Dukat

Dukat ORB, S.L.

Code of Ethics

The principles that guide the behaviour of everyone who is part of Dukat.

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Ethical commitment

Ethics,
transparency
and respect.

At Dukat, we believe that sustainable success is only achieved when our actions are guided by ethics, transparency and respect. This Code of Conduct establishes the principles that must guide the behaviour of everyone who is part of Dukat.

We are committed to the principles of the United Nations Global Compact, in the areas of human rights, labour standards, the environment and anti-corruption.

Scope of application

Mandatory compliance.

All Dukat employees and managers.

External collaborators, freelancers, subcontractors and partners working on behalf of Dukat.

Suppliers and associated companies with commercial or consortium relationships.

Each person is responsible for knowing, understanding and applying the principles set out herein.

General ethical principles

Five non-negotiable values.

Integrity

We act with honesty, transparency and consistency in all our decisions.

Respect

We foster an inclusive, safe work environment based on equal opportunities.

Responsibility

We take responsibility for our actions and take care of the resources we manage.

Confidentiality

We protect sensitive information from clients, partners and colleagues in accordance with the Data Protection Policy.

Legal compliance

We respect all applicable laws, regulations and rules, both local and international.

Policies and commitments

The rules we apply.

Anti-bribery and anti-corruption policy

Open

Dukat expressly prohibits any form of bribery, corruption, fraud or unfair practice.

  • Offering, promising, accepting or requesting personal or financial benefits to influence business decisions.
  • Using intermediaries to make unlawful payments or favours.
  • Financing political activities with corporate funds.
  • Receiving gifts, invitations or favours that could compromise professional objectivity.

Practical rules

  • Gifts or courtesies must be symbolic, occasional and of no significant value.
  • Any actual or potential conflict of interest must be communicated immediately to management.
  • All transactions must be recorded in a transparent and verifiable manner.

Dukat maintains a zero-tolerance policy on corruption.

Wellbeing, equality and harassment prevention

Open

We foster a work environment based on dignity, equality and mutual respect.

  • Protocol for the Prevention and Action against Workplace and Sexual Harassment.
  • Clear reporting, investigation and sanctioning mechanisms.
  • Guaranteed confidentiality, impartiality and victim protection.
  • Supplementary Harassment Protocol and Digital Disconnection Protocol.

Protection of information and personal data

Open

Dukat strictly complies with the General Data Protection Regulation (GDPR) and the Organic Law on Data Protection and Guarantee of Digital Rights (LOPDGDD).

  • Lawful, fair and transparent processing of all personal information.
  • Applies to employees, clients, suppliers and collaborators.
  • Data Protection Policy as the regulatory framework.

Right to digital disconnection

Open

Dukat guarantees the right to digital disconnection for all employees.

  • Outside working hours, no response to calls, emails or messages is expected.
  • Except in duly communicated exceptional situations.
  • Digital Disconnection Protocol integral to the Code.
  • Promotes wellbeing, mental health and work-life balance.

Environment and sustainability

Open

We integrate sustainability into our business strategy by applying ISO 14001 principles.

  • Efficient use of natural resources.
  • Reduction of waste and emissions.
  • Collaboration on green technology and circular economy projects.

Compliance and reporting

Open

Anyone who is aware of or suspects a violation of the Code must report it in good faith.

  • Channels: Ethics Compliance Directorate, confidential email or direct contact.
  • Guarantee of confidentiality and impartial investigation.
  • Protection against retaliation of any kind.

Commitment and update

Open

Compliance with this Code is an essential condition for working with Dukat.

  • Document reviewed periodically to adapt to regulatory and organisational changes.
  • Each employee, collaborator or partner signs a declaration of adherence.
  • Ongoing commitment to the values expressed.

Official document

Commitment signed by every member.

Every employee, collaborator or partner signs a declaration of adherence and ethical commitment to the values expressed in this code.

Version 1.0 · 23 October 2025

Dukat ORB, S.L. — Passeig del Bellresguard 12, 08320 El Masnou, Barcelona

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