The purpose of this Code of Ethics (hereinafter, the “Code“) of Zaragoza Medienerco, S.L.U. (hereinafter, “Medienerco“) is to establish the rules and standards of conduct that must govern the business and human actions and behaviour of Medienerco and the companies integrated in Medienerco (hereinafter, “Zaragozá Group“) and of its employees and directors.

Our organisation sees Ethics as a driving force for change and transformation of the Company, becoming a fundamental pillar for the development of our environment. This is why business ethics is a fundamental value for the Zaragozá Group, fully rooted in the roots of our organisation, guaranteeing that all actions and conduct emanating from our group are carried out based on a solid conviction of humanity, prosperity and environmental commitment.

We understand Ethics as a differential value, which helps us to grow and prosper as an organisation thanks to the support and importance it has for our customers, partners, employees and suppliers. Hand in hand with a strong moral commitment, we weave professional relationships based on respect, dignity and solidarity.

Our mission is not limited to mere compliance with the Law but to make Ethics and our values the central axis of all our actions and behaviour, being aware of the responsibility we have towards our the Company and the Environment.


This Code is applicable to all employees, professionals, managers and directors of any of the companies making up the Zaragozá Group, regardless of their hierarchical level, geographical location, responsibility, position or functional dependence.

Compliance with this Code is understood to be without prejudice to firm compliance with all the rules of the legal system of those jurisdictions where the Zaragozá Group works, operates and is present.

Its scope covers all areas of activity and lines of business of our organisation. All Zaragozá Group professionals, regardless of their personal circumstances and hierarchical level, are aware of the importance of facing their day-to-day work with respect for the values that inspire this Code.


Our mission is to offer alternatives to create sustainable development through all our areas of activity. Through the fulfilment of our business plan, we want to create value for the company and for all those people who place their trust in our way of working and the way we do things.

Our vision always approaches the challenges from a prior search for the current needs of people so that we can enjoy a better life. To this end, we adapt to each situation, with flexibility and analysis, always making sure that our actions do not compromise future generations.

We are committed to our premises and we stand by a set of values:

Social responsibility: We are aware of the impact that economic operators have on the environment that surrounds us, which is why we are strongly committed to business management based on mitigating the negative impacts that our business actions may have in the Company.

Respect for the Environment: We care for the environment, fully aware of its importance in our lives.

Customer orientation: We place customers at the centre of our activity, being aware that they are a fundamental part of the growth of our organisation.

Innovation and creativity: We always seek to be at the forefront of our sector, exploring and implementing innovative and creative changes that bring added value to our clients and customers.

Honesty: We believe in doing things well and always living up to our values.  

Leadership: We are committed to strong and determined leadership, so that with dedication and effort we are able to prosper and move forward.  

Excellence in achieving objectives: Constant pursuit of excellence.

Professionalism: Our relationships with customers and suppliers are based on the highest standards of professionalism.


Respect for human rights.

The Zaragozá Group and its professionals and managers undertake to fully comply with the Universal Declaration of Human Rights of the United Nations, as well as to integrate into the day-to-day running of the organisation the utmost respect for the rights of minorities and the human dignity of all human beings, respecting the fundamental rights and public freedoms enshrined in the laws and international agreements of all the places where we are present.

We are a company committed to social and environmental welfare, aware that above all we are people. All our employees and collaborators must, in their professional performance, fully respect all Human Rights and Public Freedom.

Respect for Labour Rights.

We show an unwavering commitment to the labour rights of all our employees, respecting and ensuring compliance with all labour regulations wherever we operate.

People are our most valuable asset, our greatest capital. That is why we promote the work-life balance of our employees as a central axis for their self-development, through responsibility, autonomy, teamwork and business trust.

Equal opportunities and diversity.

We firmly believe in equal opportunities for all people, meritocracy and the effort of all of them to achieve their goals and develop personally and professionally. At the Zaragozá Group we defend the development of any person based on their effort, talent and merit regardless of their place of origin, sex, ethnicity, sexual or religious orientation.

We understand diversity as prosperity, both for our organisation and for our Company. We promote and support all human beings to develop freely without barriers based on age, gender, sexual orientation, religion, origin or nationality.

Health and safety at work.

The Zaragozá Group promotes the health and safety of all its workers in all its work centres, ensuring the safeguarding and protection of the physical integrity of all its employees and professionals, integrating preventive actions in their daily work.

The Zaragozá Group makes a constant effort to train all its employees in health and safety at work as a way of guaranteeing a safer and more pleasant working environment for everyone.

Right to privacy.

Personal relations between the Zaragozá Group and its employees are based on the basic premise of respect for the privacy of all the people who make up this company. The Zaragozá Group undertakes to ensure the security of the information and personal data of all its employees, as well as to strictly and unwaveringly comply with the applicable regulations, always respecting the rights of all the people who form part of it.

Environmental Protection.

The preservation of the Environment is one of the main objectives of the Zaragozá Group, manifested in the day-to-day running of our organisation through the behaviour of our employees, all of whom are faithfully committed to sustainability and to implementing the best practices to preserve our planet.

The quality and environmental policy of Medienerco, as the parent company of the Zaragozá Group, is one of the basic pillars of our organisation, known by all the employees that make up the Zaragozá Group and structured under the principles of energy saving, rationalisation of water use and management, effective waste management and the fight against pollution and climate change.

Ongoing training and development.

People are Zaragozá Group’s most important asset. That is why we are committed to the constant development of all of them, offering initiatives, training and courses that allow them to grow both as human beings and as professionals.

We firmly believe in teamwork. All the achievements and merits of our company are due to the cooperation and companionship of each and every one of the people who have worked for Zaragozá Group.

We are aware that together and united we are capable of achieving and reaching all that we set out to achieve, which is why we promote dynamics and policies that aim to create a pleasant atmosphere in all our workplaces.


Each of the people who make up the Zaragozá Group are ambassadors and represent it to customers, suppliers, partners and the rest of the Company, ambassadors of the values of the Zaragozá Group, complying with and respecting the indications and rules contained in this Code.


All the professionals who make up the Zaragozá Group comply and must comply with the ethical and legal standards of transparency with our customers, suppliers, partners and any other person with whom we have dealings. The veracity of all the information we handle and deal with is very important to us, which is why we must guarantee the strictest transparency in our relations for the good course of our organisation.

Fair competition.

The Zaragozá Group competes and acts in the market with total loyalty towards its competitors, always respecting current regulations and applicable law, not exerting pressure or carrying out practices that could be considered abusive for fair and effective competition between companies, nor fixing prices or creating cartels.

Third-party information.

All members of the Zaragozá Group and the Zaragozá Group as a legal entity are obliged to strictly observe all provisions contained in the general data protection regulation (EU) 2016/679, the Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights and any other legal provisions concerning the protection of personal data.

At any time, all those persons who are related to the Zaragozá Group and whose personal data has been processed may exercise their rights of access, rectification, suppression, opposition, limitation, as well as the right to the portability of their data under the terms established in the regulations in force.


At the Zaragozá Group we are aware that our clients contribute to our continuous improvement, as we achieve our objectives with them together and hand in hand.

Through a relentless pursuit of excellence in all our areas of activity, personalised attention and the highest quality standards, we offer and provide the best possible service to our clients.

The professionalisation of our business model allows us to establish long-lasting and trusting relationships with our clients, who, in accordance with our values and principles, are confident that they can count on a reliable partner to help them achieve their goals.

We treat customers with honesty and integrity. All Zaragozá Group employees are obliged to provide each of our customers with the best possible service.

We see transparency as a fundamental aspect of doing business and as an essential value for building relationships based on mutual respect and trust.


The relations maintained by Zaragozá Group and any of its employees or collaborators with suppliers must always be governed by the principles of honesty, integrity and transparency.

The Zaragozá Group will choose its suppliers based purely on criteria of objectivity and impartiality and always safeguarding the best quality of the goods or service.

Furthermore, when choosing suppliers, the Zaragozá Group will look for those who share Zaragozá Group’s ethical values and respect the provisions of this Code, establishing mechanisms for reviewing and not contracting suppliers who violate minimum standards of ethics, quality and transparency.

Relations with partners.

Medienerco works constantly to create and add value to all the partners that make up each of the Zaragozá Group companies, always maintaining a policy of communication with all of them.

Relationship with Public Authorities and Bodies.

Relations with any of the Public Authorities, Public Administrations and Public Bodies, whether national, regional or local, as well as relations with foreign Public and Governmental Authorities shall be guided by honesty, maximum respect for current legislation and professionalism.

Honesty and integrity.

The Zaragozá Group is committed to conducting business with integrity. This means avoiding any form of corruption and complying with all applicable anti-bribery and anti-corruption laws and other regulations, as well as the recommendations of international bodies such as the OECD and the United Nations and the company’s own internal anti-corruption policy.

In this way, the Zaragozá Group and all its employees undertake not to engage in any of the following conduct:

  • Offering or accepting bribes to or from public officials or private individuals.
  • Offering or accepting facilitation payments to initiate or expedite administrative processes or procedures.
  • Offering or accepting gifts and hospitality to or from public officials or any other third party in contravention of this Code.
  • Making contributions on behalf of the organisation for political purposes.
  • Obtaining favourable treatment by using sponsorship or donations as a means to achieve it.
  • Using company business relationships and contracts to benefit themselves or a third party.
  • Establishing business relationships with third parties without complying with minimum due diligence duties in the knowledge of third parties.


All employees and directors of the Zaragozá Group state that they are aware of the existence of this Code and are familiar with its contents, and each of them has access to a copy of it.

Regardless of the hierarchical position of all the people who make up the Zaragozá Group, the rules, provisions and indications regulated in this Code are inviolable and must be respected without limitation.

All employees who join any of the organisations that make up the Zaragozá Group after the entry into force of this Code must be informed of its existence, be given access to a copy of it and accept full compliance with its principles.


When any employee witnesses or becomes aware of any conduct or action in their work department that infringes or may infringe this Code, they must inform their line manager or report it through the mechanisms established by the company for making suggestions and complaints. In the event that the complaint is directed against the complainant’s hierarchical superior, the latter must report the infringement of this Code to the person responsible for the Zaragozá Group’s People Area.

Once the complaints have been forwarded to the complainant’s hierarchical superior or to the head of the People Area, as the case may be, the latter must bring them to the attention of the Medienerco Management Committee (hereinafter, the “Management Committee“).

In this way, the Management Committee will supervise full compliance with this Code, resolving and ruling on possible breaches of this Code. The Management Committee meets weekly, and the resolutions and decisions adopted by it are recorded in the minutes.

The Steering Committee shall have the following powers in relation to the subject matter of this Code:

  • Promote awareness of this Code and ensure compliance with it.
  • Propose the necessary updates or amendments to adapt the Code to significant legislative, social and environmental changes.
  • Resolve the complaints and communications that have been referred to it on the grounds of alleged non-compliance with this Code. If the infringement gives rise to a labour misconduct, it shall be sanctioned in accordance with the labour regulations in force.
  • Make periodic reports or when requested by Medienerco’s Management Body, regarding compliance with this Code.


This Code was approved by the Board of Directors of Medienerco on 28 May 2021, coming into force on the same date.