Rules of conduct

• ZBM is committed to:
  • Ensuring that the policies and practices of selection, hiring, and remuneration, employment conditions, or access to training and promotion for Professionals are based solely on merit and specific capability requirements in each case, and, in particular, always respecting the principle of equal treatment between men and women.
  • Developing appropriate training and promotion policies for Professionals that consider career and professional development, fostering an environment in which equal opportunities reach every individual, ensuring non-discrimination based on ethnicity, gender, ideology, nationality, disability, beliefs, or any other personal, physical, or social condition.
  • Providing a work environment that promotes dignity and respect, rejecting any manifestation of violence, abuse of authority at work, or any other conduct that generates an intimidating or offensive environment affecting the personal rights of Professionals, committing to a zero-tolerance policy toward any such behaviors in the workplace.
  • Evaluating employees rigorously and objectively, considering both individual and collective professional performance, with Professionals participating in defining their objectives and being informed of their evaluations.

ZBM will promote an adequate occupational risk prevention policy, ensuring its dissemination to the entire workforce to guarantee safety and health at work, compliance with applicable regulations, and the adoption of necessary or appropriate preventive measures in each case.

ZBM will encourage the creation of safe and healthy work environments, providing training and information on occupational safety and health to its employees.

ZBM Professionals must know and comply with applicable occupational risk prevention regulations in their role and ensure, within their functions, their own safety and that of their colleagues.

Respect for natural resources and the environment is one of ZBM’s fundamental operating principles, ensured through the adoption of an appropriate environmental policy.

Within their functions, ZBM Professionals must know and adopt this policy and act at all times according to principles of respect, ecosystem balance, and sustainability. They will adopt habits and behaviors aligned with good environmental practices and contribute positively and effectively to achieving established objectives. To this end, they will use the facilities, equipment, and resources provided efficiently.

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ZBM will promote family-friendly policies that facilitate the necessary balance between the professional, personal, and family life of its Professionals.

ZBM will ensure and promote respect for the law and combat corruption in all its forms, demonstrating its firm commitment to the Crime Prevention Policy, particularly avoiding practices that could be considered irregular in its relationships with clients, suppliers, collaborators, competitors, authorities, etc., including money laundering.

In any situation of doubt, Professionals must report or consult through their direct supervisor or the Criminal Risk Prevention and Control Body, if available.

Regarding gifts, gratuities, invitations, and other types of remuneration, ZBM establishes specific guidelines aiming to limit, and in some cases prohibit, gifts and invitations, whether given or received by Professionals, according to the following rules:

• It is prohibited to accept, offer, or receive a gift or invitation that, for any reason, (i) influences, may influence, or could be interpreted as influencing decision-making, or (ii) is prohibited by law or generally accepted business practices.
• Professionals are prohibited from giving presents, favors, compensations, gratuities, or other remuneration, regardless of amount, to public authorities or officials.
• Professionals are prohibited from influencing public officials or authorities by leveraging any relationship or situation derived from personal relations with them or another official to obtain a resolution that could generate a direct or indirect economic benefit for themselves or a third party.

A conflict of interest is considered to exist when a professional’s personal interest collides, directly or indirectly, with the interests of ZBM. Personal interest is understood as any interest affecting the professional or persons related to them by marriage, domestic partnership, or kinship.

ZBM Professionals must avoid all situations that could lead to a conflict of interest and refrain from influencing or intervening in decision-making related to such matters. Personal interest also includes relationships with friends.

In any potential conflict of interest situation, ZBM Professionals must report it to their direct supervisor. ZBM promotes compliance with applicable law and the adoption of internal measures to prevent criminal risks, including the implementation of effective organizational and management models as provided by applicable regulations. These measures aim to identify, evaluate, and mitigate potential risks of unlawful acts and foster a culture of integrity, regulatory compliance, and corporate responsibility.

ZBM Professionals may not use or disclose privileged information obtained in the course of their professional activity.

ZBM aims to satisfy clients’ needs and expectations. Professionals must promote long-term commercial relationships with clients based on a permanent attitude of service, trust, and value creation, maintaining a high commitment to honesty, respect, integrity, transparency, and professional responsibility.

Similarly, ZBM will foster relationships with suppliers and collaborators based on the principles of its internal procurement and supplier relationship policy, ensuring transparency of information and mutual respect within the framework of good business practices.

Supplier selection will be based on objective, impartial, transparent, and non-discriminatory criteria, through established selection and contracting processes for suppliers meeting ZBM’s standards of solvency, technical suitability, quality, price, and ethics.

ZBM is committed to competing fairly and transparently in the markets, refraining from misleading advertising, promoting free competition, and fully respecting applicable regulations.

Agreements that could affect free competition, particularly the collusion of prices in public or private tenders in which ZBM participates, are prohibited.

ZBM considers its corporate image and reputation among its most important assets.

All Professionals must ensure that their conduct does not harm ZBM’s image or reputation.

ZBM provides employees with the resources, means, and tools necessary to perform their professional duties, which must not be used for other purposes.

Therefore, all Professionals must (i) use the work tools provided by ZBM, such as phones, computers, emails, Internet access, or other materials, solely for the professional activities assigned, and not for personal or other purposes; and (ii) make proper use of company assets and resources and protect them against damage, theft, or loss, in accordance with applicable internal policies.

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ZBM will comply with applicable personal data protection legislation for data entrusted by employees, clients, suppliers, job candidates, or other individuals, ensuring proper storage, use for authorized purposes, and no disclosure without consent or unless legally required.

ZBM considers information and knowledge as key assets for business management, which must receive special protection under established Information Security policies.

ZBM’s information is generally considered confidential and subject to professional secrecy, and may not be disclosed to third parties without express authorization from the competent ZBM body or unless required by law, court order, or administrative authority.

It is the responsibility of ZBM and all its professionals to implement sufficient security measures to protect confidential information against any internal or external risk of unauthorized access, manipulation, or destruction, whether intentional or accidental. ZBM Professionals must maintain confidentiality in their work relationships with third parties.

The disclosure or unauthorized use of confidential information by ZBM Professionals for personal or unauthorized purposes violates this Code and may constitute an offense under applicable law and ZBM internal regulations.

ZBM will proactively ensure the proper use and protection of its intellectual property rights.

Professionals may not, under any circumstances, reproduce, plagiarize, distribute, publicly communicate, or otherwise economically exploit, in whole or in part, by any means, literary, artistic, or scientific works protected by the intellectual property rights of ZBM or its clients without authorization.

Anything not covered in this Code will be governed by ZBM’s internal procedures, duly communicated to all Professionals.