Code of Conduct

The mission of Interfaces Hombre Máquina Avanzados S.L. (IHMAN) implies on provide value to companies and industries through technological and innovational projects with good quality that can and will improve our clients' objectives. IHMAN strives to be the leader in I+D+i development. To achieve this objective it is necessary the greatest level of professionality in all our processes. This code of conduct is an example of the professionality that we strive for, and the one that we expect from our collaborators.

As an ethic, socially responsible and respectfull with the environment company, IHMAN gives extreme importance to the threatment with employees, clients, authorities and the general public. The success of it's commercial operations depends on its capacity to mantain trust with these people and groups of interests. This code of conduct is fundamental to the task of creating and mantaining this trust.

IHMAN considers this code of conduct as essential and that it also needs to be an integrant part of employment's conditions of the company. IHMAN will asure its absolutly review.

Why it is necessary a Code of Conduct?"

IHMAN adopted this Code of Conduct in order to define the values that it's employees must follow.

These values are based on:

• The support and respect of human's rights internacionally recognized.
• An ethical behaviour and according to the law.
• The IHMAN's loyalty.
• The correct threatment, polite and respectfull between coworkers.
• The correct consideration with the environment and with people's interest related to the company, including clients, authorities, shareholders and general public.
• The professionality and correction on company's activity development.
• Our commitment with Mundial Pact of the United Nations.

Scope

This code is applied to the following areas:

• Personal obligation.
• Discrimination.
• Conflicts of interests.
• Bribes, comissions, entertainments and gifts from the company.
• Abuse of privileged information.
• Competency's defense.
• Law's compliance.
• Use and protection of company's assets and information.

This Code of Conduct will be applied in all IHMAN's operations and complements the actuals or futures standards, guidelines and rules established by IHMAN, the group that belongs (Group DIANA) and its Sectors.

The spirit of this Code of Conduct determines the interpretation of any other rule, guideline or regulamentation established by IHMAN.

We make our best to certify that people related to our company, inclusive clients and suppliers, understand our rules and guidelines and will in a possible way act in respec with this determined scope.

Personal obligations

All employees must follow the law and observe high ethical principles.

Must show social responsability with the environment, professionality, and make use of the correct business practices on their job's performance.

The transparency, trust and integrity are essential values of IHMAN that must be respected. The employees also have to be familiarized with the correct business practices and must always exerce them.

The employees must use their good and common sense in all situations when legal requisits or business practices are not clear. They also should ask for advice or indication to their superiors when those situations appear.

Many of these requisits have been, in an explicit or implicit way, established in the reules and guidelines of the company and its Sectors. Many of those responsabilities are imposed by society and governments, and are speacially importants IHMAN's activitie's field. This code fill inside a general context.

Discrimination

All employees have the right of a good threatment, polite and respectfull from their superiors, subordinates and coworkers.

IHMAN will not accept discrimination or any manifestation for reasons of race, religion, faith, nationality, gender, disability, age, or any other reason.

All employess must behave according to this content and the spirit of these principles.

Conflicts of interests

The commercial transactions must be conducted taking into account IHMAN's interests.

Nothing, no one, not even an entity, or a company that have relation with an IHMAN's employee, can improperly benefit from IHMAN through this employee or as a consequency of this employee's position inside the company. Furthermore, no employee can personally benefit in an improperly way.

Need to be avoided all situations where conflicts between an employee's responsabilities and his personal interests can appear.

Nevertheless, ocasionally conflictos of interests o similar situations can emerge. If one of these situations appear, the communication between employer and employee is extremely important and both parts must try to solve the problem in a good way.

Bribes, comissions, entertainments and gifts

No employee will make any payment, or will bribe and offer inapropriate economic adjavantages to a public employee or to a dependet entity of the administration with the objective of receiving commercial threatment or other services, as it is established in the OCDE convention to combat the corruption of foreign public's employees.

The national rule that reflect this convention must be strictly followed.

The gifts given from the company to public employees, when allowed, must be done according to the general rules of IHMAN's spends and also according to the rules and regulations of the official organism or the legislative group of interests.

It is not allowed to appeal to thirds terceros in order to avoid any of the dispositions mentioned before.

Improperly use of privileged information

The employees that have access to privileged information about IHMAN or any other company connected to IHMAN are not allowed to sell, buy or deal with stocks or other values of IHMAN or products derived from those, and also can't reveal this information to thirds.

The privileged information is the one where a reversor can consider important at the moment of decide the buying or selling of stocks. At this it is included, for exemple, confidential information about plans of other company's aquisition, strategic alliances, the economic balance, products discovering, or changes at the capital's structure or important agreements (for example the constitution of a new company)). Both information and data of public caracter are not considered privileged information.

The employees must abstain of reveal privileged information to thirds, including their friends and family.

The restrictions with respect to privileged information will continue valid until the plans, events or transactions are made public and the information about the event is enough widespread between the public.

The improperly use of privileged information can result in civil and penal sanctions.

Defense of Competition

Fulfillment

IHMAN and its employees must respect the principles and rules of the fair competition and must not violate the correspondent laws of the competition defense.

The laws of the competition defense afect all comercial agreements, independent of its form, as the practice of the business activity in general. However, the commercial transactions are normally not affected between companies of the same group (inside the group DIANA).

In a general rule, the laws of the competition defense not only afect the commercial acting inside a concrete country but also is applied to all comercial's actions, including out of the country,in case that this exercise a considerable effect over the competition.

Agreement's notifications

Due to the complexity of the legislation of the competition's defense, all agreements with competitors or thirds that can bring negative effect about the competitivity, must be verified by the Juridic Advice.

Between the clauses that can effect negatively the competitivity are the following examples:

• Exclusivity's clauses.
• Clauses over prices.
• Clauses of association.
• Territorials' restrictions.
• Discrimination of prices.

Agreements and alliances forbidden

It is forbidden all agreements between competitors when tha objective is coordinate their behavior in the market. Between these behaviors are included:

• Agreements of prices fixation.
• Sales agreements that limit the type of products that can be offered or that link the products' buying to other purchase.
• Agreements about the territorial division, types of clients or production's quotas.
• Agreements to perform a boycott, for example, supplies negation or deliveries received.

Abuse of a dominat position

The abuse of a dominat position in a specific product's market is illegal. The word “abuse” is refered to situations where the power of the market's domain is done in detrimental of providors or clientes. At the markets where IHMAN is a strong competitor, it will be necessary to pay an special attention through the Juridic advice to the strategies and marketingś methods.

Acquisitions

The laws of the competition defense normally forbid the acquisitions that lead to a dominant position at the market and with it can affect the competition in a negative way.

Therefore, at the majority of countries, before you can perform some acquisitions it is necessary notify the competent authorities.

Rights of the intelectual property

The contracts related to the use of the intelectual property's rights-patents, rights over varieties'rights, commercial brands, diseños, copyright, know-how and industrials' secrets-, are exposed to special rules and with frequency have an extreme importance in respect to the competitive right. Therefore, in these cases it is specially necessary the juridic advice.

Law enforcement

The law enforcement is is an inconditional requirement to IHMAN and its employees.

All employees must be familiarized with the laws that concern their work, and the supervision will be responsible of providing the instructions and advice necessaries.

For exemple, IHMAN is completely compromised with the application of fair labor conditions and not discriminatories, with the protection of the environment and the assurance of health and safety of its employees. IHMAN expects that its employees perform with all the rules related to health and safety at work and protection of the environment, que sus colaboradores cumplan con toda la normativa relativa a la seguridad y salud en el trabajo y protección del medio ambiente, obtain all necessary permits and use its instalations with estrict observancy of the law.

Due to the complicated regulatory framework where IHMAN perform its activity, can emerge related questions with the laws fulfillment. It could happen that emerge interpretation's differences about if IHMAN fulfill the law or not, and a diversion beggin. In all the cases, IHMAN will act at the same responsible way and will respect the final decisions of the courts.

It could also be presented problems of adequation to the requirements of official's organisms. It is important that the direction of IHMAN is aware of it the earliest possible. Each employee have the obligation to inform immediatly to IHMAN's direction in case that consider that can exist a problem of this type.

Use and protection of company's actives and información

The correct business practice imposes the correct use and protection of IHMANś actives.

In particular, the information and industrials' secrets must be protected being confidential and if appropriate using the complementary protection form through the intelectual properties'rights.

IHMANś employees that receive or are aware of confidential information or industrials information of IHMAN or others, can not reveal these information to thirds (including friends and family) for commercial objectives, and also can not use these information to any other objective that is not connected to the company's business. Furthermore, they must adopt reasonable steps that are necessary in order to protect the information that is considered confidential or industrials secrets.

The management and difusion of the information is a direcction's task and all employees must respect the necessity of IHMAN in a professional management of the information. Every employee must keep in a confidential way the relevant information including when there is no clear obligation of keeping it secret.

IHMAN perform its investigations of vanguard at the ciency and la technology field, and keep an intense exchange of information with universities, investigation institutes, and with organizations and competitors'companies. IHMAN respect the liberty and academic traditions of its partners and the necessity of its cientifics of publicing results. Nevertheless, the employees and partners of IHMAN must respect IHMAN's interests allowing that IHMAN request the correspondents rights of intelectual property every time that it is convenient.They must also respect the confidenciality of the information or of delivered materials to IHMAN or to thirds.

Control

Every employee will receive a copy of this Code of Conduct. It is responsability of the direction include this Code of Conduct in the formation programs of the employees. The direction will control the fulfillment of this code and, when necessary, will put in practice specials programs of verification.

The terms' fulfillment of this Code of Conduct from the employees side can motivate the adoption of pertinent disciplinary actions, including dismissal.

The employees must inform about the violations of this Code of Conduct to their supervisors. There will not have punishment for this information. However, this do not implies on immunity to the offenders.

Application

This Code of Conduct will be applied in all sectors of IHMAN. The business council of IHMAN's subsidiaries will adopt to this objective the appropriated actions.