Good Governance

PONS IP, S.A. has implemented a Regulatory Compliance or “Criminal Compliance” System that complies with the requirements of Article 31 bis of the Criminal Code introduced by Organic Law 1/2015, of 30 March, which amended Organic Law 10/1995, of 23 November, of the Criminal Code, and came into force on 1 July 2015.

The PONS IP Criminal Regulatory Compliance System, adopted by the Board of Directors, consists of the Compliance Policy Statement, as well as the Compliance Manual, executive summary and supplementary annexes. 

MINUTES OF THE RESOLUTION ADOPTED BY THE ADMINISTRATIVE BODY

The administrative body of PONS IP approved the “Compliance Policy” and the company’s crime prevention and regulatory compliance plan. The compliance body responsible for monitoring the functioning and observance of the prevention and detection of possible crimes within the framework of the company’s activities, as well as for supervising and monitoring the effectiveness of internal controls for the prevention of crimes and compliance with the ethical standards set in the company is also established.

COMPLIANCE POLICY OR “COMPLIANCE” STATEMENT

The compliance policy sets out the general principles that inspire its content and that apply to all internal rules of PONS IP and affect all members and the actions they carry out.

COMPLIANCE MANUAL

Document describing the organisation, compiling and explaining PONS IP’s risk map, possible criminal conduct at risk of being committed, and the surveillance and control measures implemented or to be implemented at PONS IP.

GENERAL CODE OF CONDUCT OR CODE OF ETHICS

Internal company code that sets out the basic guidelines and general principles that must govern and be applied in the actions of PONS IP employees. This Code has been designed to serve as the “cornerstone” of PONS IP’s compliance culture, which aims to guide the actions of all its members in the performance of their duties and in their commercial and/or professional relationships. It is not merely a programmatic ethical rule. Rather, it is a mandatory rule for PONS IP employees, and failure to comply with it may result in labour-related or even criminal sanctions.

GENERAL POLICY ON RELATIONS AND CONTRACTS WITH CUSTOMERS, PARTNERS AND/OR SUPPLIERS

The purpose of this policy is to establish guidelines or models of behaviour complementary to the General Code of Conduct for PONS IP employees in their relations and/or contracts with: 

• Customers; 
• Partners and/or suppliers; 
• Public Administration, Public Entities, authorities, public officials or public administrative personnel.

GENERAL CODE OF CONDUCT FOR PARTNERS AND/OR SUPPLIERS

The purpose of this Code is to ensure that PONS IP partners and/or suppliers conduct their business activities in accordance with the PONS IP General Code of Conduct. Specifically covering: 

• Principles of conduct for partners and/or suppliers.
• Ethical behaviour and measures against bribery and corruption.
• Safety and the environment.
• Information provided to third parties.
• Responsibility of partners and/or suppliers.

ETHICS CHANNEL

PONS IP has implemented an Ethics Channel so that anyone can report to the compliance body any activity, conduct or event that may constitute criminal behaviour or a breach of administrative regulations or the company’s internal policies. To access this channel, please use the following link.

DISCIPLINARY SYSTEM

PONS IP has established and communicated to its employees a disciplinary system as a means of sanctioning actions that violate PONS IP’s internal procedures and regulations.

The sanctions have been determined taking into consideration the applicable Collective Agreements, as well as the provisions of the Workers’ Statute and/or specific applicable regulations.

Last modified in September 2025.