Code of Conduct


  1. This Code develops the principles and values of the Code of Ethics adopted by the organization.
  2. It contains conduct contrary to the Code of Ethics and establishes a disciplinary regime proportional to the seriousness of the infractions and in accordance with current legislation, both general and sectoral.
  3. The Code of Conduct is part of the Regulatory Compliance System and is fully respectful of the principles of corporate organization.
  4. Unethical behavior compromises the relationship of trust between NUMINTEC and its involved parties. Good reputation is an essential intangible resource.
  5. A good reputation in external relations favors customer loyalty, the attraction of the best human resources, the trust of suppliers and reliability in the face of creditors. In internal relations, this contributes to making and applying decisions without conflicts and to organizing work without bureaucratic controls or excessive use of authority.


  1. The Compliance Unit is the body responsible for interpreting and integrating the Code of Conduct. Its interpretative criteria are binding on the Obligated Subjects of NUMINTEC and its Administrative Body.
  2. Any doubt that may arise for the Obligated Subjects of NUMINTEC regarding the interpretation of the Code of Conduct must be consulted with their immediate superior. If circumstances require it, you can go to the Compliance Unit.
  3. All communications, information and authorizations referred to in the Code of Conduct may be made by any means that allows their reception.


  1. All Obligated Subjects have the obligation to strictly comply with the legislation in force in the place where they carry out their activity.
  2. In addition, they must comply with the rules of the Corporate Governance System and the basic procedures that regulate the activity of NUMINTEC and the provisions of the Code of Ethics, and the Regulatory Compliance System.
  3. They will also fully respect the obligations and commitments assumed by NUMINTEC in its contractual relationships with third parties, as well as the customs and good practices of the countries in which they carry out their activity.
  4. NUMINTEC managers have the obligation to particularly know the laws and regulations, including internal ones, that affect their respective areas of activity and must ensure that the professionals who depend on them receive adequate information and training that allows them to understand and comply the legal and regulatory obligations applicable to their job function, including internal ones.
  1. The Obligated Subjects will observe the principles of professionalism, integrity and self-control in their actions and decision-making.
  2. Conduct is professional when it is diligent, responsible, efficient and focused on excellence, quality and innovation.
  3. Conduct is integrity when it is loyal, honest, in good faith, objective and aligned with the interests of NUMINTEC and with the principles and values expressed in the NUMINTEC Code of Ethics.
  4. Self-control in actions and decision-making requires that the actions of all professionals be in accordance with the following requirements: that the performance is ethically acceptable; that it is legally valid; that is desirable for the Society; and that one is willing to assume responsibility for it.

All NUMINTEC professionals have the obligation to inform the Compliance Officer about the initiation, evolution and result of any judicial, criminal or administrative procedure, of a sanctioning nature, in which an Obligated Subject is an investigated, accused or accused party and may affect him in the exercise of his duties as a NUMINTEC professional or harm the image or interests of NUMINTEC.

  1. Obligated Subjects have the obligation to respect human and labor rights recognized in national and international legislation.
  2. It is prohibited to hire minors, force a person to work against their will or subject them to slavery
  1. All NUMINTEC professionals undertake not to discriminate against other professionals based on race, color, nationality, social origin, age, sex, marital status, sexual orientation, ideology, political opinions, religion or any other personal, physical or social condition. .
  2. No one from NUMINTEC will promote unequal treatment between men and women with regard to access to employment, training, promotion of professionals and working conditions, as well as access to and supply of goods and services.
  3. It is not permitted to act violently, carry out acts of physical, sexual, psychological, moral or other harassment, abuse of authority at work and any other conduct that creates an intimidating or offensive environment for the personal rights of professionals.
  1. All professionals will enjoy equal opportunities for the development of their professional career regardless of their age, sex, sexual orientation, marital status, race, nationality, ideology and beliefs.
  2. NUMINTEC management will establish an effective equal opportunity policy for its employees to develop their professional activity based on the principle of merit. Promotion decisions will always be based on objective circumstances and assessments.
  3. NUMINTEC management will apply an investment policy for the learning and personal and professional training of its employees.
  4. NUMINTEC employees have the obligation to respect the equal opportunities policy in their professional field and to support the personal and professional learning of their colleagues.

NUMINTEC management will implement policies aimed at respecting the personal and family life of its professionals, as well as conciliation programs that facilitate the best balance between this and their work responsibilities.

  1. All Obligated Subjects have the obligation to respect the right to privacy of other professionals, in all its manifestations, and especially with regard to personal, medical and economic data.
  2. All Obligated Subjects will respect the personal communications of other professionals through the Internet and other means of communication.
  3. All Obligated Subjects have the obligation to make responsible use of the media, computer systems and, in general, any other means that the Company makes available to them in accordance with the policies and criteria established for this purpose.
  4. Such media will not be used for non-professional personal use and are therefore not suitable for private communication. They do not therefore generate an expectation of privacy in the event that they had to be supervised by the authorized person in the proportionate performance of their control duties.
  5. No one will disclose personal data of professionals, except with the consent of the interested parties and in cases of legal obligation or compliance with judicial or administrative resolutions.
  6. Under no circumstances may the personal data of professionals be processed for purposes other than those legally or contractually provided for.
  7. The Obligated Subjects who, due to their activity, access personal data of other NUMINTEC professionals will undertake in writing to maintain the confidentiality of that data.
  8. The Compliance Unit and the Compliance Officer will comply with the requirements provided for in the personal data protection legislation with respect to communications sent to them by professionals or other people close to the Company.
  9. The Obligated Subjects will only request and use the employee data necessary for the effective management of the business or whose proof is required by applicable regulations, committing to maintain the confidentiality of this data.
  10. NUMINTEC will take all necessary measures to preserve the confidentiality of the personal data at its disposal and to guarantee that confidentiality in their transmission, when necessary for business reasons, complies with current legislation.
  1. NUMINTEC management will provide employees with a safe and stable environment, keep occupational risk prevention measures up to date and will scrupulously respect the regulations applicable in this matter in all places where it carries out its business activities.
  2. All Obligated Subjects are responsible for observing strict compliance with health and safety regulations in order to protect themselves and other employees or third parties.
  3. All people are obliged to maintain the facilities and equipment and the work environment in proper working order and safety. The facilities must be used respectfully and kept clean and tidy.
  4. The possession, distribution and consumption of all types of drugs and psychotropics is prohibited in the facilities or workplaces, except for prescription medicines.
  5. NUMINTEC will inform the suppliers with which it operates so that they comply with its standards and programs regarding safety and health at work.
  1. Obligated Subjects will not give or accept gifts or presents in the development of their professional activity.
  2. Exceptionally, the delivery and acceptance of gifts and gifts will be permitted when the following circumstances occur simultaneously: are of irrelevant or symbolic economic value; respond to signs of courtesy or usual business attention; and are not prohibited by law or generally accepted business practices.
  3. The Obligated Subjects may not, directly or through an intermediary, offer or grant or request or accept unjustified advantages or benefits that have the immediate purpose of obtaining a benefit, present or future, for NUMINTEC, for themselves or for a third party.
  4. In particular, they may not give or receive any form of bribe or commission, coming from or made by any other party involved, such as public officials, Spanish or foreign, personnel from other companies, political parties, authorities, clients, suppliers and partners.
  5. Acts of bribery, expressly prohibited, include the offer or promise, direct or indirect, of any type of improper advantage, any instrument for its concealment, as well as influence peddling.
  6. Nor may money be received, in a personal capacity, from clients or suppliers, not even in the form of a loan or advance, all of this regardless of the loans or credits granted to NUMINTEC professionals by financial entities that are clients or suppliers of NUMINTEC and that are not engaged in the activities previously expressed.
  7. NUMINTEC professionals may not give or accept hospitality that influences, could influence or could be interpreted as influencing decision-making.
  8. When there are doubts about what is acceptable, the offer must be declined or, where appropriate, consulted first with the immediate superior, who may refer the query to the Compliance Unit.
  1. NUMINTEC fights against tax evasion, fraud and money laundering.
  2. The administrative management procedures include protocols against tax evasion, fraud and money laundering, with control actions being carried out on their implementation.
  3. The internal audit department will review the correct implementation of the administrative-financial procedures.
  4. Annually the company’s accounts will be audited by an external company to give the highest degree of transparency to NUMINTEC’s actions.

1. A conflict of interest will be considered to exist in those situations in which the personal interest of the professional and the interest of NUMINTEC collide, directly or indirectly. There will be personal interest of the professional when the matter affects him or a person related to him.

2. The following will be considered persons linked to the Obligated Subject:

  1. The spouse of the Obligated Subject or the person with a similar emotional relationship.
  2. The ascendants, descendants and siblings of the professional or the spouse (or person with a similar emotional relationship) of the Obligated Subject.
  3. The spouses of the ascendants, descendants and siblings of the Obligated Subject.
  4. The entities in which the Obligated Subject, or persons linked to him, by himself or through an intermediary, are in any of the control situations established by law.
  5. The companies or entities in which the Obligated Subject, or any of the persons linked to him, by himself or through an intermediary, exercise an administrative or management position or from which he receives emoluments for any reason, provided that, in addition, they exercise , directly or indirectly, a significant influence on the financial and operational decisions of said companies or entities.

3. By way of example, the following are situations that could give rise to a conflict of interest:

  1. Be involved, in a personal or family capacity, in any transaction or economic operation in which NUMINTEC is a party
  2. Negotiate or formalize contracts on behalf of NUMINTEC with natural persons linked to the professional or with legal entities in which the professional or a person linked to him or her holds a management position, is a significant shareholder or administrator.
  3. Be a significant shareholder, administrator, director, etc. of clients, suppliers or direct or indirect competitors of NUMINTEC.
  1. Professional decisions must be based on the best defense of the interests of NUMINTEC, so that they are not influenced by personal or family relationships or any other particular interests of the Society’s professionals.
  2. In relation to possible conflicts of interest, NUMINTEC professionals will observe the following general principles of action:
  1. Independence: act at all times with professionalism, with loyalty to NUMINTEC and its partners and regardless of own interests or those of third parties. Consequently, they will refrain in any case from prioritizing their own interests at the expense of those of the COMPANY.
  2. Abstention: refrain from intervening or influencing the making of decisions that may affect NUMINTEC entities with which there is a conflict of interest, from participating in the meetings in which said decisions are raised and from accessing confidential information that affects said conflict.
  3. Communication: report any conflicts of interest involved, prior to carrying out the operation or conclusion of the business in question, in writing, to the hierarchical superior, the Human Resources Department and the Compliance Unit, as appropriate. The latter will evaluate the situation and make the appropriate decisions, advising, if necessary, on the appropriate actions in each specific circumstance. Members of the Compliance Unit involved in a potential conflict of interest must inform the Compliance Unit, which will also be competent to resolve any doubts or conflicts that may arise in this regard.
  4. In the communication, the Obligated Subject must indicate:
  • If the conflict of interest affects you personally or through a person linked to you, identify them where appropriate.
  • The situation that gives rise to the conflict of interest, detailing, where appropriate, the purpose and main conditions of the projected operation or decision.
  • The amount or approximate economic evaluation.
  • The NUMINTEC department or person with whom the corresponding contacts have been initiated.

3. These general principles of action will be observed in a special way in those cases in which the situation of conflict of interest is, or can reasonably be expected to be, of such a nature that it constitutes a situation of structural and permanent conflict of interest between the Subject. Obligated party, or a person linked to the professional, and NUMINTEC.

4. In order to be able to determine the existence of possible incompatibilities, before accepting any public position, the NUMINTEC Human Resources Department will be informed and the Compliance Unit will be informed.

  1. In relations with any interest group such as clients, suppliers, public administration or society in general, no false statements or promises will be made whose fulfillment cannot be guaranteed.
  2. NUMINTEC will apply a policy of zero tolerance against any practice of corruption, bribery or facilitation payments in all its active and passive forms, whether through acts or omissions or through the creation or maintenance of favorable or irregular situations.
  1. All Obligated Subjects have the obligation to collaborate with the utmost diligence and within their possibilities in the development and successful completion of any internal investigation carried out in accordance with the Internal Investigations Protocol.
  2. Providing untruthful information intentionally or manifestly negligently within an internal investigation, whether in the context of an interview or in any other way, will be considered a disciplinary infraction.
  1. Non-public information that is the property of NUMINTEC will, in general, be considered information for internal use, unless it has been classified as confidential or reserved, and in any case it will be subject to professional secrecy, without its content being provided to third parties, unless it is in the normal exercise of their work, profession or functions and provided that those to whom the information is communicated are subject, legally or contractually, to an obligation of confidentiality and have confirmed to the Company that they have the means necessary to safeguard it.
  2. Information or data whose unauthorized disclosure, outside or within NUMINTEC, could cause harm (economic or reputational) or violate any regulatory or legal requirement, giving rise to the imposition of sanctions or claims against NUMINTEC, will be classified as confidential.
  3. All highly sensitive or especially valuable information or data, the disclosure of which could cause serious or significant harm, will be classified as confidential information.
  4. It is the responsibility of the Administrative Body to put in place sufficient security means and apply the established procedures to protect internal, confidential and reserved information recorded on physical or electronic media, against any internal or external risk of non-consensual access, manipulation or destruction. , both intentional and accidental. For these purposes, the Obligated Subjects will maintain confidentiality about the content of their work in their relationships with third parties.
  5. Reveal confidential or reserved information or use it for private purposes in violation of the Code of Conduct.
  6. Any reasonable indication of a leak of confidential information or information reserved for particular purposes must be reported by those who are aware of it to their immediate superior and to the Human Resources Department or the Compliance Unit.
  7. In the event of termination of the employment or professional relationship, all internal, confidential and reserved information will be returned by the Obligated Subject to the Company, including documents and storage media or devices, as well as information stored on any electronic device. corporate or personal, subsisting in all cases the professional’s duty of confidentiality.
  1. NUMINTEC has a system for identifying and ensuring compliance with environmental legislation in the process of certification.
  2. For NUMINTEC, maintaining the environmental management system is a commitment to sustainable development and environmental protection. Special attention is paid to preventing pollution and minimizing the environmental impact of the activities carried out by NUMINTEC.
  1. NUMINTEC, applying in all cases standards of transparency, information and protection, will offer, to the extent possible, a quality of services and products equal to or superior to the legally established requirements and quality standards, competing in the market and carrying out the marketing and sales activities based on the merits of your products and services.
  2. NUMINTEC professionals guarantee the confidentiality of their clients’ data, committing to not reveal it to third parties, except with the client’s consent or due to legal obligation or in compliance with judicial or administrative resolutions.
  3. The collection, use and processing of personal data of clients must be carried out in a way that guarantees the right to privacy and compliance with legislation on the protection of personal data, as well as the rights recognized to clients by the legislation on information society services and electronic commerce and other applicable provisions.
  4. Professionals will avoid any kind of interference or influence from clients or third parties that could alter their impartiality and professional objectivity and will not be able to receive any kind of remuneration from clients or, in general, from third parties, for services related to the professional’s own activity within from NUMINTEC.
  1. NUMINTEC will adapt the supplier selection processes to criteria of objectivity and impartiality and will avoid any conflict of interest or favoritism in its selection.
  2. The prices and information presented by suppliers in a selection process will be treated confidentially and will not be revealed to third parties except with the consent of the interested parties or by legal obligation, or in compliance with judicial or administrative resolutions.
  3. Obligated Subjects that access personal data from suppliers must maintain the confidentiality of such data and comply with the provisions of the legislation on the protection of personal data, to the extent applicable.
  4. The information provided by NUMINTEC professionals to suppliers will be truthful and not projected with the intention of misleading.
  5. Professionals will avoid any kind of interference or influence from suppliers or third parties that could alter their impartiality and professional objectivity and will not be able to receive any kind of remuneration from NUMINTEC suppliers or, in general, from third parties, for services related to their own activity. professional within NUMINTEC.

NUMINTEC expresses its purpose of continuous and sustained creation of value for its partners and will permanently make available to them those channels of communication and consultation that allow them to have adequate, useful and complete information on the evolution of the Company, respecting the principle of equal treatment of partners who are in identical conditions.

  1. NUMINTEC’s communication with the areas in which it carries out its work (also through the media) will be characterized by respect for the right to information.
  2. Under no circumstances will it be permitted to disseminate false or biased news or comments.
  3. All communication activities will respect the laws, rules, practices of professional conduct and will be carried out with clarity, transparency and timeliness, safeguarding, among others, price-sensitive information and industrial secrets.
  1. NUMINTEC will compete in the markets fairly and will not carry out misleading or denigrating advertising of its competition or third parties.
  2. Obtaining information from third parties, including competitor information, will be carried out inexcusably legally.
  3. NUMINTEC will promote free competition for the benefit of consumers and users. NUMINTEC will comply with antitrust regulations, avoiding any conduct that constitutes or may constitute collusion, abuse or restriction of competition.

1. NUMINTEC is committed to the generally accepted principles of corporate social responsibility as an integrating framework for its programs and actions with professionals, clients, suppliers, shareholders and all interest groups with which it interacts.

2. In this sense, all NUMINTEC staff, faithful to the business objective of generating wealth and well-being for society, will adopt a responsible business ethic that allows harmonizing the creation of value for its partners with sustainable development that considers the protection of the environment as its main objectives. environment, social cohesion, the development of a favorable framework for labor relations and constant communication with the different groups related to the Company in order to meet their needs and expectations.

3. Management policies are developed to improve NUMINTEC’s impact on society, which will include at least:

  1. Voluntary implementation of the Criminal Risk Management System.
  2. Implementation of a Protocol to combat Fraud and Corruption.
  3. Implementation of a Protocol for the Prevention of Money Laundering and Financing of Terrorism.

4. For these purposes, professionals will receive adequate training on the legislation applicable in those countries in which NUMINTEC carries out its activities.



1. The sanctions that may be imposed are intended to guarantee compliance with the rules established in this Code of Conduct.

2. The sanctions will be applied observing the principles of proportionality, equal treatment, weighting and fairness.

3. No person obliged to comply with this rule, with absolute independence of their level or position within NUMINTEC, is authorized to request another person in the Company or people in the environment to contravene what is established therein.

4. Likewise, no person obliged to comply with this rule can justify inappropriate conduct based on an order from their superiors or ignorance of this Code.

5. Any breaches of this rule that may eventually occur will be investigated and, where appropriate, sanctioned by the Compliance Unit in accordance with the applicable regulations, the collective agreements in force and the Internal Investigations Protocol.

6. Likewise, NUMINTEC will inform the competent authorities of any non-compliance with regulations if there may be signs of the commission of a crime.

7. The Compliance Officer will coordinate:

  1. With the Human Resources Department those actions that are necessary to adopt in relation to NUMINTEC personnel.
  2. With the Legal Advisory Department those actions that are applicable to people close to the Company due to a commercial or other type of relationship.

8. In any case, the measures adopted will adhere to the principle of proportionality, and the affected party will be given a hearing so that they can explain what happened.


In addition to the conduct described in the preceding sections, all conduct that, without being classified in this regime, constitutes it in application of our laws and regulations and fundamentally in the Penal Code, will be considered misdemeanors.

  1. When the competent body determines that a NUMINTEC professional has carried out activities that contravene the provisions of the Code of Conduct, the corresponding disciplinary measure will be applied in accordance with the regime of offenses and sanctions provided for in the applicable collective agreement or labor legislation.
  2. Disciplinary measures will be applied to all personnel of the organization regardless of their place of work or position, including members of the Administrative Body and Senior Management.
  3. Infractions committed by members of the Administrative body, management or the Compliance Unit will always be considered serious or very serious.

For the investigation and determination of the infraction, as well as the sanction, the provisions of the Internal Investigations Protocol will be followed.


1. The infractions committed will expire within the following periods:

  1. minor ones 3 months from the date on which the Compliance Unit became aware of their commission
  2. serious ones 6 months from the date on which the Compliance Unit became aware of their commission.
  3. very serious ones 18 months from the date on which the Compliance Unit became aware of their commission.

2. In any case, the prescription provided for in the Penal Code in force at all times will apply.

3. If the sanctions are judicially challenged, it is understood that the period of prescription of the sanction is interrupted.


The history of violations by an Obligated Subject that may appear in their personal file will be canceled, if they do not commit any other violation, within the following deadlines:

  1. minor infractions after six months.
  2. serious infractions after twelve months.
  3. very serious infractions after twenty-four months.



The Code of Conduct will be reviewed and updated periodically, taking into account the suggestions and proposals made by the Obligated Subjects, and with special attention to the recommendations of the Compliance Unit. Any modification of the Code of Conduct will require the express approval of the NUMINTEC Administration body.

  1. The Obligated Subjects expressly accept the provisions and rules of action established in the Code of Conduct.
  2. Professionals who, in the future, join or become part of NUMINTEC, will expressly accept the vision, values and standards of action established in the Code of Ethics and the Code of Conduct. Both will be annexed to the respective employment contracts.
  1. The Code of Conduct will be reviewed and updated periodically, based on the annual report of the Compliance Officer, as well as the suggestions and proposals made by NUMINTEC professionals. The Administrative Body, the Human Resources Area Management and the Compliance Unit may formulate proposals for improvement or promote the adaptation of the Code of Conduct as a whole.
  2. The modification of this Code of Conduct will in all cases correspond to the Administrative body.

The Code of Conduct was approved at the meeting of the Company’s Board of Directors, held on 01/02/2023.