Code of conduct and human rights policy

1. Purpose and scope

This Code sets out the ethical principles and the public commitment of Qwi Tecnologías de la Información, S.L. (“Qwi”) to respect human rights, and integrates them into its operating procedures and processes.

It is binding on Qwi’s partners, directors, managers and employees, regardless of position or type of contract. Qwi will encourage its collaborators, suppliers and subcontractors to apply equivalent principles.

The Code complements Qwi’s Integrated Management System, certified to ISO 9001 (quality), ISO 14001 (environment) and ISO/IEC 27001 (information security), and the applicable legislation in each country where Qwi operates.

2. Values and general principles

Qwi adopts as its reference framework the Ten Principles of the United Nations Global Compact, the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights and the Declarations of the International Labour Organization (ILO).

Its activity is guided by these values:

• Integrity: acting with honesty, transparency and good faith.

• Legality: complying with applicable law and internal rules.

• Respect: treating all people with dignity and without discrimination.

• Responsibility: being accountable for its decisions and their social and environmental impact.

• Technical excellence: delivering high-quality, secure and reliable solutions to its clients.

3. Commitment to human and labour rights

Qwi publicly commits to respecting internationally recognised human rights in all its activities and business relationships. In particular:

• No forced or child labour: no form of forced, compulsory or child labour is tolerated, either at Qwi or in its supply chain.

• Equality and non-discrimination: equal opportunities are guaranteed in recruitment, pay, training and promotion, without discrimination on any grounds.

• Respectful workplace: any form of harassment, intimidation or abuse of authority is prohibited.

• Fair working conditions: working hours, rest periods and pay set by law and applicable collective agreements are respected.

• Freedom of association: workers’ rights to freedom of association and collective bargaining are recognised.

• Health and safety: a safe and healthy working environment is guaranteed and work-life balance is promoted.

• Privacy: the personal data of employees, clients and third parties is protected.

To integrate this commitment into its operations, Qwi takes human rights into account when selecting suppliers and partners, trains its staff on this Code, and acts to prevent, mitigate and remedy any adverse impact it may cause or contribute to.

4. Integrity, anti-corruption and conflicts of interest

Qwi applies zero tolerance towards corruption in all its forms, including extortion and bribery.

• Bribery: offering, promising, giving, requesting or accepting improper payments, gifts or advantages, directly or indirectly, to public officials or private-sector individuals is prohibited.

• Gifts and hospitality: only items of symbolic value, consistent with business courtesy and not influencing any decision, are acceptable. In case of doubt, Management must be consulted.

• Conflicts of interest: any situation in which a personal interest may interfere with the interests of Qwi or its clients must be reported to Management before acting.

• Fair competition: Qwi competes honestly and complies with competition and procurement regulations.

• Accurate records: transactions are recorded completely and truthfully; money laundering and illegal financing are prohibited.

• International sanctions: Qwi complies with applicable sanctions and export control regimes and does not do business with sanctioned persons or entities.

5. Confidentiality, data protection and information security

Qwi protects the information of its clients and partners with the same rigour as its own, in line with its ISO/IEC 27001-certified management system.

• Confidential information is used only for the purpose for which it was received and shared only with those who need it for that purpose.

• Personal data is processed in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish data protection legislation.

• Technical and organisational measures are applied to ensure the confidentiality, integrity and availability of information.

• The intellectual and industrial property rights of Qwi and of third parties are respected.

6. Environment

Qwi applies a precautionary approach to environmental challenges, in line with its ISO 14001 management system.

It is committed to preventing pollution arising from its activity, using resources efficiently and developing technologies that contribute to more efficient electricity networks and the energy transition.

7. Relations with clients, suppliers and third parties

• Clients: Qwi provides truthful information about its solutions, fulfils its contractual commitments and ensures respectful service.

• Suppliers and subcontractors: they are selected on objective criteria of quality, price and ethical compliance. Qwi requires them to respect human rights, labour and environmental law and anti-corruption rules.

• Public authorities: relations are based on legality, transparency and cooperation.

8. Reporting, enforcement and review

Anyone may report in good faith concerns or possible breaches of this Code through ethics@qwi-ti.com or directly to Management.

Reports are handled confidentially and Qwi prohibits any retaliation against anyone reporting in good faith, in accordance with Spanish Law 2/2023 on whistleblower protection.

Breaches of the Code may result in disciplinary or contractual measures in accordance with applicable law.

This Code was approved by Qwi’s governing body on 1 October 2026. It is reviewed annually together with the Integrated Management System and published on Qwi’s corporate website.