Code Of Ethics

We define our Code of Ethics as a document that serves as a guide for developing work processes, strategies, and coherent decision-making, following a set of guidelines that take into account both the internal and external interests of the company.

General matters

Our company provides equal opportunities and seeks to foster a work environment that attracts and develops talent of all genders, nationalities, generations, cultures, religions, and backgrounds, respecting and valuing individual differences.

In line with this commitment, the company will treat all its employees fairly and will not tolerate any form of harassment or discrimination in the workplace.

Allwina expects its employees to interact with each other and with anyone related to the company with courtesy, respect, and dignity, regardless of hierarchy or contractual conditions, both inside and outside the workplace.

This principle applies not only individually to each member, but must also be understood as a collective ethical guideline. Responsibility is linked to compliance with the company’s rules and commitments, making decisions based on shared values and seeking to exceed the expectations of others.

 

Non-Discrimination Policy

With the aim of continuously improving the work environment, in accordance with national labor law and based on the belief in equal opportunities, we maintain a non-discrimination policy, promoting diversity and respecting the rights of all people.

Likewise, it is against our policy and the law to hire minors or to promote forced labor.

The company does not discriminate on the basis of:

• Gender
• Race
• Color
• Disability
• Political opinion
• Sexual orientation
• Age
• Religion
• Nationality and/or immigration status (including refugees)
• HIV status
• Union membership
• Social origin

Confidentiality

In our effort to be a trustworthy company, we must protect the information of our employees, colleagues, participants, service providers, clients, and suppliers. In the course of our work, we often access personal and employment data of others, the irresponsible disclosure of which can harm both their rightful owners and third parties, negatively impacting our image as a reliable company.

Therefore, it is necessary to handle information with special responsibility, control, and protection, using it strictly for institutional purposes.

Maintaining confidentiality and properly handling information is a fundamental principle we consider essential to establish ourselves as a committed and trustworthy company.

Bribery and Corruption

This policy covers our principles and requirements regarding the fight against bribery and corruption, as well as the maintenance of proper documentation and financial records of the company.

This policy complies with relevant national and international legislation. In case of any conflict between our controls and the law, the stricter rule will apply.

We have zero tolerance for any form of corruption.

Corruption includes, among other practices:

Bribery: We do not promise, offer, give, authorize, request, or accept, directly or indirectly, any financial or other advantage to or from any person in order to obtain or retain business or secure an improper advantage in the course of our work.

Financial or other advantages: These include anything of value, such as cash, gifts, services, job offers, loans, travel expenses, leisure activities, or invitations. Private funds cannot be used to circumvent this policy.

Facilitation payments: These are considered bribes and are prohibited. “Facilitation payments” are unofficial, improper, small transfers of value made to secure or speed up a routine or necessary action to which we are legally entitled.

Money laundering: We do not engage in transactions involving proceeds, property, or consideration derived from criminal activities, including bribery, fraud, or tax evasion.

Tax evasion: We do not facilitate tax evasion.

Fraud: This applies both to our interactions with public officials and private sector employees.

Non-compliance with this policy constitutes illegality and may result in legal and disciplinary sanctions, including dismissal, fines, or imprisonment.

We are committed to maintaining accurate financial records. Private funds will not be used to circumvent this policy.

Complaints

This Complaints Policy reflects Allwina’s commitment to promoting an ethical and transparent environment, where employees, suppliers, clients, and any stakeholders can confidentially and safely report any suspected or known irregular activity, misconduct, or ethical violations within the organization.

Scope:
This policy applies to all employees, contractors, suppliers, clients, and any other stakeholders related to Allwina. Reportable irregularities include, but are not limited to fraud, corruption, discrimination, harassment, embezzlement, legal violations, conflicts of interest, and any other unethical or illegal activity.

Guiding principles:

• Confidentiality: The identity of the whistleblower will be protected as far as possible, unless disclosure is required for investigation or legal compliance.
• Protection against retaliation: Allwina strictly prohibits any form of retaliation against good-faith whistleblowers. Any retaliation will be treated as a serious violation.
• Impartial investigation: All reports will be investigated objectively and fairly by a designated team.

Reporting channels:

• Email: hello@allwina.com
• Public reporting form via the company website and social media
• Direct managers or supervisors

Reporting procedure:
Whistleblowers must provide detailed and accurate information, including names, dates, locations, and descriptions of events. The company commits to timely investigations and appropriate action. The whistleblower will be kept informed of progress where possible, respecting confidentiality.

Corrective action:
If confirmed, appropriate disciplinary and corrective measures will be taken, which may include legal action, termination of employment, or improvements to policies and procedures.

Communication and training:
This policy will be communicated across the organization, with periodic training on ethical reporting and procedures.

Review and updates:
This policy will be periodically reviewed to ensure effectiveness and relevance, and updates will be communicated accordingly.

This Whistleblowing Policy reflects Allwina’s commitment to maintaining the highest ethical and integrity standards in all its operations.