ETHICS CODE OF Hiberus Tecnologías de la Información, SL.


Hiberus Tecnología is a company specialized in business consulting and the provision of technological services and outsourcing. It is the leading technology company in the Ebro Valley, a reference in the Spanish market, and in the process of expanding into the Latin American market. Hiberus is part of one of the main business groups in the ICT (Information and Communication Technology) sector in Spain, HENNEO, made up of more than 2,300 professionals and with a turnover of over 100 million euros.


Hiberus Tecnología offers a wide range of technology and business solutions (Business Consulting, Solution Implementation, AMS, Software Factory, BPO, Outsourcing, Managed Services, and Systems Integration) under a hyper-specialization model where our more than 2,300 professionals are distributed in areas of expertise with the aim of providing clients with the flexibility, efficiency, and added value of a small specialized company but with the solvency of a large company and a presence throughout the value chain. With this document, we want to share our code of ethics, which, guided by the Ethical Code and internal regulations of the Henneo group and based on Hiberus' own values and commitments, constitutes the framework on which we develop our specific policies.




Purpose and scope of the Ethics Code


The Ethics Code of Hiberus is the document that establishes the criteria for action to be observed by the company in the performance of its professional responsibilities towards employees, clients, suppliers, and any other stakeholders who may interact with the organization. It is based on our mission, vision, and values, previously stated, and the Ethical Code of the Henneo Group, approved for the first time by its Board of Directors at the meeting held on June 21, 2016. We adhere to it as a company belonging to the group.


As stated in the aforementioned Ethical Code, it is important for Hiberus Tecnología to ensure ethical and responsible behavior by all its members, beyond mere compliance with the law.


This Code applies to all Hiberus Tecnología personnel, regardless of their position or role. The application of the Code, in whole or in part, may be extended to any individual and/or legal entity related to the company, when deemed necessary for the fulfillment of its purpose and possible due to the nature of the relationship.


No person, regardless of their level or position, is authorized to request an employee to violate what is established in this code, just as no employee may justify improper or illegal conduct by invoking a superior's order.


Our commitment to compliance with the law


Compliance with regulations is a necessary requirement of this code. As has been the case since Hiberus' inception, we are committed to always acting in accordance with the current legislation in each of the countries in which we operate. In addition to complying with the applicable laws, all our employees must adhere to the internally established rules and procedures, as well as those that may be developed in the future. Under no circumstances should these internal regulations lead to a violation of current legal provisions.


To facilitate proper internal control, employees' decisions will be traceable from the perspective of regulatory compliance, so that the alignment of decisions with internal and external standards can be justified, verified, and reviewed by competent third parties or the company itself. Hiberus Tecnología is committed to providing the necessary means for its employees to be aware of and understand the internal and external regulations necessary for the exercise of their responsibilities.


Furthermore, through this code, we want to materialize the principle of due diligence oriented towards the prevention, detection, and eradication of irregular behaviors, regardless of their nature, taking into account the principle of criminal liability of legal entities established in the Spanish legal system by Organic Law 5/2010 of June 22nd and Organic Law 1/2015 of March 30th. In order to comply with this due diligence, Hiberus Tecnología establishes a Crime Prevention Management System, which includes, among others, procedures to control the knowledge and compliance with this code, systems to report possible non-compliance, procedures for the identification, assessment, and treatment of different criminal risks that may arise from the nature of the activities carried out by Hiberus Tecnología.




1. 1. General principles related to people


At Hiberus Tecnología, we are aware of the importance of the people who make up our company. Hiberus employees are the voice and brand of the company. We have UNIQUE, involved, and committed INDIVIDUALS who make a difference. That is why it is essential to maintain the following commitments, as they are the main RESPONSIBLES FOR Hiberus' SUCCESS.


1.1.1. Non-discrimination and equal opportunity principles, respect for dignity, integrity, and privacy


We promote non-discrimination based on race, color, nationality, social origin, age, sex, marital status, sexual orientation, ideology, political opinions, religion, or any other personal, physical, or social condition, as well as equal opportunities among them.


In particular, we advocate for equal treatment of men and women in terms of access to employment, training, professional promotion, and working conditions. As a demonstration of this commitment, the company approved its first Equality Plan in June 2016.


We implement preventive measures and reject any manifestation of violence, physical, sexual, psychological, moral, or otherwise, abuse of authority at work, and any other behavior that creates an intimidating or offensive environment for the personal rights of its professionals.


We all commit to maintaining a work environment that respects dignity and personal freedom. Likewise, the relationships between employees and external companies or collaborators will be based on professional respect and mutual collaboration.


We consider the integral development of individuals important, so Hiberus Tecnología will facilitate the necessary balance between professional and personal life.


1.1.2. Labor rights. Safety and Health at work


We defend and promote behaviors consistent with the fulfillment of human and labor rights, and we commit to complying with regulations and good practices regarding employment conditions, health, and safety in the workplace.


All employees are responsible for knowing and rigorously complying with health and safety regulations at work and ensuring their own safety and that of the people affected by their activities. The consumption of substances that could affect the proper fulfillment of professional obligations is prohibited.


Believing that the existence of communication channels allows for greater cooperation, we respect the rights of unionization, association, strike, and collective bargaining, and no coercive measures will be allowed to prevent the exercise of these rights.


Believing that the existence of communication channels allows for greater cooperation, we respect the rights of unionization, association, strike, and collective bargaining, and no coercive measures will be allowed to prevent the exercise of these rights.


1.1.3. Selection and Evaluation


Our selection criteria are based on the academic, personal, and professional merits of the candidates and our needs. We evaluate individuals based on their individual and collective professional performance.


1.1.4. Training


We plan training for our employees, promoting equal opportunities and professional career development that will contribute to the achievement of business objectives.


All employees have a duty to actively participate in the training plans made available to them, engaging in their own development and committing to keep their knowledge and necessary skills up to date in order to add value, maintain excellent performance, and foster their professional progress.


Individuals in leadership or management positions should facilitate the development and professional growth of their team members.


We plan training for our employees, promoting equal opportunities and professional career development that will contribute to the achievement of business objectives.



1.1.5. Resources and Means for Activity Development


We commit to provide employees with the necessary and appropriate resources and means for their activity development.


Without prejudice to the mandatory compliance with specific rules and procedures regarding resources and means, individuals within the organization are committed to responsibly use the resources and means made available to them, engaging in activities solely in the interest of the company, ensuring that such resources and means are not used or applied for personal purposes.


The use of equipment, computer systems, and programs provided by Hiberus to employees for their work, including Internet access and operations, must comply with criteria of security and efficiency, excluding any use, action, or computer function that is illegal or contrary to company rules or instructions. In other words, the use of equipment to use illegal software programs or applications, which could damage the image or reputation of Hiberus, or to access, download, or distribute illegal or offensive content is not allowed.


1.1.6. Protection of Intellectual and Industrial Property


Hiberus Tecnología is the owner of the property and rights to use and exploit computer programs and systems, equipment, manuals, videos, projects, studies, reports, and other works and rights created, developed, improved, or used by its employees within the scope of their work or based on the company's computer facilities. The only exception to the aforementioned will be the explicit transfer of ownership of custom-developed software to a third party.


Likewise, Hiberus Tecnología prohibits any deliberate action aimed at infringing the industrial and intellectual property rights of third parties, regardless of the motivation behind such acts. The administrator, representatives, and employees must refrain from using unlicensed software, third-party patents, trademarks, or distinctive signs of other companies without their consent, etc.


All contracts entered into by the company must strictly follow the rules and procedures in this regard to avoid infringing the rights of third parties.


1.1.7. Respect for Corporate Image and Reputation


We consider our image and reputation as one of our most valuable assets to preserve the trust of our partners, clients, employees, suppliers, authorities, and society in general.


All employees must take the utmost care to preserve the image and reputation of the company in all their professional activities. They must also monitor the respect and correct and appropriate use of the corporate image and reputation by employees of contracting and collaborating companies.


Employees must be particularly careful in any public intervention, requiring authorization from the relevant Executive Management to engage with the media, social networks, participate in professional conferences or seminars, or any other activity with public exposure, provided they appear as employees of Hiberus Tecnología.


1.1.8. Loyalty to the Company and Conflict of Interest


We believe that the relationship with our employees should be based on loyalty arising from common interests.


Conflict of interest arises when employees' personal interests, directly or indirectly, conflict with or collide with the interests of the company, interfere with the fulfillment of their professional duties and responsibilities, or involve them personally in any transaction or business operation of the company. Therefore, employees must avoid situations that create a conflict between personal interests and those of the company, refraining from representing the company Without prejudice to the provisions established in specific clauses of each contract, no employee of Hiberus may provide consulting, advisory, managerial, employee, or advisory services to another competing company when there is a conflict of commercial, technical, or contrary interests by the worker, contrary to the good faith of the contract.


1.2. Gifts and Presents


We declare ourselves against influencing the will of individuals outside the company to obtain any benefit through the use of unethical practices. It is also not allowed for other individuals or entities to engage in such practices with our employees.


Individuals who are part of Hiberus are not allowed to give or accept gifts or presents in the course of their professional activities. Exceptionally, the giving and acceptance of gifts and presents will be permitted when the following circumstances simultaneously occur:


  • They are of negligible or symbolic economic value.
  • They are responses to acts of courtesy or customary business attentions.
  • They are not prohibited by law or generally accepted business practices.


Employees of Hiberus may not directly or indirectly offer or grant, solicit or accept unjustified advantages or benefits with the immediate or future objective of obtaining a benefit for the company, themselves, or a third party. In particular, they may not give or receive any form of bribery or commission, whether from or performed by any other party involved, such as public officials, whether Spanish or foreign, personnel from other companies, political parties, authorities, clients, suppliers, or shareholders. Acts of bribery, explicitly prohibited, include the offering or promise, directly or indirectly, of any type of improper advantage, any instrument for its concealment, as well as the trafficking of influence.


Q: To celebrate the end of the year, one of our suppliers sent us a gift basket. The basket contains high-quality items, and I estimate its value to be approximately €100. We have been doing business with this supplier for the past few years. The basket is meant for all the staff to enjoy. Can we accept the gift?


A: You may accept the gift with prior authorization from your immediate supervisor. Such practices may fall within common business standards. However, it is HIBERUS TECNOLOGÍA's policy to receive prior approval. It will be your supervisor's responsibility to determine if accepting the gift would compromise or appear to compromise you in future negotiations.


It is also not allowed to receive, on a personal basis, money from clients or suppliers.


Hospitality that influences, can influence, or can be interpreted as influencing decision-making is not permitted.


When there are doubts about what is acceptable, the offer should be consulted with the Compliance Committee, either through internal communication channels or through your hierarchical superior.


Code of Conduct Hiberus Tecnología


1.3. Confidentiality. Reserved and Confidential Information. Data Protection.


At Hiberus, we consider the acquisition and proper use of information as competitive advantages, so its administration and handling must be done in a responsible, secure, objective, and legal manner.


1.3.1. Information Handling


The information managed by personnel must be treated and reflected in an integral, accurate, truthful, and clear manner. In particular, all economic transactions must be clearly and accurately reflected in the corresponding records through the accounting accounts, as well as all operations carried out and all income and expenses incurred, all in accordance with accounting and contracting procedures.


Additionally, employees must preserve the company's knowledge, facilitating its dissemination to other employees with due transparency when required, and making it available to the knowledge management systems enabled for this purpose, to facilitate activity management and enhance personal development.


1.3.2. Handling of Reserved or Confidential Information


Individuals at Hiberus Tecnología have the obligation to protect the information and knowledge generated within the organization, whether due to ownership or the obligation to safeguard such information.


Employees must refrain from using any data, information, or documents obtained during the course of their professional activities for their own benefit. They should also not disclose information to third parties, except in compliance with applicable regulations, company policies, or when expressly authorized to do so. Likewise, they should not use confidential data, information, or documents from a third-party company without written authorization.


Individuals at Hiberus Tecnología commit to maintaining confidentiality and using any data, information, or documents obtained during their responsibilities within the company in accordance with internal regulations.


In general, unless instructed otherwise, the information they have access to should be considered confidential and used only for the purpose it was obtained.


Additionally, they should not make duplicates, reproduce it, or make more use of the information than necessary for the performance of their duties, and they should not store it in information systems that are not owned by the company unless expressly authorized for specific purposes.


The obligation of confidentiality will continue even after the activity has concluded, including the obligation to return any company-related materials in the employee's possession upon the termination of their relationship with the company.


The following, in an exemplary and non-limiting manner, is considered confidential or privileged information:

  • Accounting information and financial projections
  • Mergers, acquisitions, partnerships, expansion plans, and business plans
  • Securities transactions and financing
  • Commercial and operational policies and practices
  • Judicial or administrative disputes
  • Organizational changes
  • Research and development of new products or services
  • Personal information of Hiberus Tecnología employees
  • Intellectual and industrial property, such as source code, trademarks, patents, and copyrights
  • Customer and supplier lists, structures, and pricing policies


1.3.3. Protection of Personal Data


We strive to respect the personal and family privacy of all individuals, whether they are employees or others, whose data we have access to. Authorizations for data use must be based on specific and justified requests. Employees must strictly comply with internal and external regulations established to ensure proper handling of information and data provided to the company by third parties.


In collecting personal data from clients, employees, contractors, or any individual or entity with whom a contractual or other relationship exists, all personnel must obtain the necessary consents and authorizations, and commit to using the data according to the purpose authorized by the data provider.


Furthermore, all internal procedures implemented regarding data storage, custody, and access must be understood and respected, as they are intended to ensure the different levels of security required according to the nature of the data.


Employees should report to their superior any incidents related to the confidentiality of information or the protection of personal data that they detect.




2.1. Clients


For Hiberus Tecnología, the CLIENT is the center of our business, which is why having sufficient empathy is extremely important. Creating value, initiative, and proactivity are the cornerstones of Hiberus. We must provide our clients with the value they cannot find in other companies. COMMITMENT and ethical behavior, personal and professional integrity, are our way of understanding and conducting our activities.


2.1.1. Relationship with clients


Hiberus' commitment is to treat all our clients fairly, appropriately, and within the framework of the free market.


The relationship with clients should be developed within the framework of the current laws. Therefore, if we identify that a client is involved in illegal or unethical acts, it will directly lead to the termination of our relationship.


Hiberus Tecnología strongly condemns all terrorist activities and will exercise special vigilance when establishing business relationships with new clients who, due to their origin or activities, may be associated with terrorist groups or organizations.


2.1.2. Transparency and integrity in communication


The promotions and sales arguments we use at Hiberus Tecnología are free from false information. We must offer our products and services honestly and accurately. Engaging in deceptive or dishonest practices is a violation of our Ethical Code and will not be tolerated.


Our intention is to provide our clients with complete, transparent, understandable, and accurate information so that they can make autonomous decisions.


2.1.3. Relationship with Public Administrations


The guiding principle in all our relationships with Public Administrations will be strict compliance with the applicable legal framework, taking into special consideration the provisions in the section on gifts and favors.


No hospitality shall be given or accepted that may influence, be perceived as influencing, or be interpreted as influencing decision-making.


When there are doubts about what is acceptable, the offer should be consulted with the Compliance Committee, either through the internal communication channel or through their hierarchical superior.


2.2 Suppliers and collaborators


The development of trust-based relationships and mutual benefit with suppliers has contributed to the success of Hiberus Tecnología. Therefore, we seek to manage our relationships with them with transparency, ensuring equal opportunities, respect, and integrity.


2.2.1. Supplier selection


The supplier selection processes are characterized by seeking the greatest competitive benefit for the company without compromising objectivity and impartiality, and avoiding any conflict of interest or favoritism in their selection.


2.2.2. Relationship with suppliers


Hiberus Tecnología promotes compliance with the provisions of this Ethical Code among its suppliers and recommends that they conduct their activities within the framework of the current laws. All suppliers working with us must commit to respecting the human and labor rights of all employed workers. The violation of any of these principles will not be acceptable under any circumstances by Hiberus Tecnología.


2.2.3. Commitments


The fundamental principle of Hiberus Tecnología is to respect the agreements and commitments established with our suppliers and collaborators.


We also respect intellectual and industrial property rights, and therefore, personnel must establish business relationships with contractors or suppliers who demonstrate that they are duly authorized to use or market products and services.


Hiberus Tecnología offers its suppliers and external collaborators the opportunity to confidentially and in good faith address the Compliance Committee when they believe that the practices of any employee are not in line with the provisions of this Code.


We also commit to accepting that agreements established with our suppliers or collaborators include clauses regarding compliance with certain ethical, social, and environmental standards.


2.3 Market


Hiberus Tecnología competes in the market fairly and does not tolerate deceptive, fraudulent, or malicious conduct that leads to gaining undue advantages.


2.3.1. Commercial or Market Information


The search for commercial or market information by individuals at Hiberus Tecnología will always be conducted without violating the rules that protect it. Individuals will reject information about competitors obtained improperly or by violating the confidentiality under which legitimate owners maintain it.


Individuals at Hiberus Tecnología will also avoid spreading malicious or false information about company competitors.


Agreements with our competitors that unlawfully restrict free trade are not allowed. Such illegal practices may include price-fixing agreements, group boycotts, and bid manipulation.


Individuals at Hiberus Tecnología have the responsibility to report to the Compliance Committee any potential agreement that may contravene this code.


2.4 Partners


Creating value for our partners is a fundamental objective of our organization, and for this purpose, Hiberus Tecnología determines, reviews, and adopts business and financial strategies, maintaining the necessary balance with the objectives of the entire organization.


In any case, maximizing the value of our company will be carried out while respecting the requirements imposed by the law, acting in good faith with the contracts entered into with employees, suppliers, financiers, and clients, and, in general, observing the ethical principles and behavioral criteria provided in this Ethical Code.


The information transmitted to partners will be objective, transparent, truthful, complete, up-to-date, and adequately reflect the company's situation. This principle will be particularly scrupulously adhered to in relation to financial information.


2.5 Social and Environmental Commitment


Hiberus assumes Corporate Social Responsibility (CSR) as a continued COMMITMENT to ethical conduct and CONTRIBUTION to economic development, focused on improving the quality of life of its personnel and society as a whole.


2.5.1. Committed to society


At Hiberus Tecnología, we are aware of and believe in the active role that companies must play within society as drivers of aid and collaboration.


For this reason, we have been collaborating with various social initiatives, such as:


Collaboration with ATADES (Association for the Assistance of Intellectual Disabilities) for the expansion of their facilities and services.


Support for non-profit organizations with high social involvement, such as the UP and Down Association, an association for people with Down syndrome. Collaborating in solidarity initiatives with organizations such as UNICEF or Somos, a virtual community where IT professionals and experts assist NGOs.


Collaboration with the educational community from basic to higher levels, through initiatives such as the 'Ubiquitous' Chair at the University of San Jorge, aimed at conducting joint training activities and research projects in the field of Information Technologies, as well as mentoring final degree projects and internships.


Sports sponsorship. Sponsor of CAI Basket Zaragoza, Club Voleibol Zaragoza in Superliga, and Real Zaragoza. Also, sponsorship of school league teams to promote grassroots sports.


Committed to sector development through leadership in different associations such as TECNARA (Association of Information Technology, Electronics, and Telecommunications Companies of Aragon), CONETIC (National Confederation), and clusters such as Cesla (Free Software) or BIIN (Business Intelligence), as well as sector events like the Noches de las Telecomunicaciones de Aragón and La Rioja.


2.5.2. Committed to the environment


We respect the environment by avoiding any type of pollution, minimizing waste generation, and rationalizing the use of natural and energy resources whenever possible. We have a paperless company commitment.


Reviewing the company's energy efficiency and combating climate change.




3.1. Administration of the Ethical Code


In order to promote its practice and structure the resolution of ethical conflicts, this section establishes the mechanisms for the administration of Hiberus Tecnología's Code of Conduct.


3.1.1. Obligations derived from the Ethical Code. Knowledge and Communication.


All Hiberus employees must read, understand, and comply with this Ethical Code. If necessary, they should remind their colleagues, subordinates, or superiors of the rules and policies. The Compliance Committee should pay special attention to the effective implementation and compliance with this Code. They should also adhere to the procedures and instructions established in the management system that may affect their work.


Any exceptions to the policies established in this Ethical Code and the derived rules, as long as they do not conflict with current legislation, must have the prior written consent of the Compliance Committee, unless explicitly indicated in this Code.


In order for all stakeholders to be aware of this Ethical Code, the procedures of the Criminal Risk Prevention Management System will establish mechanisms to communicate its content. This Code will be made available to anyone interested on the Hiberus website.


3.1.2. Compliance Committee and Communication Channel


To ensure compliance with this Code, among other purposes, the Compliance Committee is established. Its members are elected as established in the HTI003_ME001 Crime Prevention Manual by the Hiberus Tecnología Board of Directors. Its composition, structure, and functions are detailed in the aforementioned manual.


Any Hiberus Tecnología employee who believes that a practice that may constitute a violation of this Ethical Code is taking place must immediately report it directly to the Compliance Committee through the established communication channel:


In order to obtain more information about the alleged misconduct, Hiberus Tecnología guarantees the confidential treatment of any inquiry or report received from managers or employees.


Any form of retaliation against an employee who, in good faith, makes a report regarding behaviors that may violate this Code is expressly prohibited, regardless of the outcome of the investigation into the reported or denounced facts.


All Hiberus Tecnología employees must cooperate in internal ethics investigations. We believe that establishing channels of communication without fear of negative consequences is vital for the proper implementation of our Code.


Any questions regarding the interpretation, scope, and application of this Ethical Code should be referred to the Compliance Committee.


3.1.3. Sanctions


Individuals who are part of Hiberus must adhere to the principles of the Ethical Code. Failure to comply with its provisions will be considered a violation, and the involved individual may be subject to sanctions.


For contractors, whether individuals or legal entities, and for contracts through external agencies, this Code will apply to the extent applicable, and failure to comply may result in the termination of the relationship with Hiberus.


Hiberus Tecnología employees must share the principles of our company. Therefore, they must express their acceptance of responsibility by signing the Commitment Letter they will receive with the Ethical Code.


3.1.4. Approval, Validity, and Effectiveness Review of the Code


The Ethical Code has been approved by the Board of Directors and has an indefinite duration. However, it will be periodically reviewed and updated by the Compliance Committee, taking into account the contributions received from employees or stakeholders.


The Committee will prepare an annual report on the compliance with the provisions of this Code and, if deemed necessary, will recommend the modifications or measures that are pertinent.