AURA Code of Ethics

1. Message from the Management

 

I am pleased to present our code of conduct which was built on the principles and values ​​that have been the hallmarks of our company since the beginning: respect, professionalism and humanity.

 

Our code continues to be a declaration of the most scrupulous standards of ethics and integrity in everything we represent and do, permeating all areas of action of AURA and its employees. Our code of conduct guides the decisions and actions taken every day, ensuring that we keep to the path of honesty and rectitude that is demanded of any entity, its managers and workers.

 

Our code of conduct not only defines how we do things, but also how we behave in all aspects and moments, taking into account our impact on society and its development. This is how we have successfully built an impeccable international reputation, which we must continue to preserve tirelessly as one of the most valuable assets of this company.

 

2. Responsibility for compliance with the code of conduct

 

All employees are subject to compliance with the following obligations:

 

        1. Know the code of conduct and make decisions in keeping with these principles and the policies that emanate from them.
        2. Communicate any indication of processes and actions that contravene this code, through the channel enabled for this purpose on the AURA intranet and the corporate website.

 

3. Approval and validity of the code

 

This code is reviewed and updated periodically. It was last approved by the AURA Management Body in January 2018.

 

4. Social Responsibility Committee (or Corporate Compliance Committee). Compliance Manager

 

This is the superior body in charge of ensuring the compliance and development of the code. It involves the participation of a committee composed of 4 people and the permanent presence of a person in charge of internal audit functions (Internal Audit Manager). The functions of the committee are to:

 

        1. Resolve any doubts that may arise.
        2. Study the cases of possible non-compliance and reach a decision.
        3. Propose and approve appropriate changes to the code of conduct.
        4. Keep a confidential registry of complaints and queries. Investigate and act on these complaints and inquiries.

 

5. Penalties for non-compliance

 

Non-compliance of the code and of the rules derived from the development of specific policies duly communicated could lead to the initiation of the procedures foreseen for this purpose in the corresponding regulations, including the adoption of disciplinary measures, and even dismissal and termination of previously established contractual relationships.

 

6. Managerial obligations

 

All Managers have the following obligations:

 

        1. Communicate the code to your teams.
        2. Lead compliance by example.
        3. Support teams through ethical and integrity issues that may arise at any time.
        4. Correct deviations detected in compliance with the code of conduct.
        5. Establish mechanisms in a timely manner to ensure compliance with the code in their areas of responsibility.
        6. Inform the AURA’s Internal Auditing Manager about the processes and actions that are contrary to the provisions of this code.

 

7. No retaliation

 

AURA values ​​the help of employees who identify possible problems that the company needs to address and does not tolerate retaliation for: asking questions, presenting reports in good faith or participating in an investigation. By reporting retaliation, a position of ethics and integrity is adopted in our workplace and makes AURA a better place to work.

 

Any retaliation against an employee who presents a problem with honesty constitutes a violation of the code. That an employee has reported a concern honestly or participated in an investigation cannot be the basis of an action that harms their employment, including dismissal, demotion, suspension, loss of benefits, threats, harassment or discrimination.

 

8. Conflict of interest

 

It will be considered that there is a conflict of interest in all situations in which the interest of AURA and the personal interest of any of the employees directly or indirectly collide.

 

AURA respects the participation of employees in other financial or business activities, provided that such activities are legal and that they do not enter into competition or cause possible conflicts of interest with their responsibilities as employees of AURA.

 

All employees must avoid situations that may provoke a conflict between their personal interests and those of AURA. In such cases they should refrain from representing AURA and avoid intervening or influencing the decision making in which, directly or indirectly, involves themselves or a person linked to them that has a personal interest, and must communicate such situations to the Compliance Committee.

 

9. Respect for current legislation, prohibiting any kind of corruption or bribery

 

Employees must:

 

      • Comply with the laws in force at the place where they carry out their activity.
      • Know, observe and comply with the internal rules and procedures established and / or assumed as their own by the company.
      • Assume and recognize as their own, the values ​​and principles contained in this code through their freely accepted consent.

 

AURA, and all its staff, are committed to never, under any circumstance, behave in a way that may be considered irregular, illegal, criminal or unethical in the development of their relations with customers, suppliers, competitors, authorities, etc., including those related to the fight against money laundering and the financing of terrorism.

 

In the development of their professional work no AURA employee will consciously collaborate with third parties in the violation of any national or international law, nor cooperate with them in actions or omissions that compromise the principle of legality or that may, if known, damage the reputation of AURA, its professionals, its interest groups or third parties in general.

 

AURA rejects any form of corruption, both in the private and public sectors.

 

In no case shall the employees, by themselves or through a third party, receive, request or accept in the exercise of their professional performance, an unjustified benefit or advantage of any nature, for themselves, for AURA or for a third party, in return for unduly favoring another in a business relationship.

 

Likewise, in no case shall the employees, by themselves or through a third party, promise, offer or grant, in the exercise of their professional performance and in the same context, an unjustified benefit or advantage, of any nature, for themselves, AURA, or a third party, in return for improperly favoring AURA, themselves or a third party over others in a business relationship.

 

10. Healthy and friendly work environment

 

The relationships between all employees should always be based on respect for the dignity and non-discrimination of people.

 

AURA treats all employees with respect and dignity in their workplace and provides them with an environment free of discrimination; hires, remunerates and promotes all employees based on their ability to perform the work for which they were hired and not because of their personal characteristics or beliefs.

 

Maintaining a safe workplace also means making sure that our actions do not create risks for ourselves or those around us. AURA does not tolerate threatening or violent behavior in the workplace, and at no time can we engage in risky behaviors for oneself or other employees.

 

One of AURA’s fundamental principles is to achieve a high level of well-being and professional satisfaction for all staff.

 

11. Prevention of harassment, intimidation and discrimination

 

AURA strongly prohibits any type of hostile or humiliating act against people, the abuse of authority and any type of harassment, whether physical or psychological, as well as any other conduct that may generate an intimidating, offensive or hostile work environment. Any type of child or forced labor will not be tolerated.

 

Diversity is part of what generates the success of AURA. To fulfill and maintain our commitment to diversity, we all have a responsibility to show respect and create an inclusive workplace environment. As a result, AURA does not tolerate unlawful discrimination based on protected characteristics, such as race, color, age, gender, nationality, disability, religion, sexual orientation, and other characteristics protected by law.

 

12. Equality of opportunities. Professional development

 

Professional development at AURA is a key element to ensure that we always have the most pertinent capabilities for business requirements. Promotion of AURA employees starts from the equality of opportunities and recognition of the individual’s performance and capacities, which is measured through performance management systems and / or the evaluation of knowledge and skills.

 

For all these reasons, in AURA, people with a diversity of experiences, ideas, beliefs and origins are valued, giving everyone equal opportunities.

 

Internal promotion in AURA is based on principles of competence and professional merits. Decisions in this regard are made according to clear, objective and transparent criteria. All employees are informed of the evaluation tools of their performance and assessment of their results, which in any case are based on criteria of objectivity and transparency.

 

13. Protection of personal data of employees, customers, partners and suppliers

 

AURA ensures the protection of personal data that are stored and exchanged during the daily activity in the development of business. Said protection is a priority to reach a maximum level of quality in the development of the corporate purpose.

 

For this reason, employees must always respect the legislation on personal data protection when dealing with personal data from customers, suppliers, employees or third parties.

 

To comply with the above, AURA adopts training policies, distributing didactic material to facilitate its understanding on a regular basis and thus avoid any breach in its application.

 

Information security is guaranteed through the signing of contracts with our suppliers, and the confidentiality clauses defined.

 

Computer and communications resources, especially electronic mail and the Internet, must be used only and exclusively for the performance of the professional functions of employees, and their use may be subject to follow-up or audits at any time.

 

14. Employee confidentiality contract

 

Employees only have access to information, whether in physical or electronic format, and the tools necessary to perform their work duties, and must maintain the strictest professional secrecy and confidentially for all the information they handle in the course of their professional work.

 

To this end, AURA has a complete series of confidentiality contracts that the employee must sign, depending on their responsibilities regarding personal data, in the performance of the function for which they were hired. The commitment acquired by the employee when signing one of these contracts continues, even if the employee stops working at AURA.

 

15. Commitment to Quality. Customer satisfaction

 

AURA has the ISO 9001 and 27001 certifications of Quality Management and Information Security. This guarantees the years of commitment that AURA has devoted to customer satisfaction.

 

AURA Management has many years of experience in the software world, which has led to the accumulation of a lot of information and knowledge about customer demands in this sector.

 

AURA’s commitment has always been to satisfy customers with the best and most modern computer products, using the most advanced and emerging technologies and developing the functional and operational aspects with detail and care.

 

Aware of its current needs, AURA has implemented an information security management model based on the ISO / IEC 27001 standard as a tool to identify and minimize the risks to which the information is exposed, to help reduce operating and financial costs, to establish a culture of security and guarantee compliance with current legal, contractual, regulatory and business requirements.

 

The risk analysis process for information assets supports the development of the Information Security policies and of the controls and control objectives selected to obtain the levels of protection expected in AURA.

 

16. Commitment to cutting-edge technologies and Innovation

 

AURA Management is committed to innovation and the use and research of all cutting-edge technologies that can improve the quality of the product developed by the company. To achieve this, the company favors information flow in all directions and encourages employees to share all research on new technologies that they consider important to improve the work of the company at any level.

 

17. Integrity and transparency

 

AURA is committed to the sustainability of its operations, investments and businesses. We understand sustainability as the generation of value in a responsible manner, with a balance between economic profitability, development and social inclusion, guided by the principles inspired by AURA Management and the commitments made regarding quality and Information Security.

 

In a framework of transparent, ethical and innovative action, AURA has a long-term vision for the sustainability and competitiveness of the businesses in which it maintains investments. We seek total transparency in our actions for our employees, customers, suppliers, authorities, competitors and, in general, all our stakeholders.

 

AURA is committed to free enterprise and therefore fully respects the laws of competition, antitrust and commercial loyalty, and in this sense applies the competition policy adopted by each company.

 

18. Prohibition of consumption or trade of drugs or alcohol

 

The consumption of tobacco, alcoholic beverages and / or any substances prohibited by law is prohibited during working hours, as is going to the place of work while under the influence of these substances.