CODE OF ETHICS
- PURPOSE AND SCOPE
This code of ethics sets out the values andguidelines of Ocean Brotherhood SL, with tax ID (CIF) B66764952 and registeredoffice at c/ Calvet 36 E2, 08021 Barcelona.
It applies both internally (employees andmanagement team) and externally (suppliers, customers, partners, ambassadors,investors and all stakeholders with whom we interact), both nationally andinternationally. The company provides them with this code so that they areaware of it and can commit to complying with it in the areas that apply tothem.
The code of ethics is approved by the company'smanagement committee, which is also responsible for supervising and monitoringcompliance with it, with the support of the relevant departments.
- VISION
We believe in a world where business helpsbuild a better society. We believe in a world with no room for companies thatare not good for people and the planet. We believe that the impact ofcollaboration between individuals is necessary to solve the world's mainproblems.
One of the main challenges facing the world isthe climate crisis and the protection ofthe oceans. The oceans are the main source of life; they are what gives life tothis planet. Protecting the ocean is the basic condition for leaving ourchildren a better world. We believe that an ocean with at least 30% of its areaprotected is possible and that this will contribute to the sustainability ofour planet and to mitigating the effects of climate change.
We believe in a world where people andtheir consumer choices can generate a positive impact. We believe that everyonecan help the health of the oceans, whether by contributing to ocean protection,education or awareness-raising. Above all, we believe that the solution doesnot lie in individual actions, nor in placing the responsibility on governmentsor other bodies. We will solve it by listening to the scientific community andaligning all groups: companies, institutions and consumers, each contributingthrough our consumer choices and direct actions.
We want to be a benchmark company in the world's transformation towardssustainability and in promoting the circular economy. We want people to benefitfrom products that are good for the planet and to mobilise people to help educate their children, gain knowledge andcollaborate in caring for the ocean. That is why the main economic benefit ofthis company is its social impact: the impact of improving the oceans. For thisreason, we allocate 52% of our distributable profits to protecting the ocean,and in doing so we aim to support scientific research and the development ofsolutions for a healthy ocean.
2.2 Beliefs and values
- Abusiness that does not have a positive impact on the world is not a goodbusiness.
- Ecologicaland social awareness. We are responsible for leaving a positive impact on theplanet. It is true that companies generate a negative impact in terms ofresource consumption, use of transport and waste generation. The benefit webring to society must offset this impact and, of course, we must not generateunnecessary negative impacts.
- Webelieve we can help shift the food/beverage sector towards a more sustainablemodel.
- Wecan mobilise the ocean community and reach the whole community to achieve achange in behaviour towards one that is more responsible towards theenvironment.
- Surroundingourselves with the best and most knowledgeable experts is essential to have areliable source of information and constant inspiration, which is why we relyon the support of our network of ambassadors, investors and partners.
- Honesty:we call things by their name and we owe ourselves to our collective goals. Weare honest; we do not claim to be what we are not.
- Creativity,an open mind and the freedom to say what we think, share ideas and do thingsdifferently. We share what we learn and express our opinions openly.
- Humilityto acknowledge mistakes, to say “I don't know” and to learn from others.
- Welike to take on and face challenges: a dream without action is a hallucination.
- Welove working as a team, collaborating and sharing. We are passionate about whatwe do; we truly find it fun.
- Agood project has a good team. We believe in a team that is engaged, motivated and committed. We striveto develop their skills and create an environment that allows us to retain andattract talent.
- Webelieve that, with everyone's help, there is still time to save the ocean.
- MISSION
Totransform an industry with a negative impact into one that helps protect theocean.
REAL IMPACT
➔Avoid the overproduction of single-use plastic bottlesand prevent them from reaching the ocean.
➔Enable responsible consumption.
➔Promote knowledge of the ocean in society.
➔Support scientific institutions and groups workingdirectly on ocean protection.
- CODE OF CONDUCT
4.1 Legal compliance
Businessand professional activities are carried out in strict compliance with thelegislation in force in each of the places where they take place.
Clarityand transparency in the drafting of documents so that all parties canunderstand them correctly.
Allinformation contained in the company's physical media (paper, cardboard, etc.)or electronic media is part of the company's knowledge and value and istherefore its property. Accordingly, it may not be sold, transferred,appropriated or disclosed without the authorisation of management.
Allconfidentiality agreements necessary to guarantee the confidentiality ofinformation will be signed.
Employeeswill not take part in any illegal activity or in acts that are or may bedetrimental to the company's reputation, and will respect and contribute to the legitimate and ethical objectives of the organisation. They will also complywith the established internal protocols.
Thecompany rejects all forms of corruption and bribery.
4.2 Commitment to human rights
We respect human rights and reject any form ofviolation of them.
We apply the guidelines set out in the UnitedNations Global Compact. https://www.pactomundial.org
Ocean52 is committed torespecting human and labour rights, in accordance with:
- the United Nations Universal Declaration of Human Rights,
- the United Nations Global Compact, and
- the International Labour Standards of the International Labour Organization (ILO).
4.3 Respect for labour rights
The company respects thelabour rights of all its employees recognised both nationally andinternationally. In particular, this includes guaranteeing the prohibition ofchild and forced labour, non-discrimination, safe and healthy workingconditions, and respect for freedom of association and collective bargaining.
A good working environment is crucial for thehealthy development of the business and of people.
Employees must treat their colleagues,customers, suppliers and partners with respect.
We have a protocol for addressing workplaceharassment, as well as a diversity, equity and inclusion policy (DEI policy), adigital disconnection policy and a remuneration and incentives policy.
4.4 Environmental protection
Protecting the environment, and especially theocean, is our mission. We embrace the SDGs as our own, respecting them andworking to contribute to their achievement (especially 3. Good health and well-being, 12. Responsible consumption andproduction, 13. Climate action, 14. Life below water and 17. Partnerships for the goals).
We have an environmental management system thatnot only operates internally but also extends to our suppliers and customers.We have an environmental policy.
We allocate 52% of our distributable profits toocean protection. We have selection criteria to determine the beneficiaryprojects and a team of ocean experts who form an advisory committee to ensurethe effectiveness of the donations made. We also publish an impact reportcovering all the activities carried out that have a positive effect on theocean, available on our website for anyone interested.
We include sustainability criteria in thedesign of our products and operations.
We have a green office policy. We choose oursuppliers carefully and are rigorous with our recycling system and consumptionreduction practices.
4.5 Principles of non-discrimination and equal opportunities
Recruitment andpromotion of staff depend on their skills, knowledge and experience.
We have a diverse team,and this is part of our success. To fulfil and maintain our commitment todiversity, we all have a responsibility to show respect and to create aninclusive environment in the workplace. Consequently, the company does nottolerate discrimination based on protected characteristics such as race,colour, age, gender, nationality, disability, religion, sexual orientation andother characteristics protected by law. The DEI policy sets out measures to ensurethis.
The company prohibitsany kind of hostile or humiliating act against people, abuse of authority andany kind of harassment, whether physical or psychological, as well as any otherconduct that may create an intimidating, offensive or hostile workingenvironment for people. We have a protocol for addressing workplace harassment that sets out specificmeasures and procedures to prevent or deal with situations of harassment in theworkplace.
4.6 Right to work-life balance
We comply with labourregulations regarding maternity/paternity leave and leave for children and/ordependants.
Inaddition, our diversity, equity and inclusion policy ( DEI policy) and theemployee handbook include specific measures to ensure work-life balance, suchas flexible working hours, remote working and other measures to supportbreastfeeding.
4.7 Right to privacy and data protection
We guarantee compliance with the regulations onthe right to privacy and data protection.
We undergo voluntary audits that confirmcompliance with data protection regulations.
4.8 Right to training and professional development
It is the company's objective to promote anddevelop the skills of its employees.
We have an appraisal and development system forall team members and we foster a cooperative and supportive workingenvironment. In addition, both the DEIpolicy and the incentives policy include measures that guarantee training andprofessional development.
4.9 Occupational health and safety
Working ina safe, well-equipped and pleasant space is essential. We comply withoccupational risk regulations and supervision, and we train our employeesaccordingly.
4.10 Quality of our products and services
We are demanding with our producers andpartners. We want to offer the best to our consumers, and for this reason wehave a quality system that allows us to guarantee the quality of our products.
We work with first-class suppliers, both forproducing our beverages and in other areas of the company. Having prestigiousscientific sources of information allows us to guarantee that all theinformation provided on our channels is reliable and truthful.
4.11 Fair dealing with competitors
We are committed to the circular andcollaborative economy. We strive to help improve our surroundings with aninnovative and social business model. We believe in cooperation and act withfairness and respect towards our consumers, competitors and all other legal andnatural persons who interact with us in any way. We respect free competition.
4.12 Taxand accounting transparency
Being transparent is one of our obligations andcommitments.
We are committed to rigorously complying withtax and accounting regulations. We firmly reject tax fraud and corruption.
4.13 Lobbying activities
Should it take part in institutional dialogueprocesses or in initiatives aimed at contributing to the development of publicpolicies, the company will act responsibly, transparently and in accordancewith applicable legislation, aligning such actions with its mission of oceanprotection, environmental sustainability and generating positive impact.
Ocean52 is committed to maintaining consistencybetween its public positions, its internal policies and any futureparticipation in public policy initiatives.
4.14 Communication with stakeholders
We have an open web channel through whichsuggestions and complaints, among other things, can be submitted. Our compliance system includes a whistleblowing channel.
- REVIEW AND UPDATE
This code of ethics will be reviewed at leastevery five years by the ManagementCommittee, with the support of the sustainability area, in order to incorporateimprovements and adapt its content to regulatory and strategic changes.
- TRACEABILITY AND MONITORING
Compliance with the code is monitored throughthe tracking of environmental and social KPIs, workplace climate surveys andreviews with strategic suppliers. Any deviation will be analysed and, whereappropriate, will lead to corrective measures.
Approvedby:
Santiago Mier Albert
CEO
16/09/2026