CODE OF CONDUCT

Fundación Xcalibur Ethics and Integrity Program

Shaping the present to build a better future

The purpose of this Code is to summarize the ethical and behavioral principles that should guide the relationship of the entire Foundation’s team with employees, directors, and business partners, in order to maintain a transparent and ethical posture in the Foundation’s interpersonal and commercial relationships.

MESSAGE FROM THE BOARD

Fundación Xcalilbur (from now on “The Foundation”) was created with the purpose of tackling social problems and working for a more just and inclusive society, where people have opportunities to build their future.

The Foundation is guided by the best management practices and the strictest principles of ethics and honesty. This commitment extends to everyone who speaks and acts on behalf of the Foundation.

Our values, objectives and mission gain meaning through everyone’s work and commitment. This document is a way of making clear the ethical commitments and responsibility we all share.

WHO WE ARE

Fundación Xcalilbur is a non-profit organization, founded in October 2021, by Xcalibur Multiphysics and a group of partners highly involved in social and educational causes, especially those of children, youth, and women.

Through our reason to be and our projects, we strive to convey, using sport, training and culture as pedagogical and motivational tools, key personal and social values that encourage strong emotional, mental, and physical development in vulnerable children, youth, and women.

VALUES THAT GUIDE US

Accountability: Accountability to the resources and people we serve. Providing essential services with passion and efficiency is a unique way to improve the quality of life in underserved areas. The combination of responsible management and social sensitivity makes the Foundation an ally of both the needy population and the public authorities.

Essence: The essence of the Foundation is within the contribution towards a better, fairer, and more equal world, encouraging our programme beneficiaries to reach greater and broader education opportunities, especially in human development, essential life skills, and values.

Education: As the main pillar of our philosophy, education is a key element for us. Equal education access and strong encouragement to attend and continue formal education are essential requirements for the Foundation.

Equality: We are all equal and there are no barriers. Equality between people, sex, gender, race, religion, belief, and identity. Equality in opportunities, in education, in sport, and in life. We want to do our part to make this a reality.

Respect: A fundamental value and one of the most important life pillars. This begins with treating our team, our partners, and our collaborators with respect, and continues to spread out further to our beneficiaries and their families, communities, and environments.

Sport: Understood as one of the most efficient tools for education and training, human values, and life skills, it represents the perfect springboard to encourage change in children and young people. To learn playing and play learning.

Environment: It is a responsibility and a commitment. We are directly involved in caring for nature, educating with respect and care for the environment. We are environmentally conscious, and it is in our DNA.

ETHICS AND INTEGRITY PROGRAM

The Foundation does not accept any corrupt practices and clearly advises its employees to never obtain benefits from the public or private administration in the exercise of their activities.

The Foundation is committed to promoting integrity in the environment of its activities, complying with applicable local and international legislation, especially the guidelines established in the ten universal principles of the United Nations (UN) Global Compact against corruption, according to which “Organizations must combat corruption in all its forms, including extortion and bribery”. Other important topics are also addressed, such as human rights, fundamental principles and rights at work, environment, and development.

The Foundation repudiates all forms of fraud and corruption, including bribery, money laundering or insider trading, at all hierarchical levels. Thus, any of its collaborators is prohibited from: a) To request, obtain, receive, promise, offer or give undue advantages of any nature to themselves or to third parties, including facilitation payments due to the public function performed; b) Inducing or persuading colleagues to act improperly or illegally on behalf of or in favor of the company; c) Refrain from situations of fraud and corruption (local or international), in any form, directly or indirectly, actively or passively, whether or not involving monetary values; d) Finance, fund, sponsor or otherwise subsidize the practice of unlawful acts; e) Adopt, in relation to the public sector, local or international, any initiative that could be interpreted as influence peddling and as an act harmful to the Public Administration.

The Foundation supports initiatives aimed at complying with international agreements, treaties and conventions on the matters referred to in this Code, including the Universal Declaration of Human Rights of the United Nations (UN), the Business Pact for Integrity and Against Corruption and the guidelines of the International Labor Organization (ILO).

Based on the above, among other ethical behaviors, every member of Fundación Xcalibur team must:

Position itself in a non-partisan, diligent manner and with a focus on the effective development of the social objectives the Foundation intends to achieve.
• Respect human diversity, treat each other with cordiality, privileging dialogue in collective coexistence and maintaining a healthy environment in all workspaces.
• Act respecting human rights and the environment.
• Care for the Foundation’s institutional image, helping to maintain the good reputation it has built up over the years, in a positive and competent manner.
• Respect the rules of confidentiality and secrecy of information established by the Foundation, available on the website www.fundacionxcalibur.org, including any type of internal or external disclosure, even after leaving the company.

PERSONAL DATA PROTECTION

Fundación Xcalibur guarantees the right to privacy of its employees and its partners. Likewise, it guarantees the confidentiality of the personal data to which it has access, guaranteeing its holder access to its data, as well as guaranteeing that its use will only take place for appropriate and legally permitted purposes.

USE OF INTERNET, E-MAIL, AND SOCIAL NETWORKS

The Foundation reserves the right, without prior notice, to block and monitor the employee’s access to and use of the Internet. Inappropriate use of the Internet, including visits to offensive, pornographic and websites that encourage violence, hate speech or prejudice is strictly prohibited.

RECEIVING GIFTS AND FAVOURS

Gifts, travel, meals, and entertainment of any offer of value to any Public Agent or any other person or entity, including any entertainment, hospitality, travel, or gift of significant value, may be considered an improper payment and/or a violation of laws applicable anti-corruption. Therefore, Fundación Xcalibur employees, acting on behalf of the Foundation, are prohibited from providing such courtesies. Employees are also prohibited from soliciting or receiving, directly or indirectly, any gift of relevant value, including courtesies. This provision does not prohibit giving or receiving business courtesies of small value that do not create the appearance of impropriety or a conflict of interest.

PURCHASES OR CONTRACTING SERVICES

The purchase of products complies with the selection criteria, with the principles of legality, impersonality, publicity, morality, and economy.
Negotiations must be conducted by defined formal procedures. Choices of personal interest are not allowed.
Suppliers and service providers contracted by the Foundation must observe and act in accordance with the rules of this Ethics and Integrity Program, respecting the legislation and regulations applicable to the service or product contracted.

VIOLATIONS AND INVESTIGATIONS

Failure to comply with the commitments of this Code, applicable laws, or any Group guidelines can lead to serious consequences, including loss or restrictions on developing activities, civil and/or criminal liability, or very high fines. Employees and Third Parties are also subject to civil and criminal liability, fines and/or imprisonment. In addition, employees who do not comply with the commitments of this Code, the law, or the Foundation’s instructions, or who allow a member of their team to do so, or who know of any violation and do not report it, are subject to appropriate disciplinary action, including possible dismissal. Any attempt to avoid efforts to report any violation of this Code is also grounds for disciplinary action, including termination. The Board of Directors must investigate all known violations or allegations received at legal@fundacionxcalibur.org.