ETHICS CODE

1. OUR MISSION
By implementing this Code in REALTRACK SYSTEMS, it is intended to promote the development of human excellence of our employees and collaborators, in addition to assuming authentic human values and turn them into a habit of conduct.

Likewise, through this Code and its acceptance, our collaborators will be asked to be participants of it, as well as being honest and trustworthy at all times.

If there are laws, practices or internal procedures applicable to natural and legal persons subject to this Code that are stricter than its provisions, those will enjoy pre-eminence.

2. BASIC PRINCIPLES OF BEHAVIOUR
The business and professional behaviour of the entities and persons subject to this Code must comply with the following basic principles:

2.1. Respect for the law
The activities of REALTRACK SYSTEMS will be developed in strict compliance with the applicable legislation.

2.2. Ethical integrity
The business and professional activities of REALTRACK SYSTEMS and its employees will be based on the values of integrity, honesty, avoidance of all forms of corruption and respect for the circumstances and particular needs of all the subjects involved in them.

REALTRACK SYSTEMS will promote among its employees the recognition and assessment of behaviors that are in accordance with the principles established in this Code.

2.3. Respect of human rigths
All actions of REALTRACK SYSTEMS and its employees will respect scrupulously the Human Rights and Public Liberties included in the Universal Declaration of Human Rights.

These basic principles will be translated into compliance with the commitments that will be gathered below.

3. RESPONSIBILITY OF EMPLOYEES AND EXECUTIVES

3.1. Responsibilities of employees and executives
All employees must adhere to the principles and requirements contained in this Code and ensure that other individuals or groups that carry out activities on behalf of REALTRACK SYSTEMS, including contractors, agents, consultants and other business partners, do so as well.

All employees who become aware or have founded suspicion of a breach of this Code must notify their superiors or communicate through the mechanisms established to make suggestions and submit complaints.

All managers must ensure that their employees know and respect the behavior set forth in this Code.

The management and the directors will have to ensure that all the surveillance procedures established to guarantee compliance with this Code and the policies and procedures of REALTRACK SYSTEMS work correctly, notifying their superiors otherwise.

3.2. Breaches of the code
In the case of employees, failure to comply with this Code may constitute a labor infraction and be subject to appropriate sanctions, regardless of other responsibilities in which the employee may have incurred.

4. RELATIONS BETWEEN EMPLOYEES WITHING THE COMPANY
The relationship between REALTRACK SYSTEMS and its employees, as well as the one between the employees will be based on compliance with the following commitments:

4.1. Respectful treatment and non-discrimination
REALTRACK SYSTEMS assumes the responsibility of maintaining a work environment free of all discrimination and any conduct that involves personal harassment. Every worker must be treated fairly and with respect by his superiors, subordinates and colleagues. Any abusive, hostile or offensive behavior, whether verbal or physical, will not be tolerated.

4.2. Abolition of child labour
REALTRACK SYSTEMS does not support child labour. REALTRACK SYSTEMS will not resort to child labour or incorporate into its business any product or service from it and will ensure compliance with the provisions of the International Labour Organization (ILO) in relation to the work of minors.

4.3. Equal opportunity. Wages and benefits
All employees will enjoy equal opportunities for the development of their professional career regardless of their age, sex, marital status, race, nationality and beliefs. REALTRACK SYSTEMS is committed to establishing an effective equal opportunity policy for its employees to develop their professional activity based on the principle of merit. Promotional decisions will always be based on objective circumstances and assessments.

Likewise, REALTRACK SYSTEMS is committed to maintaining an investment policy for learning and personal and professional training of its employees.

Employees will receive full and legal compensation for all hours worked. In addition to the compensation for regular work hours, employees will be compensated for overtime at the legally required rate.

4.4. Freedom of association and right to collective bargaining

In REALTRACK SYSTEMS, it is recognized and respected the right of workers to join (or not join) organizations and associations that they choose without sanctions or interference. Bargain collectively is also recognized and respected.

4.5. Occupational health and safety

REALTRACK SYSTEMS will provide its employees with a safe and stable environment, will keep the occupational risk prevention measures up-to-date and will scrupulously respect the regulations applicable in this matter in all the places where the business activities are developed.

All employees are responsible for observing strict compliance with health and safety regulations in order to protect themselves and other employees or third parties. In addition, they will spread knowledge among their colleagues and subordinates and promote compliance with risk protection practices.

4.6. Respect for employees’ privacy and data protection
REALTRACK SYSTEMS undertakes to request and use exclusively those data of the employees that were necessary for the effective management of the business or whose constancy was required by the applicable regulations. Likewise, REALTRACK SYSTEMS will take all the necessary measures to preserve the confidentiality of the personal data and guarantee that the confidentiality in the transmission of these, when it is necessary for business reasons, complies with the current legislation.

Employees who, in the performance of their professional activity, have access to information from other employees will respect and promote the confidentiality of this information and will make a responsible and professional use of it.

4.7. Conciliation of private and working life
REALTRACK SYSTEMS values the benefits for the employee and for the company that implies the existence of a balance between the professional and personal responsibilities of its employees, for this reason, measures aimed at reconciling these two areas will be encouraged.

5. COMPLIANCE WITH APPLICABLE LAWS

5.1. Relation with public authorities
Employees who interact with public authorities on behalf of REALTRACK SYSTEMS must ensure that all communications, both direct and through intermediaries, are accurate and comply with all applicable laws and regulations, including those pertaining to lobbying and anti-corruption groups.

5.2. Laws against money-laundering

Employees must comply with all anti-money laundering laws, maintain business only with reputable partners and receive funds only from legitimate sources. Employees must take reasonable measures to detect and prevent unacceptable or suspicious forms of payment, and inform their superiors or report them through established channels if they have any suspicions or concerns.

5.3. Fair competition
REALTRACK SYSTEMS condemns and marginalizes any action that involves the practice of illegal practices of unfair competition and undertakes to ensure compliance with the laws of defence of competition applicable in the countries where it carries out its activities.

6. COMMITMENT TOWARDS THE COMMUNITY

6.1. Natural environment
REALTRACK SYSTEMS will seek the greatest possible respect for the environment in which it carries out its activities and will minimize the negative effects that, eventually, these may cause. It will make available to its employees the most appropriate means for this purpose. In addition, best practices will be established, as well as the promotion among employees of the knowledge and its use.

REALTRACK SYSTEMS is committed to strict compliance with applicable environmental legislation.

6.2. Social commintment
REALTRACK SYSTEMS is committed to a socially responsible performance, in compliance with the law of the countries in which it operates and, in particular, assumes the responsibility to respect cultural diversity and current customs and principles among the people and communities affected by its activities.

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