1. INTRODUCTION

VICTRIX, founded in 1976, is the parent company of a holding company dedicated to the design, manufacture and marketing of clothing through the brand name PUNT ROMA.
Its headquarters are in Mataró (Barcelona), a city with a long textile tradition.
The company controls the entire production process of each product, from the exclusive design to the store presentation. Each stage always takes into account customer satisfaction in every detail.

PUNT ROMA opened its first store in 1997. It has had major presence in the women’s fashion market with more than 400 stores, 190 of which are located in Spain, Portugal and Andorra and the rest in other countries.
The company is still controlled by the founding family, but with the addition of new talent, the company shows consistent and reliable growth.

PUNT ROMA is a Spanish company that offers fashion for women, offering a wide range of styles, always ensuring the highest quality and best price.
We offer a perfectly coordinated collection of garments and accessories.
Our designers constantly interpret fashion trends and adapt them to the tastes of our customers.
We have state-of-the-art facilities, integrated with a SAP HANNA system, implemented across the board in all the company’s processes.
Our 45,000m2 automated distribution centre is capable of processing more than 100,000 units/day. 

2. PURPOSE

Code of ethics, code of conduct or code of good practice brings together in a single document the principles, criteria and rules of conduct by which VICTRIX employees must be governed during the development of their professional activities, constituting, as a result, a basic pillar of the company’s compliance programme that promotes and reflects a positive corporate culture.

The purpose of this Code is to set out the principles and values that should govern the actions of the company and all its employees, suppliers, contractors and business partners, in order to ensure ethical and responsible professional behaviour when conducting their professional activities, and to reflect the company’s commitment to the principles of business ethics and transparency.

The Code of Ethics is binding and contains provisions aimed at making it effective, such as communication channels and allocation of responsibilities. Such binding includes obligations, and breaches of the code of ethics will be considered by those responsible for taking appropriate action.

El Código se basa en valores, mejora de reputación de la entidad, otorga unidad y coherencia al sistema de autorregulación de la empresa, fortalece en los The Code is based on values, improves the reputation of the entity, gives unity and consistency to the company’s self-regulation system, strengthens employees’ sense of belonging to a group and indicates the company’s corporate culture to third parties.

In accordance with the law, it should be added that certain matters covered by this Code will be supplemented by the more detailed rules set out in the various sectoral Codes. The code of ethics will also be complemented by company policies which, based on the provisions of the code, regulate in more detail specific sectors (the textile sector) or a certain activity within the company.

The Code takes into account the principle of criminal liability of legal persons and serves as a basis for avoiding irregular and improper behaviour that can lead to the company’s criminal liability. 

3. SCOPE OF APPLICATION

This Code of Ethics will be subject to obligatory fulfilment by all workers of VICTRIX irrespective of the position they hold, directors, administrators, employees or staff and even collaborators such as suppliers, contractors or commercial partners of the company or the geographical area in which they are both national and international.

External consultants, workers and temporary workers, when providing services for the company, will also be linked.
Also, VICTRIX will promote the application of this Code of Ethics to any natural or legal person, when the existing legislation between both, advises the application of this.

In any case, it is expressly forbidden to disregard an order from a superior. An employee’s justification for non-compliance with the Code of Ethics on the basis of orders from their line manager will not be considered valid.

The company will promote and encourage its suppliers and collaborating companies to adopt behavioural guidelines consistent with those defined in this Code of Ethics and, where appropriate, may ask them to formalise their commitment to comply with the Code or the guidelines it establishes.  

4. ETHICAL VALUES AND MORAL PRINCIPLES

The ethical values and principles of the organisation are the foundation on which the company’s activity is based. These principles and values are as follows:

5. COMPLIANCE WITH APPLICABLE LAWS AND INTERNAL REGULATIONS

The persons bound by the Code agree to comply with the laws in force, the company’s internal procedures and the values and principles set out in this Code. They also agree to report any non-compliance they identify in their vicinity.
Employees should avoid any conduct that may damage the reputation of the company or adversely affect its interests. All employees must be aware of the laws that affect their work, requesting, where appropriate, the necessary information from their superior.
No employee will knowingly collaborate with third parties in the violation of any law, or participate in any action that compromises the principle of legality.
The company will ensure that all its members are aware of the external and internal regulations relevant to the duties they perform.
In the event of any situation of non-compliance with the law, employees must inform the company through the reporting channels detailed in this Code of Ethics. 


6. COMPLIANCE WITH STANDARDS, AGREEMENTS AND CONVENTIONS

The company agrees to comply with and integrate as internal regulations the provisions of national or international agreements and conventions which, due to the activity carried out by the company, may be binding on it.
All employees must comply with the laws in force in the countries where they carry out their activities, in accordance with their spirit and purpose, and must behave ethically in all their actions. 

7. EMPLOYEE AND SUPPLIER RELATIONS

Employees

The company’s employees are its greatest asset and will be considered as such.

VICTRIX will promote the personal and professional development of its members and foster a positive working environment. Respect will govern relations between employees who will remain vigilant against any form of violence, abuse or discrimination of any kind at work. Employees of the company must treat each other with respect in a pleasant and safe working environment, with an obligation to treat colleagues, subordinates and superiors fairly and respectfully.

Any type of promotion will respond to the principles of merit and ability as defined in the job requirements, with the company ensuring equal opportunities and promoting a corporate culture based on merit.

VICTRIX will ensure compliance with labour regulations in employment. Employees will cooperate in fulfilling these objectives by preventing, detecting and reporting any irregularities they may detect.

Special attention will be paid to integrating people with disabilities or handicaps into the labour market. 

Suppliers

Ethics and respect will govern relations with suppliers, who will be selected based on objective and transparent criteria.
In this case, compliance with the code will be part of a supply or service contract and its compliance may result in the possibility of withdrawing from the contract. Therefore, the code may be provided as an annex to the contract.
Internal procurement procedures will be scrupulously respected, decisions will be justified and related documentation will be kept for possible internal or external audit.
Extreme care will be taken to protect suppliers’ confidential information.
Suppliers must commit to respect human and labour rights in their own companies.
All employees participating in supplier and external collaborator selection processes must act objectively and impartially, applying transparent criteria and complying with the relevant internal regulations. 

Business Partners

Relations with business partners will be based on respect regardless of their culture, customs, religion and ideologies.  
One of the keys to establishing successful relations with business partners is undoubtedly the trust between both parties and an approachable, friendly and at the same time professional manner.  Therefore, all employees and partners must promote this attitude and commitment, thus strengthening the growth of both businesses. 

8. RELATIONS WITH INSTITUTIONS, AUTHORITIES, OFFICIALS

International standards for the prevention of corruption and bribery will  govern the relations of the company’s members with authorities, institutions and public officials.
Any decision taken in this area will comply with the applicable internal and external rules and will be documented for possible internal or external control.
Under no circumstances will VICTRIX offer, request or accept gifts, favours or compensation from authorities, institutions or officials. Gifts or hospitality of a small value, proportionate and reasonable in view of local practice, will be exempted from this form. In any case, cash gifts will be prohibited.
Payments are prohibited in order to expedite any kind of processing.
Careful and explicitly vigilant monitoring of compliance with the obligations arising from the awarding of any type of grant or aid will be maintained. 

9. CONFLICT OF INTEREST

Employees will avoid situations where their personal interests conflict with those of the company.
Employees, whatever their rank or role, may not use their position in the company to gain particular advantages or business opportunities or provide services to competing companies.

If there is any doubt as to whether an activity to be carried out may involve a conflict of interest, the body responsible for compliance with this Code will be consulted.
VICTRIX believes that the relationship with its employees should be based on loyalty born of common interests. Employees’ involvement in other financial or business activities will be respected as long as they are lawful and do not conflict with their responsibilities as this company’s employees.

All employees must disclose external activities, financial interests or relationships that may present a potential conflict of interest or the appearance of a conflict. They must also comply with the law and this company’s policies.
The managers of each department will be responsible for training on how to perform duties in the warehouse according to oral instructions. 

10. USE OF COMPANY GOODS AND SERVICES

Efficiency will inspire the use of the company’s goods and services.
The company provides employees with access to email, internet, intranet, telephones and other forms of communication technologies in order to carry out their work more productively and effectively. It is everyone’s responsibility to maintain the confidentiality, integrity and availability of our technology and communications infrastructure.

It is the employee’s responsibility to use the company’s resources responsibly, efficiently and appropriately in the context of their professional activity. Employees will also be responsible for ensuring the safety of the facilities in terms of access.

Downloading or installing illegal or unlicensed software, applications or content is not permitted. Intellectual property laws will be respected in all cases.
All information relating to usernames, passwords and authentication devices on computer systems will be controlled and kept secret, and any possible security risks or incidents in this regard will be reported.

11. DATA PROTECTION POLICY

Confidentiality and diligence in the use of data will govern the actions of the recipients of this Code. This principle must be respected even after the relationship with VICTRIX or any company of the Group has been terminated.

Company information may not be used for private gain, nor communicated to third parties; this information will be considered confidential and must be used for the exclusive purpose for which it was obtained.
Respect for the personal and family privacy of persons to whose data they have access is required.
All personnel should be aware of and respect the company’s internal procedures on data storage, custody and access.
Any incident related to data confidentiality will be reported to the relevant department or to the body in charge of compliance with this Code.
The personnel considered to be company management, will maintain absolute confidentiality of all VICTRIX data, and will be responsible for all operations carried out.
Other employees, although they may not have full access to all information, will also be responsible for the confidentiality of the information to which they have access. 


12. INDUSTRIAL AND INTELLECTUAL PROPERTY RIGHTS

VICTRIX recognises its commitment to protecting its own and others’ copyrights, patents and trademarks and requires the same commitment from its suppliers.
We are all committed to reporting any irregularities in this area.
Particular attention will be paid to incorporating copyright notices on materials, information, products, services and any company documents intended for public distribution.
In their relations with third parties, employees will scrupulously follow the relevant rules and procedures to avoid infringing the rights of third parties, respecting the valid intellectual property rights of others. 

13. CORPORATE IMAGE

One of the main assets of VICTRIX is its good image and reputation in the market as a result of the trust placed in it by customers, suppliers, employees and all the companies of the group in general.

So as not to damage or lose the good image and reputation achieved during all these years, all VCTRIX employees must do their utmost diligence, both personally and professionally, to preserve and guarantee the good image and reputation achieved by VICTRIX.

In any case, employees are not allowed to make derogatory or defamatory remarks or to disclose confidential information.  

14. OCCUPATIONAL RISK PREVENTION AND HEALTH AND SAFETY POLICY

VICTRIX will ensure a safe working environment, complying with current occupational health and safety regulations. VICTRIX trained workers in the prevention of occupational hazards, providing them with a manual or protocol and has a record of the training given. Every employee agrees to complete any training that is held to improve their ability to perform their work responsibilities safely and to make responsible use of company materials and equipment. It is important that each worker understands the hazards and the safety practices to be adopted for any job.

All employees will maintain a vigilant attitude in the workplace and report any safety concerns to their manager, the HR department or the body responsible for compliance with this Code.

The possession, use, purchase, sale, attempted sale, distribution or manufacture of illegal drugs in the workplace, as well as the use of alcohol, illegal drugs and the misuse of prescription drugs while performing work-related activities is strictly prohibited. Concealing work-related accidents or very serious incidents, falsifying safety records or ordering non-compliance with safety regulations is also strictly prohibited.

Employees who contravene these rules will be subject to disciplinary action. The HR department will ensure that company records contain your up-to-date emergency contact information. 


15. TRADING AND REPORTING RECORDS

VICTRIX will keep a proprietary financial and accounting record. Financial and accounting records must be complete, accurate and not misleading as this information is the basis for both internal and external reporting to governmental and regulatory authorities and other entities.
All books, records and accounts, including time sheets, sales records, invoices, receipts and expense reports, stored in files, must be complete, accurate and reliable. All information is the sole property of VICTRIX and therefore no employee may dispose of or remove from the company any VICTRIX-owned documents, even if they have access to them.
Falsification of any document or any misrepresentation of data relating to a particular transaction is not permitted.  
Transactions must be recorded in a timely manner and supported by appropriate documentation. No expenditure will be incurred or paid out of company funds unless authorised by the relevant person.   

16. DOCUMENT RETENTION 

VICTRIX complies with legal and regulatory requirements relating to the retention and disposal of documents and records. All records and information will be handled in a manner that ensures that:  

The archiving, storage and retrieval of recorded information.
Record keeping, in whatever format, satisfies legal, fiscal, regulatory and operational requirements.  
The necessary documentation is available in the event of legal proceedings.  
VICTRIX has a records retention plan.      

17. ENVIRONMENTAL COMMITMENT 

The company agrees to ensure respect for the environment, to minimise the environmental impact of all its activities and to promote among its employees a culture of respect for the environment as a principle of conduct in its actions.
 
The company expressly states its commitment to protect the planet from degradation, including through sustainable consumption and production, sustainable management of its natural resources and urgent action to address climate change, so that it can meet the needs of present and future generations.

VICTRIX is committed to providing its employees with a safe and healthy working environment and we are all committed to conducting our operations in a manner that ensures compliance with environmental regulations, avoiding any negative impact on the environment.  

The company’s employees must know and accept this policy and act at all times in accordance with the criteria of respect and sustainability, and adopt habits and conduct of good environmental practices and contribute positively to achieving the established objectives. Employees must also strive to minimise the environmental impact of their activities and the use of the facilities, equipment and work resources made available to them.  

18. CODE COMPLIANCE, CONTROL AND DISCIPLINARY REGIME  

The Internal Compliance Body is made up of:  

i. Mr. Alberto Salvano
ii. Mrs. Carolina Lahuerta

The Internal Compliance Body is the body in charge of ensuring compliance with and dissemination of this Code to all company personnel. This body will be responsible for receiving communications concerning allegations of non-compliance with this Code or queries on its interpretation.  
This body may act on its own initiative or at the request of any recipient of the Code and its decisions will be binding on the company and the employee.
Failure to comply with the Code may lead to employment consequences, apart from any administrative or criminal consequences.  

19. PUBLICATION, UPDATING AND AVAILABILITY OF THE CODE 

The Code comes into force on its publication date on 10/06/2023 and will be sent to all company members, and will remain in force until its cancellation is approved, for an indefinite period of time. It will be updated whenever the Compliance Body identifies the need or is alerted by any employee.