Ambit Iberia's ethical commitment

The Importance of Ethical Commitment. Who Does It Apply To?

AMBIT BST’s ethical commitment reflects and focuses on our mission, vision, and values. It is the cornerstone for the development of the company’s Policies and Processes.

This document establishes the symbolic framework of our culture based on ethics and the necessary conditions to fulfill our mission, which requires that all of us commit to ethical behavior, beyond just complying with laws and regulations.

The following pages outline the expectations regarding the commitments we make every day as part of AMBIT BST. Our ethical commitment is our guide so that we can all fulfill our mission, vision, and values.

Shared responsibility ensures the long-term survival of our company. Therefore, the ethical commitment applies to all employees, executives, and partners. Each of us, regardless of our role, represents AMBIT BST and must act in accordance with the principles set forth herein.

Clients, contractors, partners, manufacturers, developers, and other third parties must also adhere to this ethical commitment when acting on behalf of or for the benefit of AMBIT BST.

Our Purpose. Mission, Vision, and Values

At AMBIT BST, we believe our greatest responsibility is to contribute to society and people’s well-being through technology, integrating market compliance standards, with a special focus on the global healthcare sector. Only by acting with integrity, innovation, commitment to quality in everything we offer, and the excellence of our professionals, will we fulfill our mission.

Achieving this purpose unites us and requires daily participation and commitment from each of us in our respective roles within AMBIT BST. Every action is an opportunity to demonstrate our commitment and that we are part of a larger project that transcends borders—becoming an international technological benchmark for the health sector and health authorities in the development and operation of digital services and products.

Delivering value to our clients through services and technological solutions, ensuring compliance with the highest market quality standards, with a special focus on the healthcare sector.

Being the reference technology partner on a global scale for the healthcare sector, developing and operating its digital services and products.

People First: We strengthen cohesion, job satisfaction, well-being, and personal development as the core of our purpose.
Excellence: We base our actions on a philosophy of continuous improvement to ensure compliance with the highest quality standards in regulated environments.
Adaptability: We swiftly and proactively respond to market changes, offering the best strategic or business solution.
Commitment: Our essence. We stand out through a high level of commitment, building long-term, mutually beneficial relationships to enhance our value-creation capacity.

Ethics and compliance model

This commitment is the highest-level standard of this model and is implemented through policies, procedures, and internal controls that are reviewed and updated regularly.

To align this model with AMBIT BST’s activities, risks are periodically analyzed, responsibilities and expected behaviors are defined, resources for employee training are allocated, and processes are in place to evaluate compliance and ethical culture, as well as to detect, report, and respond to potential irregularities.

The Corporate Governance Committee is responsible for approving the ethical commitment and ensuring an ethical environment within the organization, supported by the Quality, Audit, Risk, and Security Committee. The Compliance Function, reporting to the Quality, Audit, Risk, and Security Committee, oversees enforcement of this Code and the Compliance Model in general.

Individual responsibility

Leaders: Partners and executives bear additional responsibility. They lead, coordinate, and take on greater accountability in ensuring compliance with our ethical commitment.
Employees and collaborators: We are all key players in the reality we live and build. At AMBIT BST, we work as a team, while also being individually responsible for ethical conduct. Our shared and individual commitment enables a culture of integrity.
Complying with the ethical commitment: Codes of conduct, laws, and regulations: The ethical commitment outlines the minimum compliance expectations at AMBIT BST. Our duty is to follow both the letter and spirit of this document. This means understanding and aligning our behavior and actions with the AMBIT BST Code of Conduct, company policies and procedures, and applicable laws and regulations. However, we are aware that the ethical commitment cannot cover every situation we might face. Therefore, we are expected to use sound judgment and seek guidance when in doubt, by contacting our direct supervisor, the People and Culture Department, and/or the Legal & Compliance Department.

How to make the right decision

When we are faced with a situation where we have to make a decision, we must ask ourselves before we do so:

Is this behavior contrary to the ethical commitment?
Does this behavior violate company policies and procedures?
Does this behavior conflict with applicable laws or regulations?

If any answer is "yes" or "I don’t know" — seek help:

Contact your supervisor.
Or the People and Culture Department.
Or the Legal and Compliance Department.

Mutual commitment

Health and safety: AMBIT BST is committed to providing a safe and healthy work environment for employees and all who visit or work in our facilities. Everyone is responsible for health and safety.
Harassment-Free workplace: Everyone has the right to work in an environment free from intimidation, harassment, and abuse. Unwanted or disruptive behavior from any employee that constitutes harassment, interferes with work, or creates a hostile environment will not be tolerated. This includes bullying, abuse of power, offensive language, and any form of aggression or hostility.
Equal opportunity: AMBIT BST brings together employees from diverse backgrounds, skills, and cultures. This diversity drives our success.
Respect and data privacy: Confidentiality of personal data accessed in the course of our work must always be preserved—even after employment ends. Proper security measures must be in place to protect confidential or personal data.
Professionalism at work: AMBIT BST employees must perform their roles with efficiency and technical accuracy, minimizing costs and maximizing effectiveness.
Conflicts of interest: Avoid any personal interests that interfere—or appear to interfere—with objective business decisions. Use good judgment and avoid situations that may damage trust or reputation.
Protecting our assets: We are responsible for properly using and safeguarding AMBIT BST’s assets, including our brand, reputation, information, equipment, intellectual property, and systems.
Sensitive information and intellectual property: Access to confidential company information must be strictly protected. Intellectual property developed at work belongs to AMBIT BST and may not be used for personal purposes.

Sensitive information refers to, among others, to:

a. Business and strategic plans.

b. Plans related to potential or actual mergers or acquisitions, and/or sales and liquidations of companies.

c. Financial information.

d. Intellectual property, know-how, and inventions.

e. Information on sales and marketing.

f. Information on corporate intelligence.

g. Information on technology, operations, research, and technical data.

h. Manufacturing techniques and processes.

i. Employee files, compensation information, and other personal data of employees.

j. Information and records of third parties (e.g., vendors, suppliers, etc.) provided to us within the framework of a confidentiality relationship.

k. Non-public information (including that of clients and business partners) obtained in the course of our professional activity.

Reliability of information and record control: Business partners, public officials, the general public, and other stakeholders must be able to rely on the truthfulness and integrity of the information we publish. Internally, it is also essential to have reliable information so that we can make informed decisions and comply with corresponding legislation, respecting the obligations regarding the disclosure of information. Our books and records must accurately and clearly reflect our transactions, with a reasonable level of detail and in accordance with our accounting practices and policies. Some employees have specific responsibilities in this area, although we all contribute to the process of recording business results and maintaining records. Each of us is responsible for helping to ensure that the information we record is accurate, timely, complete, and maintained consistently with our internal control system.

Commitment to our environment

Business and Supplier Relations: Our suppliers and business partners are essential to developing our business and meeting our high standards and expectations. For this reason, we select them carefully, carrying out the relevant financial and non-financial due diligence—such as safety and environment, human rights, or anti-corruption—and we use an objective and impartial selection process. All employees must follow these principles:

a. Avoid any conflict of interest and favoritism in business and supplier relationships.

b. Comply with internal regulations regarding the selection of suppliers and business partners.

c. Help suppliers and business partners understand our expectations and act according to our applicable regulations.

d. Report any suspicion about a supplier or business partner regarding the possibility that they may not be meeting our standards or their contractual obligations.

e. Cooperate with all audits and investigations involving our suppliers or business partners.

f. Promote awareness and compliance, on the part of suppliers, with the code of ethics.

Gifts, gratuities, and hospitality: Under appropriate circumstances, a modest gift may serve as a token of appreciation, or a meal may be the right setting for a business conversation that strengthens a professional relationship. However, if not properly managed, the exchange of gifts, gratuities, and hospitality may create or appear to create a conflict of interest, especially if they occur frequently or if the value is significant enough that someone might reasonably believe a business decision is being influenced. Employees must not accept or offer gifts, gratuities, or hospitality of any kind that could affect their objectivity (or the objectivity of the person receiving the gift or hospitality) or influence them in a business, professional, or administrative relationship.
Interactions with the state and public administration / anti-corruption: In several countries, interaction with the government is strictly regulated, so we must be very careful with it and always conduct ourselves with the highest degree of integrity. In this sense, we must not take any action that could be or could be perceived as an attempt to influence a governmental decision and/or that of a Public Official. All countries prohibit bribery of their public officials, and many also prohibit bribery of foreign public officials. Our policy goes beyond these laws and prohibits any inappropriate payment in all our activities, both to government entities and in the private sector. We do not pay bribes or illegal commissions under any circumstances. This also applies to any person or company representing the company. It is especially important that we closely monitor third parties acting on our behalf. We must always ensure that we conduct due diligence and know our business partners and all those with whom we have business relationships. We must know who they are and what they are doing on our behalf. Third parties must understand that they are required to act in strict compliance with our standards and maintain adequate records of all transactions.
Community relations: We strive to establish strong and lasting relationships with the local communities where the company is present, based on recognition, trust, mutual respect, and shared value, through proactive dialogue and responsible and transparent management of social impacts and opportunities. Cultural diversity and local customs are recognized and respected.
Commitment to applicable laws and regulations: We work daily to ensure that our products and services are of the highest quality, safety, and reliability. Achieving this is only possible by complying with all applicable laws and regulations, as well as AMBIT BST’s policies and processes in this regard.
Commitment and respect for the environment: A responsible attitude toward the environment will be ensured, along with a commitment to comply with environmental legislation and the rational use of resources. Therefore, any illegal act that degrades the environment must be avoided.
Political activities, lobbying, and donations: AAMBIT BST does not make any political donations or conduct political activity, neither in cash nor in kind; nor does it engage in lobbying.
Global tradel: We respect the trade control, import, and export laws of all countries in which we operate. Trade requirements often change, and the laws of different jurisdictions may conflict. To avoid problems, we must consult the legal and compliance department about local legislation.
Anti-Money laundering: Money laundering is a global problem with serious consequences. It is defined as the set of mechanisms or procedures aimed at giving an appearance of legitimacy or legality to goods or assets of criminal origin and is not limited to cash transactions. Participation in such activities undermines our integrity, damages our reputation, and may expose AMBIT BST and its employees to serious sanctions.
Competition law: We believe in free and open competition and do not engage in inappropriate practices that may restrict free competition. We also do not seek to gain competitive advantages through unethical or illegal business practices. Competition laws are complex, and the requirements may vary depending on the circumstances, although, in general, the following activities are considered red lines and should be avoided if detected, reporting them to the Legal and Compliance Department:

a. Sharing sensitive competitive information of the company with a competitor.

b. Sharing non-public information of business partners or third parties with their competitors.

c. Attempting to obtain non-public information about the competition through new hires or job candidates.

Human rights: In addition to complying with local legal requirements, AMBIT BST is committed to respecting internationally recognized Human Rights, including those outlined in the International Bill of Human Rights and the principles related to the rights established by the International Labour Organization (ILO) concerning the Fundamental Principles and Rights at Work and the eight core Conventions that develop them. We are also committed to respecting the Human Rights of individuals who belong to the most vulnerable groups or collectives, regardless of where we operate. This includes: indigenous peoples; national, ethnic, linguistic, or religious minorities; children, the elderly, persons with disabilities; and refugees, displaced persons, and migrant workers, as well as their families.

Commitment to Technology

Justice and non-discrimination: The values of equality, tolerance, respect for others, and justice govern this principle. Our technology professionals foster fair participation for all people, including those from minority groups. Discrimination based on age, color, disability, ethnicity, family status, gender identity or expression, union affiliation, military status, nationality, race, religion or beliefs, sex, sexual orientation, or any other inappropriate factor is a clear violation of this commitment.
Respect for privacy: The responsibility to respect privacy applies especially deeply to our technology professionals. Technology allows the collection, control, and sharing of personal information quickly, cheaply, and often without the knowledge of the affected individuals. At AMBIT BST, we understand the various definitions and forms of privacy and comprehend the rights and responsibilities associated with collecting and using personal information.
We honor confidentiality: At AMBIT BST, we are often entrusted with confidential information such as trade secrets, client data, non-public business strategies, financial data, research data, unpublished academic articles, and patent applications. In our company, we protect confidentiality, except when there is evidence of a legal violation. In these cases, the nature or content of such information should not be disclosed except to the appropriate authorities.
Risk analysis: Technology professionals are in a position of trust and, therefore, have a special responsibility to provide objective and credible assessments and testimony to employers, employees, clients, users, and the public. Technology professionals must strive to be perceptive, thorough, and objective when evaluating, recommending, and presenting system descriptions and alternatives. We take extraordinary care to identify and mitigate potential risks in machine learning systems.
Access to computing and communication: At AMBIT BST, we commit not to access another person's computing system, software, or data without a reasonable belief that such action is authorized. In exceptional circumstances, our technology professionals may use unauthorized access to disrupt or inhibit malicious systems.
Designing and implementing secure and robust systems: Breaches of computer security cause harm. Strong security must be a primary consideration when designing and implementing systems. At AMBIT BST, we commit to due diligence to ensure that the system works as intended and to take appropriate measures to secure resources against accidental, intentional use, modification, and denial of service. Since threats may emerge and change after a system is deployed, we integrate mitigation techniques and policies, such as monitoring, patches, and vulnerability reports. Additionally, we take steps to ensure that parties affected by data breaches are notified in a timely and clear manner, providing appropriate guidance and remediation.
Modifying or retiring systems: Changes to interfaces, the removal of features, and even software updates impact user productivity and the quality of their work. At AMBIT BST, we are committed to being careful when changing or suspending support for system features that people still rely on. Our professionals must thoroughly investigate viable alternatives before ending support for a legacy system. If such alternatives are unacceptably risky or impractical, we must assist stakeholders in migrating to an alternative. Our professionals must help system users monitor the operational viability of their systems and help them understand that timely replacement of inappropriate, outdated features or entire systems may be necessary.
Recognizing and carefully managing systems Integrated into societal infrastructure: Even the simplest computing systems can potentially impact all aspects of society when integrated with daily activities such as commerce, travel, government, healthcare, and education. When organizations and groups develop systems that become a major part of societal infrastructure, their leaders have the added responsibility of being good stewards of these systems.

Raising concerns. Reporting issues

In case we observe or suspect any illegal or unethical behavior, we must report it immediately. If we have doubts, need help, or want to raise any concern, it is always best to first discuss (report) the matter with our direct supervisor. Our colleagues and supervisors are available to help us, and we also have other resources to turn to, such as our values and internal regulations. However, if this is not possible, if it creates a conflict, or if we prefer to speak with someone else, we can go to any other supervisor and, in any case, we can always contact the AMBIT BST ethics channel at any time. The ethics channel allows questions and concerns to be raised confidentially.
canaletico@ambit-bst.com

Zero tolerance for retaliation: Each of us plays a fundamental role in protecting the integrity of AMBIT BST. Therefore, we must immediately report any possible breach of our ethical commitment, internal regulations, or applicable legislation. Employees can communicate potential concerns confidently and without fear of retaliation. No retaliation of any kind will be tolerated against anyone who, in good faith, raises questions, reports actions inconsistent with our commitment, internal regulations, or legislation, or who cooperates in an investigation of an alleged irregular act. "Good faith" reporting means providing information honestly, completely, and accurately, even if it is later shown to be unfounded or incorrect. Any information found to have been provided in bad faith may lead to disciplinary consequences.
Investigations: All employees must fully cooperate with internal and external audits, investigations, and inquiries carried out by the company. Additionally, in the course of our activities, we may be subject to investigations or requests for information from public officials or regulatory bodies. If we become aware of any potential investigation or inquiry, we must immediately notify our direct supervisor and the legal and compliance department before taking any action in this regard. Employees are expected to cooperate fully, and any information provided must be truthful, clear, and complete. Regarding audits, investigations, and inquiries, it is strictly prohibited to:

- Destroy, alter, or conceal documents in anticipation of or in response to a request for them.

- Provide incomplete, false, or misleading statements to a company investigator or public official, or attempt to influence others to do so.

- Conduct an investigation individually, as the appropriate and necessary resources must be assigned for investigations.

Accountability and disciplinary regime: Individuals who violate our commitment, internal regulations, or applicable law may be subject to disciplinary measures, which could include termination of employment, as well as other possible actions and legal sanctions. Other individuals involved in irregular actions may also be subject to disciplinary measures. This includes those who fail to exercise due diligence to detect a breach, those who refuse to report information that may be relevant to an investigation, and those supervisors who approve, tolerate, "look the other way," or attempt to retaliate against someone who has reported a possible breach in good faith. Any violations of this commitment that may occur will be analyzed on a case-by-case basis and will be sanctioned in accordance with internal procedures, agreements, and applicable legal regulations.