ETHICS AND
RESPONSIBILITY

This Code of Ethics (hereinafter “the Code”) aims to establish the principles and values ​​that must constantly inform the activities of the Remeco Group and should be considered a guide for employees, managers, and members of the Board of Directors of our Organization in all their professional relationships.

This Code does not cover every possible situation that may arise; however, it does set forth the principles that should, at all times, guide the behavior of everyone who works in our Organization.

Therefore, it is important that everyone knows and complies with this Code and performs their work in accordance with the principles expressed herein, bearing in mind that each of us is responsible for its compliance and dissemination. This is without prejudice to any other internal regulations of a special nature and applicable legislation, which will prevail in the event of any conflict or contradiction with this Code.

This Code will govern all contractual, commercial, or business relationships of the Remeco Group with its suppliers and/or clients.

(NOTE: The version of the Code of Ethics shown is an abridged version. The full version can be requested from the Remeco Group Compliance Officer by emailing compliance@remeco.com)

This Code applies to all stakeholders, including employees, managers, and members of the Remeco Group's Board of Directors.

Furthermore, all individuals and legal entities that maintain any type of relationship with the Remeco Group in the performance of their professional or business activities are subject to compliance with this Code. This includes external auditors, consultants, advisors, suppliers, advertisers, media agencies, external production companies, organizations, institutions, etc.

The Remeco Group's corporate culture is focused on achieving positive results in all areas of the organization, based on honesty and professionalism in the workplace, compliance with current legislation, and corporate responsibility.

At the Remeco Group, we are aware of the responsibility and position that a company like ours holds in the health of people in Spain and Portugal. Responsible leadership in the development of our business activities is a priority for our company, achieved through ethical and responsible behavior towards society and the environment.

The human element is a priority for our organization, which develops policies promoting equal opportunities, teamwork, respect for human dignity, and non-discrimination. Likewise, excellence in our work, in the pursuit of continuous improvement, is a guiding principle that drives us to carefully identify and develop the talent and capabilities of our staff, so that they add value to the business.

The Remeco group supports and adopts as its own the Code of Ethics of the Health Technology Sector, the MedTech Code of Ethical Business Practice, the FENIN Code of Good Practices, APORMED, as well as all those Codes of Ethics that, due to its activity, may be associated with them.

a. Legal and Regulatory Compliance

The Remeco Group is fully committed to strict compliance with the legal framework.

Recipients are obligated to take all appropriate measures to comply with current legislation. In this regard, and should any doubts arise, the Remeco Group's Criminal Compliance Officer (Ethics and Compliance Committee (hereinafter, CEC)) should be consulted.

b. Conflict of Interest

A conflict of interest will be considered to exist in any situation in which the interests of the Company, on the one hand, and the personal interests of the individual subject to this Code, on the other hand, directly or indirectly, come into conflict. A personal interest will exist when the matter affects the individual, either directly or indirectly through a person with whom they are connected.

Some situations, not exhaustive, in which a conflict of interest may arise include:

• Entering into a contract on behalf of the Remeco Group with a supplier company owned or managed by a friend or family member.
• Working as a consultant for a Remeco Group supplier or client.
• Conducting business activities on one's own behalf that are similar in nature to the work performed at the Remeco Group.
• Having a personal or financial interest in a business dealing with the Remeco Group.
• Obtaining a personal advantage or financial gain, beyond normal remuneration, in an agreement or business relationship with a third party involving the Remeco Group.

c. Confidentiality and Confidential Information

Experience has demonstrated the high level of competition in the market, making the preservation of the confidentiality of the Company's initiatives and strategies a top priority.

However, experience also shows how easily not only decisions, but even simple internal discussions, are made public through various channels.

It is crucial to raise awareness among all individuals who provide services to the Remeco Group in any capacity, regarding the need to maintain a high level of confidentiality in the use of information to which they have access simply by virtue of being part of the organization.

Therefore, the disclosure outside the company of any information, without exception, to which any employee or manager of the Remeco Group has access in the performance of their duties is prohibited.

All Remeco Group employees are responsible for protecting company information to which they have access, developing diligent behavior based on the custody and monitoring of said information to avoid unintentional disclosures.

Information will not be handled outside of appropriate work channels (including online chats, social media such as Facebook, Twitter, or LinkedIn, or blogs). Likewise, letters, reports, contracts, and any other type of document must not be left exposed on tables or in places accessible to unauthorized individuals.

The confidentiality of information must be maintained throughout the duration of the relationship with the Company and after its termination. Furthermore, confidential information must not be used for personal gain.

Recipients will not use any means contrary to law or ethics to acquire confidential information from any competitor, supplier, client, or third party.

The recording of any activity, whether audio or audiovisual, carried out on the premises (owned or leased) of the Remeco Group, using any audiovisual or electronic device, is prohibited unless it is related to the normal performance of work duties.

d. Privileged Information and the Integrity, Responsibility, and Transparency of Financial Information

The Remeco Group will define the individuals or bodies authorized to activate mechanisms for treating any information as privileged. All information of the Remeco Group must be recorded and presented accurately, diligently, and in accordance with current regulations, ensuring proper accounting of all the Company's assets, activities, and liabilities.

e. Equality and Non-Discrimination

The Remeco Group promotes equal opportunities in all matters relating to access to employment, working conditions, training, professional development, and advancement.

The Remeco Group assumes the responsibility of maintaining a work environment free from all discrimination and any conduct that constitutes personal harassment.

The relationship between employees, managers, and directors of the Remeco Group will be governed by mutual respect for personal dignity and fair and courteous treatment of others.

The Remeco Group promotes non-discrimination on the grounds of race, nationality, ethnicity, gender, age, disability, personal and family circumstances, marital status, physical appearance, sexual orientation, maternity or pregnancy, religion, ideology, political opinions, beliefs, or any other grounds prohibited by law.

The Remeco Group has a zero-tolerance policy regarding any abusive, humiliating, offensive, or potentially harassing behavior, whether physical or psychological. This includes, in particular, behavior based on race, color, sex, religion, ethnicity, nationality, age, personal and family circumstances, sexual orientation, disability, physical condition, or any other grounds prohibited by law.

No one shall behave in a way that induces, promotes, encourages, facilitates, or determines the occurrence of acts, activities, or relationships that constitute or could constitute prostitution or corruption of minors.

There will be no unfair treatment, retaliation, or discrimination against individuals who, in good faith, report the existence of the aforementioned behaviors or participate in the investigation of a complaint.

f. Health, safety at work, and environmental protection.

Within its labor, business, and professional relationships, the Remeco Group is committed to the protection, safety, and health of its employees, customers, suppliers, and the general public. Our ongoing efforts are directed toward compliance with laws and regulations regarding occupational risk prevention, health protection, and workplace safety.

Using the resources provided by the Company, all employees are responsible for ensuring that the work environment meets health and safety requirements and for performing their duties in strict compliance with occupational health and safety standards and policies.

In carrying out their duties, Remeco Group employees will conduct themselves with complete respect for natural resources and the environment, as well as for the laws and regulations established for its protection. All work activities will always be carried out with the appropriate administrative and environmental permits.

All employees must follow the instructions and guidelines provided by the company for compliance with health, safety, and environmental protection regulations.

The Remeco Group has policies, procedures, and standards for occupational risk prevention and health protection that are accessible to all its employees.

g. Drugs and alcohol.

It is strictly prohibited to possess, distribute, or consume any type of illegal drug during working hours.

The consumption of alcohol during working hours is not permitted. Moderate alcohol consumption may be permitted in exceptional circumstances, such as celebrations, meals, and other situations related to local culture or customs, provided it does not impair the performance of work-related duties.

h. Resources and Materials for the Performance of Professional Activities

The Remeco Group provides its professionals with the necessary and appropriate resources and materials for the performance of their professional activities.

Employees and managers of the Remeco Group must make responsible use of the resources and materials made available to them, using them exclusively for professional activities in the interest of the company. These resources and materials may not be used or applied for personal purposes unless expressly authorized by the appropriate person. This entails the duty to protect these materials from unauthorized use and to prevent theft, loss, damage, illegal, or inappropriate use.

No valuable item belonging to the Company may be removed from the workplace or Company premises, nor destroyed, without prior authorization.

Some non-exhaustive examples of prohibited conduct include:

• Theft of materials and supplies, equipment, documents, money, or other property.
• The improper use of corporate credit cards, telephones, computers, printers, fax machines, or any other similar equipment.
• Withholding any information or assets belonging to a third party that are in the Company's possession.

i. Business and Competitive Relations

All stakeholders (managers, employees, customers, suppliers, organizations, institutions, etc.) are key to the reputation and profitability of the Remeco Group. Relations with these stakeholders must be open, honest, loyal, respectful, and ethical.

Any act that violates regulations concerning competition and unfair competition is prohibited.

j. External Communication.

It is essential to safeguard the Company's image and reputation to present itself as a serious and consistent organization.

Unless expressly authorized by a position, authority, or mandate, no opinion, official or unofficial, will be communicated or leaked, nor will any document or information be published in the media, social networks, forums, blogs, or similar online platforms.

All communications with external media will be conducted exclusively by authorized individuals and departments.

Any contact or attempt to contact a member of the organization with the intention of obtaining media-relevant information about the Company must be reported to Management as soon as possible.

k. Email, Internet, and Telephony

The Internet, intranet, email, mobile telephony, and all other resources provided by the Company to its employees and managers are work tools for the development of the Remeco Group's business. Inappropriate use of these tools is prohibited. Exceptionally, these resources may be used for personal matters in a limited and non-abusive manner, provided that such use does not interfere with the Company's work or business or disturb the rest of the Organization.

All communications and information transmitted, received, created, and/or stored on Remeco Group's computer or telecommunications hardware or software systems are the property of the Company. The Remeco Group will implement all necessary measures to prevent computer damage and denial-of-service attacks.

Computer equipment and electronic communication resources are the property of the Remeco Group and are made available to users for the performance of their duties. Their use may be subject to monitoring. This control can be carried out, where appropriate, by recording and monitoring the number of accesses, places visited, emails sent and their content.

In this regard, the companies of the Remeco Group are authorized to:

• Take appropriate disciplinary action in the event of abusive and/or improper use.
• Restrict access by temporarily or permanently blocking or disabling its use.

Under no circumstances may these tools be used to carry out illegal acts or acts prohibited by this Code. For example, the Remeco Group's computer systems and tools may not be used to send, receive, host, or publish:

• Abusive, offensive, hostile, sexually explicit, or discriminatory information.
• Information that poses a risk of computer virus attack.
• Materials containing intellectual property rights, trade secrets, or similar content without the appropriate authorization from the relevant third parties.
• Messages or files with any intent contrary to ethics and morality, or that violate, harm, or may violate or cause harm to the Remeco Group or its recipients.
• Activities that in any way induce or lead to the commission of electronic fraud.

I. Privacy and Data Protection

The Remeco Group scrupulously complies with current legislation regarding data protection and privacy for all of the Company's stakeholders.

All information provided by patients, suppliers, auditors, or consultants in general, who maintain an employment, commercial, or professional relationship with the Company, is properly safeguarded, thus guaranteeing privacy and compliance with all laws, rules, and regulations regarding data protection.

In compliance with this legislation, the Remeco Group's current privacy and data protection policies and procedures will be observed.

It is prohibited to seize, use, or modify, without proper authorization, confidential personal or family data of a third party, which is recorded in files or on computer, telematics, or any other type of media or record, using Company resources.

Likewise, it is prohibited to seize letters, papers, emails, or any other documents or personal effects without the owner's consent, including the interception of communications or the use of listening, transmission, recording, or reproduction devices. Accessing data or computer programs by breaching corporate security measures is also prohibited.

The Company's resources and tools may be audited and monitored by the Remeco Group in accordance with applicable law.

m. Fraudulent practices and deceptive promises.

In dealings with stakeholders, no deceptive promises or false proposals will be made that are manifestly contrary to good faith and that imply the attempt or commission of any act of corruption, bribery, fraud, or any other conduct classified as a crime under the Criminal Code. Relations with stakeholders will be honest and fair.

No deception will be used, nor will any operations be carried out that lead to error, harm, or could harm the personal, commercial, and business relationships in which the recipients are involved, especially by using computer manipulation or telecommunications devices, credit cards, debit cards, or any other means of payment.

n. Duty to Communicate and Whistleblowing Channel.

The Remeco Group is committed to fostering a work environment where employees feel free to report any situation or event that concerns them or that they consider important to the company.

In this regard, any member of the Organization, or even individuals outside the organization, who have well-founded suspicions of practices contrary to the principles and values ​​of this Code or the Law, should report them to the organization through the “Whistleblowing Channel” by sending a written report (which may be anonymous) to compliance@remeco.com, by mail to Avenida del Ejército, 50, 15006 – A Coruña, Spain, or via the following link.

There are also other options for filing a complaint, such as by telephone or in person, within a maximum of 7 days from the informant's request. Verbal communications must be documented, at the informant's option, through a recording or full transcript.

The complaint must contain, at least, the following information in order to be processed:

• A description of the conduct that violates the Code of Ethics.

• Possible individuals involved.

• Approximate dates of the events.

• Means by which the conduct that violates the Code of Ethics was carried out.

• Affected business areas.

• Relevant processes affected (e.g., procurement, accounting, treasury).

• Potential economic impact.

• Where applicable, supporting documents or evidence of the events.

No one may be criticized or belittled in any way, even if the investigation reveals that the suspicions were unfounded, for having reported facts or circumstances that, in good faith, they believed they should bring to the Organization's attention. In this regard, no form of retaliation or unfair or discriminatory treatment is permitted or will be tolerated.

The Whistleblowing Channel is governed by the “Whistleblowing Channel Procedure” and, under no circumstances, will it be a means of communicating situations of personal or work-related dissatisfaction, or those that have no involvement with the Company.

o. Gifts, payment of illegal commissions, donations, and illegal benefits.

As a general rule, it is not permitted to offer, accept, or solicit gifts, payments, or invitations in relation to any client, supplier, public authority, or public official (national or international), outside of common custom and local practices and contrary to applicable regulations.

Similarly, donations or loans to political parties, non-governmental organizations, and associations made on behalf of the Remeco Group will only be permitted when they have been approved and comply with applicable legislation.

This Code of Ethics governs all relationships, contractual or otherwise, between the Remeco Group and its employees, clients, and suppliers.

All employees and managers must conduct themselves in accordance with the principles and values ​​expressed herein. Ignorance of the rules and principles contained herein does not excuse compliance.

No breach of the Code will be tolerated. Depending on their severity, breaches of the Code may be penalized with the disciplinary sanctions provided for in the applicable disciplinary regulations. Furthermore, any violation of the Code may constitute a breach of a current law or regulation, and therefore, the parties involved may be held liable civilly, criminally, and/or administratively.

The system for reporting, receiving, and managing potential violations of the Code of Ethics will be managed by the Ethics and Business Council (CEYC), ensuring the confidentiality of all parties involved throughout the entire process.

Each worker is responsible, whenever they identify a possible risk or need for improvement in the process, for communicating the respective to their superiors, in order to increase efficiency and allow for first and second level controls.

Failure to comply with, or partial compliance with, the processes/procedures and the current Code of Ethics may result in the initiation of disciplinary proceedings against the employee or employees involved.

The Disciplinary Process, or disciplinary procedure, which is the means by which the employer exercises disciplinary authority, is the set of actions undertaken to clarify the facts alleged against the employee.

An employee is any natural person, whether a national or a foreigner, who voluntarily agrees to provide their professional services, in exchange for remuneration, to Remeco, within the scope of the organization and under its authority and direction. When we say "under its authority and direction," we mean that the employment relationship is one of subordination; that is, the employee is functionally dependent on the employer.

Among the employee's duties to the employer are, among others, the duty to:

• Obedience
• Diligence
• Attendance and punctuality
• Loyalty
• Professional secrecy

Disciplinary authority is the power granted by law to the employer to sanction an employee for failing to fulfill the duties arising from the contract or for violating duties related to the requirements of the activity to which they are dedicated.

By failing to comply with the company's processes and procedures, the employee may be violating, among others, their duties of obedience, diligence, and care.

Disciplinary authority is exercised by the employer through company officials or those to whom the respective exercise is expressly delegated. When an employee fails to fulfill their duties, this conduct is called a disciplinary offense. A disciplinary offense is understood as intentional and negligent conduct (action or omission) attributable to the employee that results in the breach of their duties.

Disciplinary proceedings are initiated at the request of the Managing Director and are conducted by Human Resources and assisted by the law firm that legally represents Remeco.

The reasons that may give rise to the initiation of a disciplinary procedure include the following:

• Inappropriate behavior toward managers and/or colleagues

1. Physical intimidation
2. Verbal/psychological intimidation
3. Failure to comply with rules of respect and common sense

• Non-compliance or partial compliance with current processes/procedures, which occur occasionally or repeatedly, with serious, potential and/or actual consequences for any of those involved in the process in the following areas:

1. Potential consequences: internal, external – with clients, with patients
2. Effective consequences: internal, external – with clients, with patients

• failure to meet deadlines
• Lack of communication and information leading to difficulties in resolving problems with partners and/or those represented.

The application of disciplinary sanctions by the employer is not automatic; it follows a process. The Disciplinary Process or Disciplinary Procedure, which is the way in which the employer exercises disciplinary power, is the set of actions carried out to clarify the facts alleged against the employee.

The establishment of the disciplinary process follows these phases:

• Trial or participation stage
• Defense phase
• Investigation phase
• Decision stage

The accusation or participation phase consists of notifying the offending employee in writing of an interview. During the interview, the employee must be given a statement of guilt, containing a detailed description of the alleged actions, the date, time, and location of the interview. The employee has the right to be accompanied by a person of their choosing.

The employee must sign the statement of guilt, noting the date and location of its delivery, and confirming that they have received it.

During the interview, the employer may explain to the employee the reasons for the disciplinary action they intend to take. The defense phase involves the employee's response to the alleged actions, which may include confessing, denying, offering justifications, explanations, mitigating circumstances, or even justifying the actions. At this stage, the employee may also request in writing that any necessary steps be taken to substantiate the allegations and to appoint witnesses.

The investigation phase consists of gathering evidence of the facts, both those alleged by the employer and those alleged by the employee.

The decision phase is the application (or not) of the disciplinary measure. The offending employee may be suspended preventively if their presence at the workplace is deemed inappropriate, without prejudice to the timely payment of their salary. According to current legislation, the employee may appeal the sanction.

Disciplinary proceedings, when initiated, follow current legal regulations, and after the investigation, sanctions may be applied. These can range from the simplest (written reprimand) to the most severe (employee dismissal).

In addition to the right to apply disciplinary measures, the employer may file a civil or criminal action before the competent authorities, seeking a conviction of the offending employee to obtain compensation for the damages suffered or simply a conviction.

This Code of Ethics was reviewed and approved on September 21, 2021, and supersedes the previous Code of August 1, 2019, and June 26, 2017. It will be continuously updated and aligned with the objectives, circumstances, and needs of the Company.