CODE OF ETHICS

PRESENTATION

Preamble

The ESIC Code of Ethics (hereinafter referred to as the Code) contains the set of principles and values that should inspire the conduct of all members of the ESIC Learning Community. inspire the conduct of all members of the ESIC Learning Community. The code, which is not The code, which has no sanctioning nature, is intended to serve as a guide for the coexistence of all members of ESIC, as well as for their relationship with ESIC. ESIC, as well as for their relationship with the environment.

Due to its willingness to fulfill its mission as an institution of higher education with honesty and integrity, faithful to the values that make up its raison d'être, the code includes the following commitments and integrity, faithful to the values that make up its raison d'être, the code includes the commitments acquired by ESIC ESIC's commitments to its various stakeholders and to the organizations to which it has adhered to formalize this intention. to formalize this intention.

This code is complemented by a series of institutional documents and specific regulations, inspired by the principles and values contained herein, specify the standards of behavior of ESIC employees, its students and those who act on behalf of the institution. ESIC employees, its students and those who act on behalf of the institution. All of the above taking into account that those to whom this code applies must also comply with the provisions of the law, also comply with the provisions of current legislation.

2. ESIC's Purpose, Mission and Values

Our PURPOSE is: "To promote the transformation of people so that they can be successful in their professional lives in a responsible way and be actors of change. to develop successfully in their professional lives in a responsible way and to be actors of change in organizations and in society". in organizations and society".

Our MISSION is formulated in the following terms:

1. We are a Higher Education Institution that provides training in the areas of Management, Marketing and Digital Marketing and Digital Competencies, fostering the capacity for Innovation and Entrepreneurship. Entrepreneurship.
2. We contribute to the transformation of people by training them in knowledge, training them in competencies and sensitizing them to values throughout their professional cycle. professional cycle.
3. We are therefore building a learning community adapted to the demands of the times in order to contribute to the development of a more prosperous, responsible and responsible global society. to contribute to the development of a more prosperous, responsible and innovative global society. and innovative global society.

Our Mission is materialized:

Our Mission is materialized: TRAINING our students in technical knowledge and skills, and executive skills that allow them to develop in their own professional and personal world. personal world.

IMPULSING the development of knowledge through scientific, technical, social and cultural research, especially in business, marketing and communication, and research, especially in business, marketing and communication, and facilitating dialogue between academia and the business world. academic activity and the business world.

INSTRUCTING our students the importance of responsibility, values, teamwork and efficiency in any work they do, regardless of their hierarchical level. and efficiency in any work they perform, regardless of their hierarchical level and in any area of activity in national and international entities. any area of activity in both national and international entities.

INTEGRATING the transformative spirit, especially of marketing and the digital economy, into the strategic thinking of one's own professional performance. strategic thinking in their own professional performance. FOSTERING the development of individual talent individual talent and helping to identify it.

INFUSING values such as solidarity, generosity, diversity, effort, tolerance, critical, global and multicultural thinking, which help to be a better person based on the respect for freedom of thought, conscience, religion and personal expression. respect for freedom of thought, conscience, religion and personal expression.

PROMOTING relationships between professionals and leaders in the professional world, especially in Marketing, in Spain and in the countries where ESIC is present. Marketing, in Spain and in the nations where ESIC is present.

And we do so according to the following pedagogical principles:

• INTEGRATIVE TRAINING, in constant dialogue with the professional environment (national and international) where our students are international), providing our students with the knowledge and skills that are in demand today, especially in marketing skills that are in demand today, especially in marketing, management and digital economy. and digital economy.
• PROFESSIONALISM, personal responsibility, technical ability and dedication to the job as requirements for tenure. requirements for qualification.
• IMPORTANCE of integral human formation in accordance with the founding principles of the social thought of Leo Dehon and the Congregation of the Priests of the Sacred Heart of Jesus. social thought of Leo Dehon and the Congregation of the Priests of the Sacred Heart of Jesus, which have governed our institution since its origins. Heart of Jesus, which have governed our institution since its origins.
• INVITATION to reflect, to generate creative initiatives and to evaluate the risks involved in decision-making. risks involved in decision making.
• USE of a lively methodology, in accordance with each student, that combines academic rigor and professional practice, promotes teamwork and values effort and effort. and professional practice, promotes teamwork and values effort and hard work. work.

Our VALUES statement assumes a commitment to our students and to society.

Our culture of Commitment and Proximity, both with the people who have worked at ESIC and with those who are now part of it, are our most important assets because they have are our most important assets because they have made our institution what it is today. our institution what it is today. Commitment and closeness imply doing our utmost to improve and to understand that we cannot to improve and understand that we are not isolated individuals, but a community and that as such we have to help each other. as such we have to help each other to bring out the best in each other.

Because OUR DESTINY IS COMMON, we assume as our own and promote, among others, values such as:

• Respect for all forms of self-expression, be it personal, cultural and/or religious in nature religious
• Solidarity and generosity
• Tolerance
• Effort and honesty
• Critical thinking
• Teamwork
• Honest and open communication

3. International commitments and accessions

Beyond compliance with the laws in force in the countries where it operates, and as an institution committed to its values, at ESIC it is important to assume and put into practice the principles committed to its values, at ESIC it is important to assume and put into practice principles of action that express, clearly and distinctly, its commitment to the clearly and distinctly express its commitment to the training of responsible leaders, respect for all human rights, labor rights respect for all human rights, labor rights, the environment and the contribution to sustainable development. and the contribution to sustainable development, as well as the fight against corruption. It is thus a academic institution that is a signatory of the Global Compact (also a partner of the Global Compact Local Network in Spain). Global Compact Local Network in Spain) and the Principles for Responsible Management Education (PRME). Responsible Management Education (PRME), initiatives sponsored by the United Nations. United Nations.

In turn, ESIC is committed to achieving the 17 Sustainable Development Goals (SDGs) that make up the 2030 Agenda, approved in 2015 by 193 countries. Development Goals (SDGs) that make up the 2030 Agenda, approved in 2015 by 193 member countries of the United Nations. member countries of the United Nations. ESIC integrates the SDGs into its various academic and institutional activities, subject to a transparent activities, which are subject to a transparent process of accountability that details its contribution to their fulfillment. its contribution to the fulfillment of the SDGs.

ESIC's governing bodies are committed to the achievement of these goals and to contributing to the attainment of the SDGs, as well as to making them accessible and understandable both to the to the achievement of the SDGs, as well as to making them accessible and understandable to both the ESIC Learning ESIC's Learning Community and the third parties with whom it interacts, involving them in this involvement. involvement.

OBJECTIVES AND SCOPE OF APPLICATION

1. Purpose

The code contains the minimum set of values and ethical principles that should guide and inspire the conduct of the people who make up our Learning Community and those with whom we work. of the people who make up our Learning Community and of those with whom it maintains a professional relationship, with the aim of professional relationship, with the objective of strengthening community coexistence and growing in excellence through grow in excellence through the decisions and actions carried out.

The principles and values contained in this code help to interpret the legislation and internal regulations, as well as the commitments to which ESIC voluntarily adheres as a company. ESIC's internal regulations, as well as the commitments to which it voluntarily adheres as an institution. institution.

2. Objectives

The code is proposed:

• To publicize ESIC's values and general commitments to society.
• To offer its stakeholders a guide that can inspire their behavior, as well as the values and guidelines underpinning its policies, procedures and regulations. values and guidelines that underpin the policies, procedures and regulations that apply at ESIC. and regulations applicable at ESIC.
• Establish a frame of reference for actions and relationships between the different stakeholders and between them and the social actors, centers or external entities that stakeholders and of these with social actors, centers or external entities that collaborate with ESIC. collaborate with ESIC.

Scope of application

The code will guide the relations of ESIC and its personnel with persons, entities, institutions, organizations and companies that provide services, collaborate or relate to it, organizations and companies that provide services, collaborate or relate to it. Specifically, the code is addressed to its Learning Community, made up of: its management bodies, administration and services personnel, students -including those from all national and international national or international territories, alumni, and all those who collaborate with ESIC, when acting with ESIC, when acting on behalf of or on behalf of the institution.

4. Commitments

ESIC will ensure that the principles, responsibilities and guidelines for action established in this Code are observed by all its members in all its spheres of influence, both at Code are observed by all its members in all its spheres of influence, both in its own activities and in those it carries out with others. activities that it carries out on its own, as well as those that it carries out with other partner or collaborating partner or collaborating entities.

The commitment to ethical and responsible behavior of all the people who make up the Learning ESIC's Learning Community should be especially contemplated:

• By applying the principles and values of this code in daily decisions and actions, in the relationship with and with stakeholders.
• In compliance with the civil legislation in force, as well as the rules developed voluntarily by ESIC or to which it has decided to adhere. voluntarily developed by ESIC or to which it has decided to adhere.
• In the prevention, detection and eradication of irregular conduct.

BASIC PRINCIPLES

The ethical behavior of the people who make up the ESIC Learning Community must consider the following basic principles, grouped in four different areas the following basic principles, grouped in four different areas:

Guiding Principles:

Integrity

Beyond compliance with current legislation, actions shall be based on the values of integrity, honesty, avoidance of any form of irregular conduct, and promotion of respect for integrity, honesty, avoidance of any form of irregular conduct and promotion of respect for the particular circumstances and needs of all those involved. the particular circumstances and needs of all those involved. ESIC will promote among its members the recognition and appreciation of behaviors that are in line with the principles established in the in accordance with the principles established in this code.

Equality

ESIC promotes the participation of people on an equal basis in all its areas of action, committing to non-discrimination for any reason or nature. committed to non-discrimination for any reason or nature. To this end, ESIC will will follow equality policies that guarantee equal opportunities for all members of its Learning Community. the Learning Community and will promote these same principles in its relations with its stakeholders, for the benefit of the entire stakeholders, for the benefit of society as a whole.

3. Prudence

The risks associated with the actions to be carried out must be assessed and taken into account so as not to receive or cause unnecessary damage. unnecessary damage or harm. In the event of any doubts about the correct application of the principles application of the principles that inspire this code, you should consult with those directly responsible and/or the Ethics and/or the ESIC Ethics Committee should be consulted.

B. Respect

4. Respect and compliance with the law.

ESIC's activities will be carried out in strict compliance with applicable legislation. The within the scope of application of this code must know, understand and correctly apply the legislation correctly apply the legislation applicable to their area of activity and to the exercise of their functions, as well as the policies, procedures and internal and the exercise of their functions, as well as the policies, procedures and internal regulations that are applicable. applicable.

5. Respect for human and labor rights

All actions of ESIC and its members shall scrupulously respect the human rights and civil liberties included in the Universal Declaration of Human Rights, the Universal Declaration of Human Rights, the Universal Declaration of Human Rights and the Universal Declaration of Human Rights. public freedoms included in lists such as the Universal Declaration of Human Rights, and labor rights recognized in national legislation, as well as international conventions, such as that of the International Labor Organization. conventions, such as those of the International Labor Organization.

ESIC guarantees decent working conditions for all its employees, promoting excellence, trust and equal opportunities. It also works to provide the necessary training necessary for the correct professional performance of each person, as well as the conciliation between personal and professional life. conciliation between personal and professional life, and to prevent occupational hazards in order to ensure health and safety in the workplace. health and safety in the workplace, in compliance with current occupational risk prevention regulations. prevention of occupational hazards.

6. Respect for the dignity of persons

ESIC expresses its respect for all the people who make up its Learning Community. It is against any type of discrimination and harassment, both in the professional and academic spheres, due to any factor that is ethically any factor ethically contrary to the principles of this code.

Through a regulation that develops this code, ESIC will establish specific guidelines for the different members of its community to community members to ensure the correct coexistence among and with stakeholders. among and with stakeholders.

7. Respect for equality

ESIC works to generate a favorable environment that facilitates and enhances equal opportunities, non-discrimination, plurality and inclusion of all its members. Respect for the respect for the uniqueness of each person and the recognition of the richness of a plural community, ESIC implements policies that reinforce a wide and varied training offer, accessible to all people, as well as an and a work, academic and social environment where plurality is not only respected but also encouraged. plurality is not only respected but also encouraged.

C. Honesty

8. Academic freedom

ESIC encourages the academic freedom of its faculty in the different disciplines, as well as in the areas of research linked to teaching. areas of research linked to teaching. In this way, professors are free to disseminate the results of their studies as part of the knowledge they offer to students. to disseminate the results of their studies as part of the knowledge they offer to their students and thus contribute to quality teaching through different teaching methodologies and academic and business research. academic and business research.

9. Intellectual and industrial property

Members of ESIC's Learning Community must respect the intellectual property and the rights or licenses for use rights or licenses of use owned by ESIC with respect to any work, program or work created or developed in or for ESIC, limiting their use to the sole created or developed in or for ESIC, limiting their use solely and exclusively to the exercise of their professional and/or academic activity. professional and/or academic activity. Likewise, they shall respect the intellectual and industrial property rights of third parties. and industrial property rights of third parties.

10. Privacy

ESIC complies with current legislation on data protection and information security. Based on regulatory compliance and respect for privacy, honor, personal intimacy and self-image, ESIC has established different policies, regulations and self-image, ESIC has established different policies, regulations, procedures and measures to protect the confidentiality and security of the information measures to protect the confidentiality and security of the information, and to guarantee the correct use of the information correct use of the information related to identified or identifiable individuals. identifiable individuals.

All employees must be familiar with and comply with current data protection and information security regulations. information security. Likewise, they must know, comply with and apply the internal policies, regulations, protocols and procedures on privacy and confidentiality elaborated, communicated and published by ESIC, communicated and published by ESIC.

11. Transparency

In accordance with current regulations and following the indications of the management bodies of ESIC, periodically render accounts, providing the updated information necessary for the proper functioning, monitoring and control of the activity. for the proper functioning, monitoring and control of the activity. This information must be accessible to interested parties when requested, within the limits of professional secrecy and intellectual property. professional secrecy and intellectual property.

D. Commitment

12. Professional excellence

The highest standards of academic and professional excellence will be constantly sought, promoting the joint updating of knowledge and skills of the different professional categories, innovation and quality. innovation and quality. All conflicts of interest in the exercise of the professional or private of professional or private activity that may collide with the interests and values of ESIC will be avoided.

13. Social commitment

ESIC, without renouncing the ethical declaration of principles of this code and using it as a criterion of territorial presence, is involved in a socially responsible territorial presence, is involved in a socially responsible action in compliance with the law of the countries in which it operates and, in particular the law of the countries in which it operates and, in particular, assumes responsibility for respecting the cultural cultural peculiarities and customs of the people and communities affected by its activities. its activities.

ESIC and its employees deploy their values with responsibility and commitment to work, aware of the importance and impact that the training of people has on all facets of life. facets of life. Therefore, the leadership to be exercised will be responsible and coherent with the social function that ESIC fulfills ESIC's social function, contemplating its impact on students, faculty and employees, other stakeholders and society in general. other stakeholders and society in general.

ESIC is committed to train and raise awareness among its students so that they understand the need to get involved and work for a more just, egalitarian and sustainable society. and work towards a more just, egalitarian and lasting society, facilitating, to the extent possible, spaces for reflection and social of its possibilities, providing spaces for reflection and social participation, with its own projects and through collaboration and through collaboration with agents and institutions of civil society that share the same interests and purpose. the same interests and purpose.

14. Care for the environment

ESIC and all its members have the responsibility to know the regulations that protect the environment, as well as to act with respect and care for it. the environment, as well as to act with respect and care for it. In addition, it is contemplated the environmental management system, based on a policy and developed through internal rules and procedures and supplier relations and supplier relationship standards and procedures, aimed at identifying and minimizing the environmental impact of its operations. and minimize the environmental impact of its different activities.

Members of ESIC's Learning Community must follow the guidelines in this area and strive to minimize the environmental impact of their activities by using the equipment, equipment, equipment and materials they use. to minimize the environmental impact of their activities by using the equipment, facilities and means of work as efficiently as possible. facilities and means of work in the most efficient way possible.

Contracting managers shall convey to suppliers, contractors or external collaborators the need to align themselves with these principles and shall require them to comply with them. external collaborators, the need to align with these principles and require them to comply with the relevant environmental compliance with the environmental procedures and requirements applicable in each case.

ADHERENCE TO THE CODE

Disclosure and acceptance of the code

All members of the ESIC Learning Community must be familiar with the contents of this code, as well as its application to institutional conduct. and its application to institutional conduct, and should always be considered in conjunction with other specific institutional specific institutional policies and norms in each area of action. At the same time, other guidelines other guidelines that guarantee the coexistence of all members of the institution will also be taken into account. members.

ESIC employees and managers must expressly accept and ratify the principles set out in this code. established in this code.

In order for this commitment to ethical and responsible action to be known by all ESIC stakeholders, the code will be made known through the relevant channels, such as ESIC's stakeholders, the code will be made known through the relevant channels, such as the ESIC website, where it must be made public at ESIC's website, where it must be made public. In addition to its dissemination, ESIC must implement training and awareness awareness-raising and training activities to ensure its understanding and correct application by all ESIC employees. and correct application by all its members.

This code must be evaluated and updated at least every two years and approved by ESIC's governing bodies. by ESIC's governing bodies.

2. Ethics Committee. Ethics Channel

To ensure proper compliance with and development of the code, the ESIC Ethics Committee has been created, The objectives of this committee will include the dissemination, guidance, supervision and control of compliance with the code, as well as the the code, as well as the resolution of any incident that may arise in relation to its application. with its application.

The Ethics Committee will be made up of the General Secretary's Office, the Sustainability Department, the Human Resources Department, and three other experts in the field (one from ESIC University, one from Human Resources Management, and three other experts in the field (one from ESIC University, one from ESIC Business School and one from ESIC Escuela Superior de Ciclos) appointed by the ESIC Business School and another from ESIC Escuela Superior de Ciclos) appointed by ESIC's corporate management. ESIC corporate management.

Likewise, with the twofold objective of making it possible to consult on matters related to this code, as well as to facilitate the possibility of preventing and/or communicating irregular behavior, the code, as well as to facilitate the possibility of preventing and/or communicating irregular behavior, and/or any non-compliance with the code, a confidential Ethics Channel has been established, with email address: canaletico@esic.edu.

3. Obligation to report

All members of the ESIC Learning Community share the obligation to collaborate in the prevention of irregular behavior. prevention of irregular behavior. All good faith reports will be treated with due confidentiality and the protection of the confidentiality and the protection of the whistleblower will be guaranteed. Correlatively, any manifestly false or manifestly false or made in bad faith may give rise to the initiation of disciplinary proceedings and to the disciplinary proceedings and the adoption of the appropriate legal measures.

4. Non-compliance with the code

This code has a guiding and preventive character. However, any principles and values and values contrary to this code that are transformed into actions may be subject, where appropriate, to disciplinary sanctions disciplinary sanction in accordance with the internal regulations detailed in the different ESIC regulations. regulations of ESIC.

When these actions are not only ethically reprehensible, but may also constitute an infraction, the current sanctioning infringement, the current sanctioning regulations shall be applied, regardless of any other legal liabilities that may have been incurred. other legal responsibilities that may have been incurred by the offender.