Corporate Social Responsibility

The essential objectives of Arin express are mainly based on the need to develop a system that fully satisfies the needs of our customers, developing prevention and organizational strategies that guarantee 100% service quality and also contribute to improving the competitiveness of our company in the market.

To this end, I establish the following Quality Policy:

√ Make Quality in Customer Service the competitive difference.
√ To have responsible and suitably prepared personnel.
√ To achieve that the criterion of Prevention of eventual failures prevails, with respect to their correction, through the identification of risks and opportunities and Quality Planning.
√ When they eventually appear, application of the criterion of taking advantage of failures to develop continuous improvement.
√ Establish and carry out a periodic follow-up of the Quality Objectives to be achieved by the company.

To this end, I consider it necessary to maintain compliance with the requirements of the ISO 9001 standard, in its concepts of process management, risk and opportunity management, customer vision, communication and continuous improvement. For its implementation to be effective, I commit myself to:a:

Comply with this Quality Policy.
Follow up the implementation and evolution of the Quality System, through the Management Review.
Disseminate this Quality Policy in the company.
Provide the necessary resources, both economic and staffing and training, for the achievement of this Quality Policy.

Lasarte, a Junio de 2017

The Management
Mikel Urdiain Sotil

Duty of confidentiality, company property and data protection.
Company and trade secrets as well as confidential information must be kept secret for the duration of the employment relationship and also after its termination.
Employees are obliged to use company property with care.
The company's internal equipment and materials are only used for business purposes.
When using personal data, privacy protection must be respected and data security must be ensured.
ARIN EXPRESS, S.L. has appointed a data protection officer to ensure compliance with data protection regulations.

Prohibition of Corruption
All forms of corruption, breach of trust and embezzlement are prohibited.
LSuppliers and service providers are selected on the basis of objective criteria.
Illegally influencing others in business transactions by exchanging gifts or giving or offering other advantages is prohibited.

Antitrust compliance
ARIN EXPRESS, S.L. and its suppliers comply with applicable antitrust and trade laws as well as pricing laws.

Bribes and kickbacks
Employees of ARIN EXPRESS, S.L. are prohibited from demanding or accepting bribes, kickbacks or other illegal or unethical benefits.
ARIN EXPRESS, S.L. does not allow unofficial gratuities at the request of public officials in order to accelerate or guarantee activities in the official routines of the authorities (e.g. issuance of visas, permits or licenses).

Fraud and embezzlement
ARIN EXPRESS, S.L. does not accept any type of fraudulent conduct or misappropriation of funds.
This means that conduct for personal enrichment that is illegal or unlawful and that is detrimental to ARIN EXPRESS, S.L. is prohibited.
Generally, this type of acts will be considered as criminal conduct.

Money laundering
ARIN EXPRESS, S.L. is committed to the fight against money laundering and the financing of terrorist and criminal activities.
Therefore, it is very important that employees are aware of and comply with the rules and laws related to such issues.

Industrial and intellectual property
The use of any type of products, programs, systems and technological knowledge in general, will be carried out respecting the regulations and legislation in force regarding industrial and intellectual property, including but not limited to: Copyrights, patents, trademarks, domain names, reproduction rights, design rights, database extraction rights and rights over specialized technical knowledge, etc.
Arin Express undertakes to comply with the Intellectual Property Law and to respect the industrial and intellectual property rights of third parties.
Arin Express employees must not use industrial and intellectual property rights for personal purposes.
Arin Express employees, as well as other personnel or collaborating entities of Arin Express, shall not disclose trade secrets to which they have access without the corresponding approvals.

Forgery
The falsification of any document or any distortion of data related to a particular transaction is not permitted.
Transactions must be recorded in a timely manner and supported by appropriate documentation.
No expense shall be incurred or paid from company funds unless authorized by the appropriate person.
Each employee, partner or supplier undertakes to combat counterfeiting by refusing to buy or sell counterfeit products, or otherwise support this illegal and harmful form of commerce.
Any unauthorized use of our brands, such as any case of illegal sale, must be reported to the Corporate Social Responsibility Department.

ARIN EXPRESS, S.L. declares that all our business and professional activities are based on strict compliance with applicable law and respect for the rights of individuals.
Violations of applicable law are unacceptable.
ARIN EXPRESS, S.L. is committed to the implementation of Corporate Social Responsibility in accordance with international standards.
This concerns both the management of the company and each individual employee.

1. Human rights and working conditions
ARIN EXPRESS, S.L. and its suppliers support compliance with internationally recognized human rights.

2. Child labor and forced labor
ARIN EXPRESS, S.L. and its suppliers reject any form of forced or child labor and do not hire employees under the age of 18.

3. Discrimination
ARIN EXPRESS, S.L. and its suppliers undertake to refrain from any form of discrimination.
Discrimination on the basis of age, disability, race, ethnic origin, religion, skin color, gender, sexual identity, marital status or other characteristics of employees is not permitted.
Sexual harassment, insults and aggressive comments towards others will not be tolerated.

4. Sustainability of leadership
Managers respect the personality and dignity of all employees and act as mediators in case of conflicts.
Todos los empleados, especialmente los gerentes, son conscientes de que su comportamiento representa a la empresa externamente.

5. Right to continuous training
ARIN EXPRESS, S.L. and its suppliers guarantee their employees continuous training during their professional career.
The company will establish regular training plans in which employees can participate free of charge.

6. Health, Labor and Environmental Protection
ARIN EXPRESS, S.L. and its suppliers ensure compliance with all applicable health, labor and environmental protection requirements.
ARIN EXPRESS, S.L. has appointed a person in charge of health, labor and environmental protection, as well as the hiring of an external company (Quirón Prevención) that assumes the tasks of implementation of health protection and prevention of occupational hazards and safety at work.
Employees receive regular training in these thematic areas.

7. Working hours and remuneration
ARIN EXPRESS, S.L. and its suppliers undertake to comply with legal regulations and provisions regarding working hours and remuneration.

8. Freedom of association
ARIN EXPRESS, S.L. y sus proveedores garantizan que sus empleados se unan pacíficamente dentro del marco legal sin la amenaza de sanciones o similares.

9. Secondary activities
Employees may not accept regular secondary employment without the consent of ARIN EXPRESS, S.L.

10. Duty of Confidentiality, Company Property and Data Protection
Business and trade secrets as well as confidential information must be kept secret for the duration of the employment relationship and also after its termination.
Employees are obliged to use company property with care.
The company's internal equipment and materials are only used for business purposes.
When using personal data, privacy protection must be respected and data security must be ensured.
ARIN EXPRESS, S.L. has appointed a data protection officer to ensure compliance with data protection regulations.

11. Prohibition of corruption
All forms of corruption, breach of trust and embezzlement are prohibited. Suppliers and service providers are selected on the basis of objective criteria. It is prohibited to unlawfully influence others in business transactions by exchanging gifts or by giving or offering other advantages.

12. Compliance with antitrust laws
ARIN EXPRESS, S.L. and its suppliers comply with applicable antitrust and trade laws, as well as pricing laws.
Anti-corruption
ARIN EXPRESS, S.L. upholds an anti-corruption policy of zero tolerance for any form of corruption or financial impropriety.
We expect our suppliers to foster a culture of integrity based on transparency, compliance with laws and ethical business practices.

Bribes and kickbacks
Representatives of ARIN EXPRESS, S.L. are prohibited from demanding or accepting bribes, kickbacks or other illegal or unethical benefits.
Gifts and Entertainment Expenses
As a supplier, we require that you do not offer gifts to ARIN EXPRESS, S.L. employees or third parties on behalf of ARIN EXPRESS, S.L. that may violate our Code of Conduct. Always proceed with care in your business relationships, so that you do not get involved in situations that involve a conflict of interest.
It is strictly forbidden to offer or accept any kind of gifts or benefits: money, loans, gift cards, kickbacks, jobs for private purposes, unethical benefits, vacations or other similar benefits to individuals.

Public Officials
The rules are stricter when interacting with government agencies and their employees or representatives. As a general rule, it is prohibited to promise, offer or provide anything of value to a government official, directly or indirectly.

Gratuities
ARIN EXPRESS, S.L. does not allow unofficial gratuities at the request of public officials for the purpose of expediting or securing activities in the official routines of the authorities (e.g., issuance of visas, permits or licenses)..
Fraud and embezzlement
ARIN EXPRESS, S.L. does not accept any type of fraudulent conduct or embezzlement.
This means that conduct for personal enrichment that is illegal or unlawful and that is detrimental to ARIN EXPRESS, S.L. is prohibited. Generally, this type of acts will be considered as criminal conduct.

Money laundering
ARIN EXPRESS, S.L. supports international efforts to combat money laundering and the financing of terrorist and criminal activities. Therefore, it is very important that employees are aware of and comply with the related regulations and laws.

The code of business conduct of ARIN EXPRESS, S.L. is a set of ethical standards to guide our business relationships, aware of the responsibility we have towards our customers, employees, suppliers and other social agents.

The code involves the articulation of a set of principles and values in business behavior, as well as in the conduct of managers and employees of the company.

The code of conduct is not a substitute for the legal regulations applicable in each case and in each territory, nor can it contradict the obligations validly assumed in each specific case by contract or collective bargaining. Nor does it constitute an exhaustive internal regulation of the company.

ARIN EXPRESS, S.L. has internal control rules and standards other than the code of conduct, although compatible with it, which have been duly approved and disseminated within the organization and which, consequently, must be known and complied with.

The principles and values of business conduct to which ARIN EXPRESS, S.L. is committed at the highest level and which inspire this code are the following:

Compliance with the law
Integrity and objectivity in business performance
Respect for people
Acting correctly in international markets
Use and protection of information
Efficient and quality management
Compliance with the law

The first commitment of business conduct of ARIN EXPRESS, S.L. is to always comply with the applicable law in all countries in which it operates, with special emphasis on the commitment to pursue its violations and to cooperate with the Justice in the event of possible infringements of the law from which the company may derive direct criminal liability in accordance with the provisions of the Spanish Criminal Code in force or any other provision in this regard that, in the future, may replace and/or complement it, as well as any other applicable criminal law.

Relations with authorities and public representatives
In all its relations with authorities and public representatives in Spain and third countries, ARIN EXPRESS, S.L. will always act in a respectful manner and in accordance with the provisions of applicable law to promote and defend their legitimate business interests.

The addressees of this code of conduct will always cooperate with the authorities and public representatives when they perform the functions that legally correspond to them..

Money laundering
ARIN EXPRESS, S.L. is particularly committed to the prosecution of money laundering and the criminal prohibition of terrorist financing.
The recipients of this code of conduct will refrain from promoting, facilitating, participating in or covering up any type of money laundering operation and will proceed in any case to report any money laundering operation of which they are aware.

Integrity and objectivity in business conduct
Integrity and objectivity in business conduct implies that the actions of all those to whom the code of conduct is addressed must always pursue a single objective within certain limits.

The objective is to ensure that, solely and exclusively in the interests of ARIN EXPRESS, S.L., the most convenient alternative for the interests of the company is always sought from among all the possible alternatives allowed by the applicable legislation, this code of conduct, the internal regulations of ARIN EXPRESS, S.L. and the applicable contracts or collective bargaining agreements.

Rejection of arbitrariness
You may not act arbitrarily or put your own interests or those of third parties first, either to your advantage or to your detriment, taking a decision other than the one that is objectively more convenient for ARIN EXPRESS, S.L.'s interests.

Conflict of interest
A conflict of interest exists when one of the addressees of the code of conduct must make a decision that affects both the interests of ARIN EXPRESS, S.L. and the interests of the addressee and related persons.
Persons related to the employee for the purposes of this code are considered to be parents, siblings, minor children, spouses or persons with an equivalent affective relationship, representatives, attorneys-in-fact, agents or controlled companies.

For example, it would be a conflict of interest:
Deciding or recommending the award of an ARIN EXPRESS, S.L. contract to a company in which a relative of the person in charge of making the decision works.
If his or her superiors authorize the action or operation, once the possible conflict of interest has been studied, then the addressee may take the decision that is objectively more convenient to the interests of ARIN EXPRESS, S.L. When allowing an addressee of this code in a situation of conflict of interest to take the decision in which the conflict exists, his or her superiors shall take into account not only the integrity and objectivity of the person who is going to decide, but also whether the image of objectivity of the company may be affected in the eyes of third parties.

When the addressee of the code of conduct who is in a situation of conflict of interest is part of a group of persons collectively responsible for making the decision (such as committees or working groups), he/she shall inform the other persons responsible for making the decision when such decision is collective and shall abstain from participating in any voting.
Any related-party transaction with the Company and the employee or persons related thereto must be expressly authorized by the corresponding superior and the Regulatory Compliance body shall be informed.
Cuando el destinatario del código de conducta que se encuentra en una situación de conflicto de intereses forme parte de un grupo de personas encargado colectivamente de tomar la decisión (como son los comités o grupos de trabajo) lo pondrá en conocimiento del resto de personas encargadas de tomar la decisión cuando dicha decisión sea colectiva y se abstendrá de participar en cualquier votación.
Any transaction or contract in which the employee or related person has any direct or indirect interest is considered a related transaction.


Gifts and hospitality

Donations
In relations with third parties, institutions and companies, the recipients of this Code of Conduct shall never make gifts or invitations whose economic value exceeds what may be considered reasonable and moderate according to the circumstances of the matter and the country in question.
Cuando las reglas de conducta aplicables a las terceras personas o empresas prohíban o limiten por debajo del umbral de lo razonable y moderado los obsequios o invitaciones, los destinatarios de este código de conducta se abstendrán de realizar ninguna invitación ni de ofrecer ningún regalo que vulnere lo establecido en las reglas de conducta aplicables a los posibles destinatarios.
In line with the above, in relations with third parties and companies, the recipients of this code shall refuse any gift or invitation whose economic value exceeds what may be considered reasonable and moderate according to the circumstances of the matter and the country in question. Gifts and invitations shall always be politely declined, explaining that they comply with the provisions of the ARIN EXPRESS, S.L. code of business conduct..

In those exceptional cases in which, in accordance with the business practices of a foreign country, it is necessary to accept gifts that exceed the value considered moderate or reasonable in Spain, the gift will always be accepted on behalf of the company, which will be the sole owner. In such cases, the employee shall inform his or her superior.

Any donation or gift from ARIN EXPRESS, S.L. must be authorized by the Board of Directors or, by delegation thereof, by the Regulatory Compliance body. It must be duly accounted for and may not be used as a means of concealing an improper payment or bribe.

Image and communication
The directors and employees of ARIN EXPRESS, S.L. shall refrain from any activity that could damage the image and reputation of the company and from maintaining any kind of relationship with the media, which shall be channeled exclusively through the bodies and persons assigned with such functions in the company.

Respect for free competition
ARIN EXPRESS, S.L. is firmly committed to free competition and fair market behavior.
Consequently, whenever ARIN EXPRESS, S.L. competes with one or more competitors to develop a business operation, the addressees of this code of conduct will refrain from any practice contrary to free competition in order to favor the interests of ARIN EXPRESS, S.L.


The following are considered anti-competitive practices:
The unlawful obtaining of information about the competitor's product or offer.
The concertation with one or more competitors to fix prices or other determinant elements of the offer to which the competitor is competing.
The dissemination of false or misleading information that is detrimental to one or more competitors.
The realization of misleading advertising of its business and any conduct that may constitute an abuse or unlawful restriction of competition.


Relations with partners
In relations with partners, agents, collaborators and third parties, as well as in negotiations and operations involving the restructuring or acquisition of companies, alliances with third parties or corporate shareholdings, we shall ensure that such persons or entities comply with the standards of conduct and business and professional ethics aligned and consistent with those contained in this Code of Conduct.

Compliance with contracts
Whenever ARIN EXPRESS, S.L. enters into a contract, it does so with the will and commitment to put the contract into effect and to comply with everything agreed.
The addressees of this code of conduct may not unjustifiably impede or hinder the fulfillment of the company's contracts..

Relations with suppliers
Supplier selection processes shall be carried out with impartiality, objectivity and transparency.

Honest Negotiation
When the addressees of this code of conduct negotiate on behalf or in the interest of ARIN EXPRESS, S.L., they will always do so by refraining from dishonest or unfair practices.

Rejection of Corrupt Practices and Bribery
ARIN EXPRESS, S.L. rejects any kind of corrupt practice, public or private, especially bribery.
All recipients of the ARIN EXPRESS, S.L. code of conduct shall refrain from promoting, facilitating, participating in or covering up any type of corrupt practice and shall in any case report any corrupt practice of which they are aware.
In the development of its international business, ARIN EXPRESS, S.L. will be guided by the recommendations and guidelines issued by the Organization for Economic Cooperation and Development.


Respect for people
Respect for individuals is a fundamental principle/value in all ARIN EXPRESS, S.L. actions.

Respectful treatment
The addressees of this code of conduct shall always treat all individuals with whom they interact, whether or not they are addressees or aware of the code of conduct, with due respect.
Disrespectful actions or verbal or written statements against any person or group of persons, whether or not they are present, shall not be permitted.

Violence and aggressive behavior
ARIN EXPRESS, S.L. categorically prohibits the recipients of this code from any kind of violent conduct and aggressive behavior, including aggression, threat of physical aggression or verbal violence.

Equality and non-discrimination
ARIN EXPRESS, S.L. guarantees all its employees equal and non-discriminatory treatment regardless of race, color, religion, sex and sexual orientation, nationality, age, pregnancy status, degree of disability and other legally protected circumstances.

ARIN EXPRESS, S.L. has a firm commitment to its equality policies and all recipients of this code of conduct must act accordingly, knowing and favoring such policies.

Harassment
ARIN EXPRESS, S.L. also prohibits and prosecutes harassing conduct in the work environment, including sexual harassment.

Reconciliation of personal, family and work life.
The company is committed to facilitating the reconciliation of the personal, family and work life of its employees, in accordance with legal regulations and the provisions of the Collective Bargaining Agreement.

Respect for human rights
Without prejudice to the previous specific commitments, ARIN EXPRESS, S.L. has a general commitment to respect the human rights of all individuals.

Likewise, ARIN EXPRESS, S.L. maintains a special interest in the control and monitoring of compliance with human rights in its relationship with the company's personnel, with special attention to those linked to the business activity such as:

Right of association
Freedom of association and the right to collective bargaining

The rights of children and youth
Suppression of child exploitation and forced labor.
The right to fair and satisfactory conditions of employment


Proper conduct in international markets

Import and export licenses and permits
In all import and export operations of any type of goods or services, including the import and export of information, ARIN EXPRESS, S.L. will always act in accordance with the provisions of the applicable legislation of the countries concerned.

The recipients of this code of conduct must know and comply with the applicable legislation for each export and import operation, providing the competent authorities with the legally required information and obtaining from them all the permits and authorizations that are required to carry out the international trade operation.

Legislación antitrust y antimonopolio
When operating in international markets, ARIN EXPRESS, S.L. is committed to respect at all times the legislation of the various states on antitrust and antitrust practices.

The addressees of this code of conduct who intervene in the different operations must know and comply with the requirements of the legislation of the states in question in antitrust and antitrust matters.


Use and protection of information

Protection of confidential and proprietary information
In general, the recipients of this code of conduct shall not use the information they learn as a result of their relations with ARIN EXPRESS, S.L. to obtain a personal advantage, nor shall they provide it in any case to third parties.

ARIN EXPRESS, S.L. has access in its business to customer and supplier information that is provided under the contractual commitment of confidentiality.
The company assumes the commitment not to disclose and protect this confidential information.
This commitment must be assumed and complied with by all recipients of this code of conduct.
Like all companies, in the course of its operations, ARIN EXPRESS, S.L. generates reserved or confidential information, technical or commercial, which is valuable to the company or whose disclosure could harm its interests, those of its customers and suppliers, or its operations in the market.

ARIN EXPRESS, S.L. is committed to regulate in a clear and reasonable manner the identification, management and protection of its reserved, confidential or secret information.
The recipients of the code of conduct must know and comply with this regulation.

Protection of personal data
The legislation of many countries protects the most sensitive information for people, especially for individuals, preventing it from being disclosed or managed through computer systems without guarantees.
ARIN EXPRESS, S.L. takes special care to protect the personal data of persons to whom it has access in the course of its business, always complying with the applicable laws. The recipients of this code of conduct responsible for the processing or archiving of legally protected personal data are obliged to know the applicable legislation and to ensure its proper application and compliance.

Commitment to transparency
Always respecting the restrictions to the free disclosure of technical or commercial information, classified as reserved or confidential, ARIN EXPRESS, S.L. is fully committed to the transparency of its performance.


Efficient and quality management

Obtaining margin
The purpose of ARIN EXPRESS, S.L.'s business action is to obtain margin in its business operations, which must be carried out respecting the principles contained in this code of conduct.

All the addressees of the code shall endeavor to obtain margin within the permitted limits.

Proper management of resources
To facilitate the achievement of the company's margin, the addressees of this code of conduct shall at all times endeavor to manage the company's resources in the most efficient manner, avoiding any type of superfluous expenditure.

Use and Protection of Company Resources and Assets
Except for those cases in which the law or company rules authorize the use of company resources for personal purposes, the recipients of this Code of Conduct shall refrain from using company resources for their own use. The company is the owner of the property and the rights of use and exploitation of software and computer systems, equipment, telephones, computers, storage devices, e-mail systems and access to the Internet or internal and external databases, manuals, videos, projects, studies, reports and other works and rights created, developed, perfected or used by its employees.

In any case, the use of the assets, resources and means of ARIN EXPRESS, S.L. must comply with the security and protection protocols established by the company.

Quality
The principles of quality are part of the organizational culture of ARIN EXPRESS, S.L. in order to achieve maximum customer satisfaction with the proper fulfillment of the requirements established in the contracts.

Likewise, ARIN EXPRESS, S.L. has the ISO 9001 quality certificate and carries out the pertinent audits required by the certification.

Control of criminal liability
The Board of Directors of ARIN EXPRESS, S.L. reiterates its firm opposition to any practice that may pose a risk of constituting criminal or code of conduct violations, both in Spain and in any country in which the company operates.

The internal control of criminal liability is a priority objective for ARIN EXPRESS, S.L., committed to the task of prevention, detection and exclusion of any unlawful action carried out within the scope of its responsibilities, in its name or on its behalf and for its benefit, by any of its legal representatives, de facto or de jure administrators, managers, employees, agents and collaborators.

In any case, the persons to whom this code is addressed shall refrain from acts and omissions that entail the risk of incurring in any of the criminal offenses that may affect ARIN EXPRESS, S.L.

The persons to whom this code is addressed who detect conduct in breach of criminal law, of any other mandatory legal regulation, of this code of conduct or of other internal rules of supervision and control of ARIN EXPRESS, S.L. must inform the Regulatory Compliance body by means of the complaints channel or by any other valid means for these purposes.

Any of these persons who, in the normal exercise of their management, control or auditing functions, detects or becomes aware of any allegedly unlawful conduct, must inform the Regulatory Compliance body through any of the syndicated means.

No employee shall be obliged to comply with orders or instructions contrary to the law or this Code of Conduct. Should such a situation arise, the employee must contact the Regulatory Compliance body through any of the aforementioned channels.


Dissemination and application of the code of conduct through training actions.
ARIN EXPRESS, S.L. will carry out the necessary training actions so that all its employees are informed about this code of conduct and its content.

The training will include criteria and guidelines to resolve doubts according to the accumulated experience. In addition to general training, ARIN EXPRESS, S.L. will provide specialized training to those groups of managers or employees who, due to the tasks they perform, must have a more precise and detailed knowledge of the rules of conduct applicable to their area of activity.

Support and advice
All recipients of this code of conduct will have the following channels at their disposal to communicate their doubts about the code of conduct in their respective areas:
*) To their hierarchical superiorsbr /> *) To their Human Resources area


Verification and control
ARIN EXPRESS, S.L. will establish an adequate monitoring and control system to verify compliance with the code of conduct without waiting for complaints or denunciations to be received.

In addition to the bodies in charge of ordinary management, the Head of Human Resources will monitor and control compliance with the code of conduct, and will report directly to the Criminal Compliance and Prevention Committee.

Whenever an ARIN EXPRESS, S.L. recipient or person aware of the code of conduct wishes to inform the company of a possible violation of criminal law or the code of conduct, he/she may contact the Human Resources Manager directly, or through the complaints channel of the Regulatory Compliance Manager.


Independence and confidentiality
ARIN EXPRESS, S.L. guarantees that whoever submits a complaint or report in the manner indicated in the preceding paragraph, the confidentiality of their identity, except when they must identify themselves to the authorities in accordance with the provisions of the law.

ARIN EXPRESS, S.L. also guarantees that the company will carry out the investigation of the facts that have been reported or communicated.

Prohibition of retaliation
ARIN EXPRESS, S.L. guarantees that no retaliation will ever be taken against anyone who in good faith brings a possible violation of the code of conduct to the attention of the company, collaborates in its investigation or helps to resolve it.

This guarantee does not extend to those who act in bad faith with the intent to spread false information or to harm people. Against such unlawful conduct, ARIN EXPRESS, S.L. will take appropriate legal or disciplinary measures.

Investigation of possible violations
The Head of Human Resources will analyze the facts that have been reported or communicated and may request information from other bodies of the company who will always be obliged to provide it, provided that there is no legal prohibition to do so.

For this purpose, the provisions of the Protocol of action in case of breaches of the code of conduct of ARIN EXPRESS, S.L. and the Complaints Procedure of ARIN EXPRESS, S.L. shall be applied.
Except when the applicable laws stipulate otherwise, when the investigation progresses, the Human Resources Manager shall inform the affected persons of the facts so that they can provide additional information and, where appropriate, allege or justify the reasons for their actions.


Reaction to non-compliance with the code of conduct
When the existence of a breach of the code of conduct that is prosecuted by law is ascertained, ARIN EXPRESS, S.L. will proceed to bring it to the attention of the competent authorities when legally required to do so.

If the violation of the code of conduct legitimizes the company to take disciplinary measures against its managers, employees or workers, including dismissal, the company will initiate the appropriate procedures to carry them into effect.

Finally, if the violation has been carried out by representatives, agents, agents and mediators of ARIN EXPRESS, S.L., the company will act in accordance with the provisions of their respective contracts and in accordance in any case with the principles of this code of conduct and may terminate the relationship with ARIN EXPRESS, S.L.

Miguel Urdiain Sotil
Director General