Through our actions, we are responsible for the image that others have of our Studio. The way we interact with our people, clients, society and the environment, and the respect we show for the policies and regulations that accompany us on a daily basis in our work, build our own identity and integrity.

This Code details a set of rules that reflect the principles and values ​​of Carlos Picos Consultora when we are faced with complex circumstances.

We are all responsible for respecting it and ensuring its compliance, as it applies equally to everyone on our team.

We are rigorously committed to high levels of regulatory compliance and business ethics. Our Code of Conduct determines the limits within which we must act in order to comply with the laws and internal rules of the firm. In doing so, our Code of Conduct protects the studio and each of us.

Our Code of Conduct guides us to put our values ​​and commitments into practice, throughout the firm and in everything we do. It helps us navigate areas and situations where responsible conduct and ethical decision-making are of paramount importance. Only with our Code of Conduct and compliance with all laws and regulations can we become a firm that is respected and valued by our clients, employees and other business partners.

Each of us is responsible for understanding Carlos Picos Consultora’s policies and procedures and for maintaining high ethical standards in every aspect of our work, even in cases where our Code of Conduct does not provide precise guidance in this regard. We must always display strong integrity and common sense. When in doubt, we always raise our voices and ask for help.

We act with integrity in all of our activities. Always and without exception.

Our reputation for delivering services and consulting with complete integrity is critical. We are committed to fighting any form of corruption or bribery. We play to win, but always respecting the rules, treating all our business partners fairly and competing for a business based on the quality of our products and services. In this process, we expect the same from all those who interact with us.

We do not get involved with corruption, no matter what form it takes. We do not offer or accept bribes, and we do everything necessary to prevent bribery by third parties acting on our behalf, for example, by appropriately reviewing companies and individuals who contact us, hire our services, or those who receive any type of service.

Always on the alert against corruption

Corruption can take many forms, so we are always vigilant and on the alert for suspicious behavior, such as a business partner demanding unusually high commissions or cash payments.

We would rather lose a good business opportunity than win it through dishonest methods. Bribery — whether in the government or private sector — is always inappropriate and has no place in our study.

We do business that crosses borders. But always within legal limits.

We are a firm with activities and business partners in the region and the world. We are aware that all business relationships with our national and international partners may be subject to laws that control trade. Our main objective is to prevent our services from being misused. That is why we strictly abide by all applicable laws, including regulations that control trade such as embargoes, anti-terrorism laws, money laundering and other provisions designed to prevent misuse.

We are always on the alert against money laundering.

We do not allow dirty money to be a part of any of our activities. But while it is easy to state this as a fundamental principle, protecting our firm against criminal attempts to launder money and other assets generated by illegal activities is a challenge that requires constant vigilance from all of us. Because being involved in money laundering or terrorist financing — even inadvertently — constitutes a crime.

We are always ready to deliver our services, but only with companies and individuals who carry out their activities in accordance with the law using resources from legitimate sources. We take steps to ensure a transparent business relationship.

Money laundering is the deliberate attempt to move cash or property generated by illegal activities into legitimate and legal financial activities. At Carlos Picos Consultora we take all the necessary measures to prevent our firm from being used as a means of laundering money.

In order to protect our reputation and avoid any possible criminal liability, we must constantly monitor the activities of our business partners, so we know who we are dealing with before signing contracts or making transactions, and be alert to detect irregularities in payments or any behavior. suspicious by customers or third parties.

We do not create relationships based on gifts.

We are all in favor of doing business in a way that allows us to create excellent business relationships. But gifts and entertainment should be taken with great caution. And when in doubt, we ask our boss and colleagues, act with caution and make our actions transparent.

We do not consider it appropriate to accept or grant a personal benefit of any kind that is connected to our professional activities. But in the course of our good business relationships, a small gift or modest invitation may be offered that is within what is considered reasonable and common practice. In such situations, we must exercise caution and common sense to avoid any possible misinterpretation of our intentions and consequently any damage to our reputation. Invitations may be aligned with our internal rules, but may leave a bad taste due to the situation and other circumstances.

We will reflect carefully and will only offer or accept gifts that are moderately priced and are understood as mere courtesies from the firm, and not as an attempt to induce us to act unprofessionally or to abuse our position. We will also pay attention to the image that may be created by external circumstances and the situation in general. We will use the same criteria when deciding whether to offer or accept a gift. We will not offer or accept cash or cash equivalents, such as gift cards or shopping coupons.

We will exercise special caution when dealing with public officials or government representatives, as we abide by the strict regulations that govern this behavior in many countries.

Our priority is the firm and our interests.

When we do our work, all of our actions and decisions must be based on what is best for the firm. But situations may arise in which personal gain can influence our professional judgment. It is extremely important that we know how to recognize potential conflicts of this type, and that we make them known before the trust on which the success of our firm is built is damaged.

We are well aware that our relationships and personal interests should never affect our business activities or influence our decision-making in any way. We must be careful to avoid situations where a conflict may occur between the professional and the private sphere, or — equally important — where it may appear to be the case.

This means, for example, that we should not make any investment or enter into any relationship that could cause others to doubt our fairness, integrity or ability to perform our obligations with due objectivity.

It is important to note that having a conflict of interest does not in itself constitute misconduct, but the way we treat it can. The most important thing is transparency: if we suspect that there is a possible conflict, we must immediately notify our superior and ensure that we obtain the necessary validations to act against a possible conflict of interest.

We treat people fairly and with respect. We treat people with fairness, consideration and respect. Our goal is to ensure that each individual feels valued and fully supported to achieve their best personal performance.

We respect human rights. We make the decision to seek the creation of sustainable value, which implies striving to contribute positively to the protection and promotion of human rights and the well-being of people.In our own business activities, we avoid causing or contributing to causing adverse impacts on human rights.

At Carlos Picos Consultora we demand that each of us refrain from saying or doing anything humiliating, arrogant, offensive or disrespectful to any of our colleagues. This is essential for our motivation and dedication at work.

We build our team on talent and appreciate differences as they make us stronger and are essential to our success. We promote an inclusive environment that embraces all types of diversity, including a wide variety of levels of education, ideas, perspectives, age and ethnic origin.

We do not tolerate discrimination against anyone on the basis of age, race, color, sex, sexual orientation, gender identity / expression, national origin, religion, disability, genetic information, or any other personality trait or preference. This policy governs all of our employment decisions, such as recruiting, hiring, promotions, benefits, disciplinary records, and terminations.

We do not allow conduct of workplace harassment to another employee or person in the work environment. Workplace harassment is abusive behavior committed by one or more people against an individual or a group, with the aim of undermining the harassed. It is, generally, a repetitive and prolonged set of hostile attitudes that includes gestures, words or actions that degrade, disqualify or humiliate the harassed. This is a reprehensible practice, as it causes shame, coercion, exposure to the abusive situation, humiliation, discrimination and fear, with negative reflections on the work environment and the health of the individual, which is undermined in their dignity.

We do not disclose data of the employee and collaborators to third parties who have no commercial need or authority to have such information without the express consent or authorization of the firm or employee / collaborator in question.

We value people’s health and safety above all else.

Wherever we do business, we always act responsibly: not only complying with all applicable regulations, but also reducing risks and minimizing our impact on the environment.

Consumption of Alcohol and Drugs As employees or collaborators of Carlos Picos Consultora, we must all be responsible and present ourselves to our work free from the influence of alcohol or drugs. We must have respect for our lives and that of our co-workers and clients. Thus, the consumption of alcohol and drugs is prohibited during the work day.

We always maintain an appropriate and responsible attitude when participating in activities outside the firm, the workplace or outside working hours, which are organized by the firm, by Business Partners or on behalf of the firm.

We are committed to energy efficiency and climate protection and are constantly working to develop sustainable solutions for our business activities and for our customers. In all our activities and in close collaboration with our suppliers, we work to achieve the highest levels of health and safety protection and maintain the trust of our employees, customers, partners and other interested parties. In the event of any incident or emergency, we are well prepared to take any necessary action.

Sharing information with our customers allows us to create value and benefit from the knowledge of our employees. In order to adequately protect our knowledge and expertise, we take all available measures to prevent unauthorized disclosure or misuse in all of our activities.

We trust our intellectual property because confidential information and intellectual property in many forms — from people’s knowledge to internationally protected patents — are some of our most valuable assets. That is why we take the utmost care to protect them.

We comply with all applicable information protection and cybersecurity policies, requirements and guidelines, and regulate the distribution of confidential information in an appropriate manner. We do not share confidential information on social media or public places.

Commercial or marketing information is confidential. Its disclosure without authorization, as well as the use and disclosure of individual information of the consumer or of the employees and collaborators, is prohibited.

In our daily activities at the firm, we collect and process personal data relating to people such as employees, clients and business partners. This data is private and must be treated with respect.

We are committed to respecting the personal rights of anyone. We follow strict rules when handling personal data. All personal data collected by us will be processed in a clear, transparent, careful manner and in full compliance with the applicable legal requirements. Treating personal data confidentially is always part of doing business with integrity. We protect personal data against unauthorized access or loss.

At Carlos Picos Consultora we take advantage of the opportunities that digitization offers us to guarantee our long-term success and support the success of our clients. We carefully and effectively integrate its benefits into the way we do business and harness its full potential to improve our conduct of business, our products and our customer solutions.

Digitization is crucial to remain competitive, which is why it is one of our strategic areas of action. To stay ahead of the competition, we need to accelerate the execution of digital projects and build strong digital skills across the firm. Technologies such as machine learning, cloud computing, artificial intelligence or others with the aim of generating new digital business models, or to make processes more efficient and simple.

We also recognize the considerable impact of digitization on our employees, our customers, and society as a whole, and we are committed to driving this transformation in an ethical and responsible way for the benefit of all stakeholders, including:

Ensuring that its evolution and use are driven by our values ​​and by the principles established in our Code of Conduct.

 Developing digital solutions in a multidisciplinary and diverse collaborative environment, and being used in an inclusive way to empower our employees, customers and other stakeholders.

Openly communicate information about the technical capabilities and intended use of digital solutions and provide means for monitoring and control by customers and other users.

Safeguard data protection and privacy as fundamental principles in all digital solutions, as reflected in our Code of Conduct.

Stationery, furniture, computers and others owned by the firm allow everyone to do our jobs in the best possible way. Naturally, we treat these goods in a responsible way, protecting them from loss, damage, theft or misuse. We apply the same criteria when treating property owned by any of our clients, partners or interested third parties.

We consider as a fundamental part of our values ​​that all the members of Carlos Picos Consultora treat the property owned by the company with due care and respect. And not only tangible assets, as it is equally important to be responsible in the way we treat intangible assets such as intellectual property rights, copyrighted material, accounting records, and also the reputation of our brand.