1. INTRODUCTION

(1.1.) The purpose of this Code of Ethics and Conduct is to set forth the values, principles and principles of the Code of Ethics and Conduct. standards that must govern the behavior and actions of each of the employees and managers of the company. Voilabeauty SL (hereinafter referred to generically as the entity) as well as and the members of its administrative body1. Ethical behavior goes hand in hand with beyond formal compliance with the law, therefore any person who agrees to work for the Voilabeauty SL, accepts the commitment to act correctly. In addition, this Code also The same shall apply to its business partners, customers and suppliers, to the extent that the values, principles, principles and standards contained in this Code may apply to them. Voilabeauty SL will encourage business partners to develop and implement ethical programs consistent with our values and principles.

(1.2) The values that guide the work of Voilabeauty SL are the following:

People-oriented: the company’s main asset is its people . people: customers, employees and suppliers. Treat everyone with dignity, valuing their contributions to the achievement of the human and business success will be a priority for the company.

Integrity: Promote a culture of integrity, honesty and respect for legality and the rules and regulations of the law. ethical standards, both with regard to the interests of Voilabeauty SL as well as those of Voilabeauty SL. other stakeholders.

Environmental responsibility: sustainability, respect for the environment and reduction of environmental impact environmental footprint is a commitment that cannot be postponed because everyone has a shared responsibility in the development of present and future generations.

(1.3) Voilabeauty SL will promote the knowledge of the Code among employees and subjects before described so that their actions are governed by the principles and values on which this document is based. Code. The proper application of the Code requires knowledge on the part of the employees and of its contents, that of its complementary developments (policies and procedures) and that of its the relevant legal provisions applicable to the activities carried out by the company. as a result of their functions in the entity.

Any doubt about the interpretation or content of the Code or that refers to the manner of situations not specifically described therein, shall be clarified with the Compliance Committee, with the corresponding hierarchical superior or, as the case may be, with the Compliance Committee. administrative body. (1.4) Without prejudice to any other liability that may arise, failure to comply with the criteria and guidelines contained in the Code may result in the adoption of disciplinary sanctions that may be applicable in accordance with the provisions of the labor legislation. Specifically, infringements of the rules of conduct contemplated in This Code are serious infractions.

2. SCOPE OF APPLICATION AND ACCEPTANCE

2.1. SUBJECTIVE SCOPE OF APPLICATION

(1) This Code of Conduct shall apply to the following persons, whether they are or legal entities, as the case may be:

1.- EMPLOYEES, regardless of the type of contract that determines their employment relationship, position they occupy or the geographic area in which they work.

2.- MANAGERS: a) those who have employment contracts with Senior Management. Address; b) the Corporate Director; c) those who are expressly determined by the governing body of the administration.

3º.- MEMBERS OF THE COMPANY’S MANAGING BODY, regardless of its composition, form and operating regime of the body in question.

4º.- CUSTOMERS AND SUPPLIERS to the extent that they may be applicable and provided that Voilabeauty SL. has the capacity to make it effective by means of adhesion.

(2) The subjects referred to in paragraphs (1) to (4) above shall be collectively referred to as the “Obligated Subjects. The group of individuals and legal entities included in the The subjective scope of application shall be referred to as the “Addressees” of the Code.

2.2. ACCEPTANCE AND COMPLIANCE

(1) Voilabeauty SL shall adopt the necessary measures to give effect to the set of values, principles and the norms that make up this Code, disseminating its contents among those to whom it is addressed, and resolving any doubts that its application may generate. To this end, it shall endeavor, insofar as possible, to possible, that the regulated entities and the rest of the addressees commit themselves to their compliance, so that the values, principles and standards, together with the regulations applicable in each case, govern the performance of their duties. activities within the entity or its commercial or institutional relations with it.

(2) No one, regardless of his or her position in Voilabeauty SL, is authorized to request from a recipient of the Code of Ethics and Conduct that contravenes its provisions. No regulated entity may justify conduct that violates the Code or misconduct that is contrary to the Code. practice on the basis of a superior order or ignorance of the contents of the Code.

(3) The content of the Code of Ethics and Conduct shall prevail over the content of those internal regulations (including verbal orders that may be given by a superior officer) that could be used as a basis for The company may not contradict it, unless they establish more stringent requirements of conduct.

(4) The application of the contents of this Code shall in no case give rise to the violation of applicable legal provisions. If such a circumstance is found to exist, the contents of the Code shall comply with the provisions of the aforementioned legal provisions.

(5) This Code does not modify the employment relationship existing between the entity and its employees, nor does it creates no contractual right or obligation, but assumes that the rules of conduct indicated The terms and conditions of the employment relationship are integrated into the manner in which the employment relationship is to be performed.

(6) The entity does not tolerate the commission of any criminal act by any employee or member of its governing body, or when its commission is carried out by third parties with intention to directly or indirectly benefit the entity.

The entity will strive to do not only what is legal, but also what is right, precisely for this reason it will not allow any crime to be carried out in our name.

2.3. RESPONSIBILITY FOR COMPLIANCE WITH THE CODE OF CONDUCT.

(1) All officers have the following duties:

a) To communicate the Code of Ethics and Compliance to the teams.

b) Leading compliance by example.

c) Support their teams in the ethical dilemmas that may arise at any given time.

d) Correcting deviations detected in compliance with the Code.

e) Establish, in a timely manner, mechanisms to ensure compliance with the Code in its areas of responsibility. responsibility.

f) To report on processes and actions contrary to the provisions of this Code.

(2) All employees are subject to compliance with the following obligations:

a) Be familiar with the Code of Ethics and Conduct and make their decisions in accordance with these principles and with the policies that emanate from them.

b) In addition, they must immediately communicate in a responsible manner any indication of the existence of processes and actions that contravene the provisions of this Code.

c) Collaborate in investigations and audits.

d) Non-observance by managers and employees of the Code of Ethics and Conduct and of the rules and regulations of the Company. The development of specific policies, duly communicated, could result in the development of the opening and initiation of the internal corporate investigation procedures to be established by the administrative body, even leading to disciplinary dismissal.

3. ETHICAL AND RESPONSIBLE BEHAVIOR (STANDARDS OF CONDUCT)

3.1. GENERAL PRINCIPLES

(1) All Regulated Entities are responsible for knowing and complying with the laws applicable to their function. according to their area of responsibility and place of work, and must fulfill their functions and obligations. in full compliance with the procedures established in the sectors of its activity.

(2) In case of doubt, the Obligated Subjects may obtain assistance on how to comply with the content of this Code and other applicable regulations through its superior. hierarchy or, as the case may be, through the Compliance Committee.

(3) Failure to comply with these regulations could give rise to legal liability that may The Company shall not be liable for any disciplinary action, including termination of employment. (4) In addition to complying with this Code and the applicable rules in each case, all Subjects shall Obligors shall at all times demonstrate ethical behavior in all their actions. and avoid any conduct that, even if not in violation of the law, may damage the reputation of the company. and negatively affect the entity’s interests, reputation and public image (as could be the case with the inappropriate use of social networks).

3.2. RESPECT FOR THE LAW

In the performance of its professional duties, no Obligated Subject shall knowingly collaborate with third parties in violation of any national or international law, nor will it cooperate with them in actions or omissions that compromise the principle of legality or that could, if known, harm the reputation of the entity.

3.3. HONESTY

(1) The Regulated Entities shall be honest in all negotiations in which the interests of the Company are involved. entity at stake and will comply with the commitments acquired.

(2) Covered Entities shall avoid, or, as the case may be, declare, any conflict of interest that The company’s employees shall not be allowed to put personal priorities before the collective ones and shall behave with rectitude, without seek in any case to benefit themselves or third parties through the due use of their position or contacts at Voilabeauty SL, to favor him or a third party over others, in breach of his or their obligations in the purchase or sale of goods or in the contracting of services professionals.

(3) Likewise, they shall protect the confidentiality of the entity’s information that has been provided to them. entrusted, as well as those related to customers, shareholders, employees or suppliers.

3.4. INTEGRITY

(1) Voilabeauty SL is subject to a strict policy of not accepting or offering gifts, donations, or in-kind donations. in kind or in cash. It is a conduct contrary to the Code of Ethics and Conduct, and it may even become criminal, the offering of gifts, invitations or presents to third parties (whether officials or not) with the intention of influencing them to perform their duties dishonestly or under conditions more favorable than to other customers, or to thank them for acting in this way even if they do not previously suggested it, or in general to act in a way that is contrary to the law in force.

(2) Knowledge of any conduct that may be contrary to the standards of conduct of behavior and responsible will be immediately notified through the whistleblowing channel to the Compliance Committee.

(3) Exceptionally, the regulated entities may accept gifts, invitations, services from hospitality or other inducements that do not exceed customary, social or courtesy usage, and are related to the commercial activity.

(4) The corporation shall not make donations in cash or in kind of any kind whatsoever to political parties, organizations, movements, entities, whether they are of a political nature, or of a public or private, whose activity is clearly linked to political activity.

(5) The right of employees and managers to exercise freedom of expression and to participate in political activities, but provided that they do not interfere with professional performance, nor entail a conflict of interest. Under no circumstances will the resources or facilities of the organization to support personal political activities.

(6) These prohibitions do not apply to sponsorship activities carried out in accordance with the law. in force.

4. COMMITMENT TO EMPLOYEES

4.1. Human rights

(1) Voilabeauty SL considers that the Obligated Parties are essential collaborators in order to fulfill the objectives of and the creation of quality employment in an environment that is committed to training and professional development and the promotion of diversity of skills, cultures, beliefs and nationalities, all of which are on equal terms and rights and with an express rejection of any form of harassment in the workplace. For this reason, as relations between all employees must always be based on respect for the dignity and non-discrimination of all employees. people.

(2) The entity recognizes that the principle of equal treatment and equal opportunities for Employees, regardless of race, color, nationality, ethnicity, religion, gender, orientation, or sexual orientation. political or sexual orientation, marital status, age, disability or family responsibilities, it is a principle The Human Resources policies will be inspired by the Human Resources policies and will be applied to the hiring of new employees. employees, such as training, career opportunities, salary levels, as well as the other aspects of the Employees’ labor relationship.

(3) The exercise of the rights of association shall in no way be prevented or restricted, and collective bargaining within the framework of the regulations governing each of these areas. fundamental rights.

(4) Voilabeauty SL will respect and promote Human Rights. Recognizes that human rights are fundamental and universal rights, which must be interpreted and recognized in accordance with the laws of the country. international practices, in particular the Universal Declaration of Human Rights of the United Nations and the Universal Declaration of Human Rights of the United Nations and the principles proclaimed by the International Labor Organization.

4.2. Professional development

(1) Voilabeauty SL will promote the personal and professional development of its Employees, fostering their involvement in the improvement of their own capabilities and competencies. Policies and actions relating to the selection, recruitment, training and internal promotion of employees must be based on clear criteria of capacity, competence and professional merit. See shall take into account the internal promotion of Employees to fill the positions that in each case convenient.

(2) Employees shall be informed of the policies for the evaluation of their work and will actively participate within the framework of the management processes articulated to improve their work, initiative and dedication.

4.3. Commitment to people’s health and safety

(1) Voilabeauty SL shall ensure a safe and healthy working environment for Employees, adopting all reasonable measures to maximize the prevention of occupational hazards. In addition, the entity shall provide the necessary means for the due compliance with the measures deemed necessary for the to prevent occupational hazards.

(2) All Employees shall be responsible for maintaining their place of work, following the rules and health and safety practices.

(3) It shall constitute a breach of this Code for any person to employee of the functions entrusted, without respecting the occupational risk prevention measures foreseen. for their job and the non-use of the PPE provided to them when it is necessary to do so. mandatory. In addition, the entity shall provide the necessary means for the due compliance of the measures deemed appropriate to prevent occupational hazards.

(4) The consumption of alcoholic beverages during working hours is prohibited, to the extent that ingestion may jeopardize safety and productivity in the work environment and the maintenance of the professionalism and responsibility of the Employees.

The use of drugs is strictly prohibited on the premises of Voilabeauty SL.

4.4. Commitment to workplace harassment

(1) GVoilabeauty SL rejects any kind of harassment in the workplace (abuse of authority, physical or sexual harassment). psychological harassment, sexual harassment, as well as any other conduct that could generate a work environment that is intimidating, offensive, or hostile to persons) as unacceptable and intolerable; and not will allow behaviors or organizational factors that reveal harassing behavior in the workplace. work environment.

(2) The following shall constitute a breach of this Code and may constitute an infraction serious or even criminal offence, any harassing behaviour, including expressly uttering expressions of insulting, offensive, defamatory, or degrading character, with respect to other colleagues -either directly or indirectly or indirectly-, and whatever the medium used -verbal, SMS, whatsapp, email, etc.-. or adopt inappropriate behaviors that impede the normal performance of work.

5. COMMITMENT TO THIRD PARTIES

5.1. CUSTOMER ENGAGEMENT

(1) The entity considers customer satisfaction a priority. As a result, the efficiency of the processes and transparency in performance, as well as the provision of clear information on the and truthfulness, and the provision of a treatment that guarantees the quality of customer service, must be ends in themselves. same for all employees of Voilabeauty SL.

(2) Every effort shall be made to ensure that the products offered do not entail risks for the health, taking the appropriate actions to resolve them.

5.2. COMMITMENT TO SUPPLIERS

(1) The entity shall deal with suppliers of goods and services in an ethical and lawful manner; select only suppliers whose business practices respect human dignity, do not violate the law and do not jeopardize the reputation of the company.

(2) All suppliers shall be operating in full compliance with the laws in force. They should respect the observance of internationally recognized human rights and to ensure that they do not defraud or abuse these rights within its business operations, nor within its own structure. organizational.

(3) Every supplier shall promote and respect the following principles:

a) Eliminate all forms of child labor.

b) Eradicate any type of forced or coerced labor.

c) Avoid discrimination in any type of work position.

d) Respect the maximum working hours and minimum wages established.

e) Guarantee that its employees develop their work under safety and hygiene standards.

f) Respect the rights of employees to associate, organize or bargain collectively without suffering as a result. any kind of sanction.

g) Obtain and maintain environmental permits for the operation of its business if required. Likewise, in the event that its operation generates waste, such waste must be supervised, controlled, and and treated in the manner indicated by the corresponding legislation.

(4) Suppliers shall be responsible for ensuring that subcontractors work in accordance with the following standards promoted by this document and within the corresponding legal framework.

(5) Providers must maintain a preventive approach to the protection challenge. adopting methods that benefit a greater environmental responsibility and favor the development and diffusion of environmentally friendly technologies.

(6) Every supplier shall avoid being a participant in any type of corruption, extortion or bribery that might affect the principles of fair trade or result in public scandals in which the entity could be affected. Each supplier agrees that its participation in any of the events listed at is cause for immediate termination of the contract. that links you to Voilabeauty SL without being able to claim any compensation as a result.

(7) Voilabeauty SL will positively value those suppliers that express their commitment to the principles promoted in this Code of Ethics and Conduct through acceptance and compliance. Likewise, and apart from the above, Voilabeauty SL reserves the right to terminate its contractual relationship with those suppliers who are in breach of the Code in a repeated or serious manner, and may claim compensation for damages (including moral damages, if any).

(8) Voilabeauty SL will endeavor to extend the contents of this Code of Conduct to its suppliers. incorporating the Code itself into the contracts it enters into with them.

6. COMMITMENT TO THE ENTITY’S ASSETS, KNOWLEDGE AND RESOURCES

6.1. Protection of personal data

(1) The entity shall ensure the protection of personal data that is stored and exchanged in the course of the daily activity in the development of social business to the extent that such protection is The company’s priority is to achieve the highest level of quality in the development of its corporate purpose. For this reason all managers and employees must always comply with the legislation on the protection of personal data. personal data. In order to comply with the above, training policies will be adopted.

(2) The following shall constitute a breach of this Code, without prejudice to possible criminal liability The discovery or disclosure of personal information (e.g., the discovery or disclosure of personal information): bank account numbers, personal data such as dates of birth, anniversaries, addresses, phones…) of other employees, customers or suppliers and of which you are aware. solely for the work and function performed in the entity.

6.2. Proper use of computer tools

(1) Employees will make use of IT tools (e-mail, intranet, etc.), internet, telephones…) in conditions that are in accordance with the development of the position and with the functions that play. They shall not be used in an abusive manner, or for their own benefit for actions that could affect the reputation or image of the entity.

(2) Employees shall only have access to computer systems that are being accessed by the employee. authorizing and with the appropriate licenses. The following shall not be installed, used or distributed any software that could affect the security of the systems, nor may copies be made of any software that could affect the security of the systems, nor may copies be made of any software that could affect the security of the systems. unauthorized or perform actions that allow the entry of computer viruses.

(3) Serious non-compliance with this Code shall be constituted by a breach of the measures provided for in this Code. in the security document relating to IT tools (e.g.: disclosure of passwords, etc.). and passwords to access their own or third parties’ computer equipment, which can lead to leaks. information; downloading of programs or software that may contain elements that may contain elements that could damage to operating systems, access to disreputable websites, unauthorized copying, unauthorized files or files contained in the company’s terminals in USB or send them in an unauthorized way to a third party. personal computer).

(4) The communications that could be made through computerized tools (including especially corporate e-mail) must not contain offensive or offensive statements, and must not contain defamatory. The user of any computer or communication media owned by the company shall not use any of the following entity may not disclose or transmit unlawful, sexist, abusive, defamatory, obscene information, racist, offensive, pornographic, or any type of offensive information or information not authorized by the Laws, either through photographs, texts, advertising banners or links to web pages. external: you may also not publish, transmit, reproduce, distribute or exploit any other component harmful to the integrity of computer systems or that may infringe proprietary rights. Similarly, they may not publish or provide material or access to resources on hacking, craking or any other information that Voilabeauty SL considers susceptible, even if it is potentially compromise the security or integrity of computer systems.

6.3. Protection of confidential information

(1) Both employees and officers shall maintain the strictest professional and professional secrecy. keep confidential all information they handle in the course of their professional work. (2)Throughout the following rules shall apply to the handling of the information confidential:

a) All information will be protected and kept strictly confidential. It will not be used, in whole or in part, for a purpose other than that to which the obligated entity was assigned based on of its work.

b) Confidential information will only be used by the obligated entity for the purposes for which it was provided. assigned to him/her according to his/her employment contract or the relationship that links him/her to the entity. In the event that the obligated entity requires the assistance of a third party to the entity and it is necessary to disclose to it the information, the necessary measures shall be taken to ensure that the information is kept confidential. duly protected, by signing a confidentiality document to that effect.

c) The obligated entity shall not disclose, directly or indirectly, the information to third parties. other than those referred to in the preceding paragraph.

d) The obligated entity shall notify, as soon as possible, any incorrect processing or use of confidential information, cooperating with the entity in order to protect such information.

e) No obligated entity shall store information about the entity in private or other computers. means not provided by the company itself.

f) In the event that the obligated subject has to take the information outside the facilities of the entity to perform work tasks or those that are inherent to their relationship with the entity. return such information upon completion of off-site work.

6.4. Misappropriation of assets

The entity provides its employees with the necessary resources for the performance of their work. professional activity. Misappropriation and inappropriate use of these assets will be criminally prosecuted.

7. OBLIGATIONS WITH RESPECT TO FRAUDULENT OR UNETHICAL PRACTICES

7.1. Manipulation of information

(1) The falsification or manipulation of information, or the deliberate use of false information constitutes unlawful conduct and in many cases a crime. The entity assumes a principle of transparency of information, understood as the commitment to transmit the information reliable information to the markets, both financial and otherwise. In this way, the economic and financial information of the company, both internally and externally, The financial statements shall faithfully reflect its economic, financial and equity reality, in accordance with the principles of generally accepted accounting principles.

(2) The regulated entities must transmit the information in a truthful, complete and understandable manner. At in any case knowingly provide incorrect, inaccurate or imprecise information. In this sense managers and employees shall refrain from:

a) Keep a record of transactions in off-balance sheet items not recorded in official books.

b) To record non-existent expenses, income, assets or liabilities.

c) Making entries in the accounting books with an incorrect indication of their purpose.

d) Use of false documents.

e) Deliberately destroying documents before the legally established deadline in each case.

(3) It shall be a breach of the Code to carry out business transactions that are not in compliance with the Code. the recording of unrealized expenses, and/or making accounting entries with items that are not in accordance with the reality.

7.2. Bribery, corruption, kickbacks and influence peddling

(1) Any practice of corruption, bribery or payment of commissions in all its forms is prohibited. by acts or omissions or by the creation or maintenance of situations of favor or disfavor. irregularities with the objective of obtaining some benefit or profit for the entity.

(2) Obligated entities shall refrain from making payments to facilitate or expedite procedures. the delivery of money or goods in kind, regardless of their amount, in exchange for insuring or to expedite the course of a proceeding or action before any judicial body, public administration or official body.

(3) It is forbidden to exert any kind of influence (direct, indirect, through third parties) on any official or authority derived from the personal relationship of any obligated subject.

7.3. Money laundering and irregularities in payments

(1) The Employees of Voilabeauty SL shall pay special attention to cash payments that are unusual in view of the nature of the transaction, to those made by bearer checks or to those made in currencies other than those previously agreed upon, communicating through the following channels and procedure set forth in this Code of Ethics and Conduct those that he understands to be irregular. No cash payments in excess of 1,000 euros (or its equivalent in euros) will be accepted. foreign currency); nor payments for lesser amounts in 500 euro banknotes.

(2) Payments where the payer or payee is a third party other than the payer or payee shall also be reported. mentioned in the corresponding contracts, as well as those made in accounts that do not result in the usual in dealings with a particular entity, company or person.

8 BODY IN CHARGE OF REGULATORY COMPLIANCE IN THE AREA OF CRIMINAL RISKS

(1) The body in charge of compliance with the Code of Ethics and Conduct, as well as with the model The Compliance Committee (CC) is responsible for criminal risk prevention, by express delegation of the Board of Directors of the entity.

(2) The CC shall be composed of three members: the person in charge of the internal legal counsel (who will act as Chairman), a member of the administrative body (who will act as Chairman), a member of the administrative body (who will act as Chairman), a member of the administrative body (who will act as as a member), and an external professional (who will act as secretary), who will have to accredit sufficient legal knowledge and practical experience as a criminal defense attorney of at least of 10 years.

(3) The CC shall submit an annual report to the board of directors on the development of the criminal risk prevention policy. The management body shall evaluate and The criminal compliance management system shall be monitored at least once a year, unless any of the parties has circumstances make it advisable to shorten this period.

(4) The CC shall be responsible for proposing to the administrative body any policies necessary for the development of the Code of Ethics and Conduct and, in general, for an efficient and effective criminal risk management.

(5) In any case, the ultimate responsibility for overseeing the proper execution of the The Compliance Program is the responsibility of the organization’s management body.

9. COMPLAINT PROCEDURE

(1) All directors, officers and employees of Voilabeauty SL have the obligation to comply with the following obligations contribute to the compliance of the criminal compliance system. That is why, not only do they have to know their Code of Ethics and Conduct to make their decisions in accordance with these principles and with the The company must not only communicate in a responsible manner any indications that it may be affected by the policies that emanate from them, but must also existence of processes and actions that contravene the provisions of this system.

(2) For this purpose, the organization has created a whistleblower channel which is available to all employees, managers, customers, suppliers (and even third parties outside the organization), and to the that they will have access when they have direct evidence of the existence of an act constituting a crime. carried out by an employee, officer, legal representative or attorney-in-fact of the entity, which could criminal liability of the entity, or that entails a behavior contrary to the principles contained in this Code of Ethics and Conduct.

You may report this fact through the following channels:

E-mail: compliance@voilabeauty.com 

Next mailing address: Voilabeauty SL,C/Flassaders 42, Barcelona, CP 08003, Barcelona, Spain to the attention of. Compliance Committee.

(3) The procedure for handling complaints shall ensure anonymity, confidentiality in all its phases and non-retaliation. Specifically, they shall be subject to the following principles: (i) confidentiality, (ii) respect for the persons involved, and (iii) guarantee of whistleblowers.

10. VALIDITY

This Code of Ethics and Conduct shall enter into force on March 30, 2022.

 

PROCEDURES FOR NON-COMPLIANCE AND IRREGULARITIES

I. General considerations

(1) All employees of the organization have an obligation to comply with and contribute to the compliance of the criminal compliance system. For this reason, not only do they have to know their Code of Ethics and Conduct to make its decisions in accordance with these principles and the policies emanating from them, but must communicate in a responsible manner any indications of processes and actions that contravene the provisions of that system.

(2) For this purpose, the organization has created a whistleblower channel which is available to all employees, directors, shareholders, customers, suppliers (and even third parties outside the company), employees, directors, shareholders, customers, suppliers (and even third parties outside the company), employees, directors, shareholders and organization), and to which they may have access when they have direct knowledge of the existence of an event. of a crime carried out by an employee, director, legal representative or attorney-in-fact of the company, or by an employee, director, legal representative or attorney-in-fact of the company. entity, which may generate criminal liability for the entity may be reported through the following ways:

E-mail: compliance@voilabeautycom

Next mailing address: Voilabeauty SL, C/Flassaders 42, Barcelona, CP 08003, Barcelona, Spain to the attention of. Compliance Committee.

(3) Without prejudice to the existence of the whistleblower channel, every employee shall ensure the integrity and reputation of the company. And in the event of a possible non-compliance with the Code of Ethics and The facts may also be reported to the hierarchical superior, so that he/she can be informed of these facts. immediately forward the information received to the Compliance Committee. Although it is advisable to centralize information through the complaints channel, they will continue to be attended to and investigated. facts that are reported through other channels that end up being brought to the attention of the Compliance Committee.

II. Basic operation of the whistleblower channel

(1) Without prejudice to the detailed operation of the whistleblower policy contained in document “Procedures for the investigation of non-compliances and irregularities”, any complaint. must be made in good faith and contain sufficient background information to initiate an investigation. research.

Good faith” communication implies that all available information is provided. honest, complete and accurate, even if it is later verified that it was wrong. The information provided “in bad faith” is subject to disciplinary action.

(2) Complaints shall, to the extent possible, contain the following information:

Identity of the persons of the entity involved. If no specific identification data are known, the following are used the facts that allow his identification (position held, place, day and time of the day and time of the the events that occurred).

Approximate date or dates on which the events occurred.

Minimal description of what happened

If evidence is provided (documents, photos, videos, etc.), indicate the source of the evidence (who, who, what, etc.). who took the photographs or recordings, who delivered the documents…).

Information on possible witnesses may be provided, indicating, if applicable, their knowledge of the facts.

In general, any other circumstance related to the reported facts.

(3) Graphically, the general scheme of operation of the complaints channel would be as follows:

COMPLAINT –> INITIAL FEASIBILITY ANALYSIS –> INVESTIGATION INTERNAL –> PROPOSAL TO THE GOVERNING BODY –> CONCLUSION

(4) The procedure for handling complaints shall ensure anonymity, confidentiality in all its phases and non-retaliation. Specifically, they shall be subject to the following principles:

a) Confidentiality: the data and statements made will be examined with strict confidentiality. All persons who need to know its contents are subject to a confidentiality commitment. The data of the complainant may only be provided if required by law and upon request by the complainant. by the competition authority.

b) Completeness: information received on potential non-compliance with the Code of Conduct (and in general on any policy or procedure relating to the compliance management system The criminal investigation) will be thoroughly and completely investigated to determine the veracity of the situation. reported.

c) Respect for the persons involved: at all times, the rights of the persons involved shall be taken into consideration. of those involved in potential non-compliance. Before making an assessment of the situations declared, the persons and/or employees affected shall have the right to transfer the reasons and explanations they deem necessary.

d) Substantiation: any decision shall be made in a reasoned, proportionate, appropriate, and considering the circumstances and environment of the facts.

(e) Whistleblower guarantee: persons who report in good faith (or on the basis of a good faith report) are assured of the following (a reasonable belief) unethical acts or acts that violate the Code of Ethics and Business Conduct. Conduct (and in general on any policy or procedure relating to the management system for the compliance), who will not suffer retaliatory, discriminatory or disciplinary action of any kind. for reporting violations of the crime prevention policy or for refusing to participate in a criminal criminal activities. This warranty does not extend to cases in which the person in question that The complainant has participated in the non-compliance. Nor will any retaliation be tolerated against who collaborates in an investigation of a breach. Any act of reprisal, or the mere threat of reprisal, or the mere threat of reprisal, or the mere threat of retaliation will be considered a serious violation of the Code of Ethics and Conduct. and subject to disciplinary action.

 

ANTI-CORRUPTION POLICY

I. General considerations

(1) This policy develops the basic principles in this area, with the aim of establishing a and directors, which serves to prevent, detect, investigate, investigate, and bring to the attention of remedy any corrupt practices within the entity. Unlike other policies, it has been using an expository methodology based on questions-answers, and with the exemplification of many assumptions so that the target audience can easily identify the fundamental elements of the duties of ethical behavior and integrity.

(2) Integrity in professional performance is one of the basic principles of performance. reflected in our Code of Ethics and Conduct, and manifests itself in certain duties of and management, as well as by our business partners, to ensure the highest level of performance, both on the part of our employees and management, and on the part of our business partners. relevant.

(3) As acknowledged in the Code of Ethics and Conduct, Voilabeauty SL is subject to a strict policy of not accepting or offering gifts or donations, either in kind or in cash. It is it is prohibited to offer gifts, invitations or presents to third parties (whether they are officials or not) with the purpose of to influence them to perform their duties dishonestly or under more favourable conditions. favorable than to other customers, or to thank them for acting in this way even if they had not been previously suggested, or in general to act in a manner contrary to the law. The subjects obligated parties may also not promise, offer or grant to directors, officers, employees or employees of a commercial enterprise or of a company, association, foundation or organization an unjustified benefit or advantage of any nature whatsoever, to favor him or a third party others, by failing to comply with their obligations in the purchase or sale of goods or in the contracting of professional services.

(4) Knowledge of any conduct that may be contrary to this policy The anti-corruption committee will be immediately notified through the whistleblower channel. of Compliance. In case of doubt as to the permissible or prohibited nature of a course of conduct, it shall be The Compliance Committee shall be informed.

II. Compliance with anti-corruption policy

(1) If you are ever unsure about how to react to a situation, or if you are in doubt as to whether or not conduct may be improper or contrary to policy, you should always seek the guidance from your supervisor or the Compliance Committee prior to carrying out any of the following activities any action. If you observe a behavior that concerns you, or that according to your understanding may represent a violation of our policy, please raise the matter immediately to the Compliance Committee. In doing so, you will provide the entity with a opportunity to assess the matter and correct it before it becomes a violation of the law or before that entails a risk to the Company’s reputation.

(2) Suspected breaches of policy of a certain significance, such as exemplified by those involving high levels of management, significant amounts, or even the The commission of criminal acts must be reported immediately to the Compliance Committee.

Practical example: a person from the financial area was requested by his superior to proceeded to make a bank transfer of funds to a personal account of a public official. When that person asked his superior what the payment was for, his superior told him that “it was not for was their business. When he expressed his concerns about whether the act might be illegal, he told him said that he did not care what the politics said and that he assumed all the responsibility for the liability if there were any problems with payment. The person in the financial area is afraid of that her superior will retaliate against her if she reports the matter.

How to react: the person in the financial area should immediately report this The company’s compliance with this situation through the Compliance Committee’s whistleblower channel. If you follow the instructions of your and violates the Anti-Corruption Policy, both of which would likely be in violation of the law. in addition to violating the Policy and the Code of Ethics and Conduct. The The Company will protect this person from any retaliation for his or her good faith reporting and will probably sanction the superior.

(3) No employee shall ever be penalized in any way, for refusing to pay bribes or illegal payments. In the same way, their work or economic results will not be negatively evaluated. because delays or losses have occurred as a result of your refusal to pay. An element with the that an employee must have in advance is that he or she will not be confronted with situations in which he or she will have to face require a bribe or illegal payment to process an application.

(4) The Company applies a “zero tolerance” treatment to violations of this policy. Policy. All employees and managers are obligated to uphold the standards ethical policy, and must take the necessary steps to prevent any violations of the same. The company’s employees will be sanctioned and, if necessary, dismissed in the following cases of willful disregard of this policy, including the failure to report the existence of known violations. In the event of a violation of this policy by any of the following persons who work for the Company but who are not employees of the Company, it may be possible to resolve the contract or terminate their relationship with the company.

(5) Such infringements may be reported to the public bodies in charge of the investigation of criminal acts, where appropriate, in such a way that it can be investigated in an criminal process. Bribery and illegal payments are crimes punishable by imprisonment.

(6) The policy applies to all persons working for Voilabeauty SL, irrespective of their location, position or category. This includes both employees (irrespective of the type of contract) and employees who are the Company, as well as officers, members of the Board of Directors, and directors of the various persons The company’s legal entities that are located within the perimeter of the organization. And it also includes the agents or third parties acting on behalf of any of the companies of Voilabeauty SL, who shall comply with the principles of this policy.

III. Basic concepts

(1) A bribery (or act of corruption) has a legal definition precise. But in order to understand what it consists of, it is important to know that it consists of giving, promising or promising to give. offer anything of value or any advantage, directly or indirectly, to any person, with the purpose of inducing that person to person or any other person to perform an improper function or activity, or to refrain from acting in the performance of their official duties, or in general with the intent to influence the behavior of another person or reward it, and thereby maintain or obtain a commercial advantage. Also it is a bribe to accept a request made by another person for the same purposes, i.e., to be act (or fail to act) improperly, both by the person accepting the request and by a third. Never participate in bribery.

(2) The forms in which a bribe or act of corruption may occur are many and include diverse: there is no list of behaviors. A bribe can have a financial content or any other kind of content. other, and includes giving or receiving money, loans, contributions or donations, travel, offers of employment, reimbursements, bonuses, goods, services or any other product or activity that may be considered as having value. Gifts, corporate hospitality and business invitations can be considered as forms of of bribes in certain circumstances. It is not permitted to solicit, accept or offer any token of hospitality. or gift, however small it might be, that could be understood as a form of persuasion or inappropriate influence, i.e., as a form of bribery. A bribe may also take the form of a incentive or award, and may be paid after the improper act (or omission) has been produced. The categories of prohibited conduct also include personal favors. The corruption channeled through personal favors is particularly difficult to detect, because they do not consume the organization’s resources and are not developed in the context of its activities. No However, they may be suitable for infringing on the independence of the recipient and, therefore, they are not in absolutely harmless. In the end, a personal favor can avoid an outlay (e.g., using the resort residential or a friend’s pleasure yacht) or even having access to a hard-to-get good or service. under normal conditions (access to a privileged seat at a concert, or a major sporting event, for example). example). Therefore, everyone in the organization must become aware that their activities in the private sphere may also affect the organization, when they are projected onto certain third parties.

(3) The entity makes no distinction between public officials or private individuals with regard to bribery. Bribery is not permitted regardless of the status of the recipient. Even if you should never offer or accept bribes from anyone, he or she needs to be particularly vigilant not to engage in no bribery, kickbacks or improper dealings with public officials. Do not offer, give, promise or authorize anything of economic value, or any other advantage to anyone (including a family member, relative or person related to a public official) if the circumstances appear to indicate that he or she is seeking the influence of the public official to obtain or maintain business or competitive advantage.

1. Who is a “public official”?

A civil servant does not necessarily have to be someone who works in the administration. public. Public officials include the following persons:

employees or representatives of any administration, public enterprise, governmental entity in anywhere in the world, including senior and junior employees. Governmental entities include, but are not limited to are not limited, to central banks, sovereign wealth funds, public hospitals, and any other business project owned or controlled by a governmental entity;

any individual exercising a legislative, administrative, or judicial function, whether by appointment or by election; – any candidate or holder of public office;

any office of a political party;

any officer, employee, representative or agent of a public international organization; or any person acting in an official capacity for a public organization international organizations such as the United Nations or the World Bank, the United Nations Development International Civil Aviation Organization, the Atlantic Treaty Organization, the International Civil Aviation Organization, the Atlantic Treaty North, Interpol…; any member of the royal family; and

any child, spouse, relative or sibling or any other family or analogous relationship to the above. It is your responsibility to know if the person you are dealing with is an official public. If in doubt, consult with the competent Compliance Committee.

2. Influencing a decision of a public official to gain an advantage.

Offering something of value or an advantage to a public official is also considered bribery. to influence some discretionary decision of the official, such as – by way of example example – the result of an inspection, a decision to reward or continue relationships the development or passage of any legislation that may directly or indirectly affect our business, or the development or passage of any legislation that may directly or indirectly affect our business. indirectly to the entity. Similar offers made to a private individual are also prohibited. provided that there is reason to believe that it is for the benefit (direct or indirect) of a public official. This includes relatives and close friends of the public official.

Practical example: a customs official performs a routine control of goods from The Company, upon its entry into the country, submits it to lengthy and complicated inspections. The customs official suggests that the Company make small payments to him, or that provide him with of free products, so that he treats the Company’s merchandise the same way he treats other shipments, refraining from inspecting them.

How to react: do not give the official any money, products or anything of value. This would be improper and illegal to grant anything of value or any advantage to the public official, even if it is he is unjustly targeting the Company’s merchandise performing inspections and controls different from the way it acts against other companies.

(4) In connection with dealings with public officials, there are certain rules of behavior that must be known.

You must not offer gifts or hospitality to public officials in exchange for any advantage or deal. favorable, or to influence any administrative decision, including to prevent you from doing something that would harm the company.

Practical example: The head of the local tax authority where the Company is located registered as a taxpayer, asks the company for certain products that can be obtained in the stations of services (beverages, cookies, toys…) for your child’s birthday party in exchange for closing a compliance inspection.

How to react: Politely explain that you are not authorized to provide products. or services of the Company, in accordance with the Anti-Corruption Policy and immediately report to the Compliance Committee.

A public official may be taken to a meal, but only if it is reasonable and appropriate He/she should not have to pay for the meal. meal for accompanying persons of public officials.

Practical example: A mayor is scheduled to attend the opening of a service station. After the opening, a manager intends to bring the public official and his companions to the nicest restaurant in town, with no limit to what they can order for lunch and dinner. drink, and give each of them an expensive branded watch.

How to react: It would be inappropriate to organize an expensive meal and provide clocks to the and their companions. The Policy would allow the Company to provide modest gifts (e.g., pens or umbrellas), particularly if these include the the Company’s brand or logo, and provide a meal if the circumstances of the visit so require. justify (it is reasonable to invite you to lunch if a meal is planned institutional, but usually according to a previously closed menu). Expenses incurred will be accounted for correctly identifying the concept.

As part of our commitment as a good corporate citizen, in certain circumstances, the following may occur charitable contributions. These contributions may be in the form of goods or services, technical assistance or training, financial support or event sponsorship. However, particular caution should be taken to ensure that the beneficiary entity is a bona fide organization, regulated and supervised in such a manner that there is no reason to believe that the entity may operate directly or indirectly to procure the benefit private of any public official. In the event that a public officer is a director or a director of the agent of the charity, or is otherwise closely associated with the charity, or expressly request that the Company make contributions to such entity, the Company must inform the Compliance Committee, who will advise you on what consultations or steps to take. to obtain a high level of assurance that the contribution will not be used for an undesirable purpose. payment prohibited.

Practical example: A high-level government official with whom you deal on a regular basis, asked if the Company could make a donation for blind children in a organization in which he participates as a volunteer.

How to react: You should consult with the Compliance Committee that will be in charge of your compliance will advise on what should be done (due diligence) to ensure that the The charity is a bona fide organization and that the contribution is not made in good faith. will be used for other purposes.

In connection with the payment of fees, public prices, permits and licenses, no payments should be made. beyond what is required by law or by local regulations, nor give any favor or advantage of any kind to public officials in order to obtain a permit, license, or any other administrative authorization. Sometimes this issue arises when the Company seeks to establish or expand a facility or obtain operating permits. No what are known as “facilitation payments” to officials to accelerate or to ensure compliance with a routine administrative procedure. Payment of public prices, fees and the like are not prohibited by this policy. If you have any questions about whether or not allows a fee for issuing a transaction with an entity, please consult with the Compliance. No payments or other advantages should be made or given to public officials for the purpose of to avoid an inspection, to influence the results of an inspection, or to avoid the imposition of a fine. During an inspection, you must treat the public official with correction, but without offering him anything of value, nor any advantage before, during or after the inspection. Such an offer, even if it is very small, could be interpreted as the existence of of an intent to influence the conclusions of the public official with respect to the inspection.

(5) The Company is also liable for bribes paid by third parties acting on behalf of the Company or for bribes paid by employees or other persons performing services for Voilabeauty SL. Therefore, you should never authorize or solicit any third party to perform services for Voilabeauty SL. employee or any third party to pay bribes to anyone (including public officials), or to receive bribes from no one. Nor may you monitor any activities of third parties acting on behalf of Voilabeauty SL, which you suspect may conflict with this Policy. Precisely in order to avoid these situations Voilabeauty SL has a specific policy of due diligence with the partners of Voilabeauty SL. business.

III. Acceptance of the anti-corruption policy by employees and business partners relevant

(1) All employees should receive a copy of this Policy and be informed that they are by signing Annex A (employees) as acceptance of their obligations to comply with it, by signing Annex A (employees) as acceptance of their obligations to comply with it, by signing Annex A (employees) as acceptance of their obligations to comply with its terms. are concerned. For operational purposes, a copy of this policy may be sent by mail to the following address corporate electronic system, but Exhibit A evidencing its actual receipt must be delivered physically and be received completed and signed in handwritten form. All employees must sign a statement indicating that they have read and understand the Policy and agree to the following comply with it. The employee statement is included in Appendix A. Compliance with this The policy is part of the obligations inherent to their employment contract, such that failure to comply with the The disciplinary regime provided for in the labor legislation will be applied and in the collective bargaining agreement applicable to the consideration of disloyalty or breach of trust in the entrusted to us.

(2) In relation to the relevant business partners of Voilabeauty SL, no business relationship shall be entered into with the relevant business partners of Voilabeauty SL. business relationship with third parties, unless they agree to a contract stating that they will not engage in a business relationship with third parties, unless they agree to a contract stating that they will not engage in a business relationship with third parties. permitting, soliciting, accepting or offering bribes or acts of corruption. Appendix B includes the clause to be included in these contracts.

IV. Sponsorship and community benefit activities

(1) Pursuant to the provisions of the Code of Ethics and Conduct, the following are excluded from the prohibitions of acceptance and/or offer of gifts or donations sponsorship activities carried out by In accordance with current legislation, and in accordance with the following provisions. Sponsorship activities include also part of the corporate social responsibility actions, allowing the companies to organizations to promote or contribute to cultural, sporting, scientific, etc. events. Since a sponsorship is linked to a specific activity , it constitutes a premise basic check that it has been developed according to the agreed parameters. The sponsorship is negotiated, formalized and verified by the organization, avoiding, as far as possible, the the intervention of intermediaries in this process, which would impair the transparency and traceability of the sponsorship. In any event, the sponsorship must be for a substantive activity whose cost is quantifiable and measurable performance. Actions will be taken to recover the amount of the sponsorship when it has not been applied to the activities committed to or when it has been impossible to verify this.

(2) Benefits to the community (participation in local festivals or traditional events) by financing part of the activities or by providing products or services free of charge or in exchange for advantageous conditions) can be interpreted as a form of donation or sponsorship, with the particularity that activities related to the communities in which they are carried out are paid for. the entity maintains links. These behaviors will be permitted provided that the Compliance previously analyzed that these are not activities of political content. For this reason, care must be taken the destination and use of the contributions, avoiding their use as consideration for favored treatment past, present or future. There are certain basic precautions in this regard, such as assessing ex-ante the legitimacy, reasonableness and proportionality of the contributions, to avoid giving amounts of money to civil servants or public entities (or persons related to these groups).

V. Exceptions and registration

(1) Exceptionally, the regulated entities may accept gifts, invitations, services from hospitality or other inducements that do not exceed customary, social or courtesy usage, and are related to the activity commercial, provided that the non-acceptance is considered to be can be considered an act of personal or institutional disregard.

(2) In case of doubt, the Compliance Committee shall be consulted as soon as it becomes aware of the following this situation.

(3) In order to ensure that such gifts, invitations, or presents are made in good faith, a The registry of gifts and invitations, which will be under the control of the HR Department, in which the following will be included The person who makes it, who receives it, as well as its estimated value. The following will be sent information thereon to the Board of Directors at least once a year.

This registry will also contain all the information related to sponsorship and sponsorship acts. benefits to the community.