prior consent of the latter.
45. It is forbidden to disseminate and/or assign information from other companies obtained without their consent.

Personal data processing.

46. Any employee of ISP who has access to personal data must strictly respect the regulations and procedures determined as well as the applicable legislation, GDPR (General Data Protection Regulation).
47. It is forbidden to assign or disseminate any personal data without the consent of the party concerned, except in those cases foreseen in the applicable legislation, GDPR (General Data Protection Regulation).
48. Any authorisations to use personal data must be in response to a request pertaining to specific data and for a given time period, recording all access to personal data.

Industrial and intellectual property.

49. Any Internet downloads or the installation of programmes which entail a breach of industrial and/or intellectual property rights are forbidden.
50. No images, texts, drawings or any other type of material protected by industrial and/or intellectual property rights shall be used for profit.
51. The employees of ISP may only use software that the company makes available to them and with regard to which ISP S.L shall have authorisation as it has acquired the relevant licenses.