Internal Regulations and Code of Ethics

I. INTRODUCTION

The drafting and preparation of these Regulations is based on the following considerations:

The substantial growth of the company and our commitment to full compliance with all applicable regulations has prompted the approval of this code of ethics and internal regulations. Through this document, the aim is to improve the work environment, prevent any possible situation of discrimination, and ultimately establish a code of ethics, conduct, and good professional practices.

II. GENERAL ASPECTS

Article 1.- Legal framework

The company "ZEPO INTELLIGENCE," S.L.U. (hereinafter, the "Company"), incorporated under applicable legislation, shall be governed by its bylaws, as well as by these Regulations and by all such rules and collective bargaining agreements as may be applicable to it.

Article 2.- Purpose of the Regulations

These Regulations form one of the basic rules for the operation of the Company and its relationship with its employees, regulating essential aspects such as the structure of the Company or the obligations and rights of its employees and their responsibilities. In any case, these Regulations shall respect the provisions of labor legislation and, where applicable, the relevant collective bargaining agreement.

Finally, these Regulations shall apply to the employees referred to in Article 4 below.

Article 3.- Territorial scope of application

These Regulations shall apply throughout the territory in which the Company carries out its activity in accordance with its Bylaws and with the resolutions adopted within its administrative body.

Article 4.- Subjective scope of application

These Regulations shall apply to all Company personnel, regardless of their level or position, seniority, or type of contract.

Hereinafter, all personnel to whom these Regulations apply shall be referred to as the "Employees."

Article 5.- Term of the Regulations

The Regulations shall enter into force on the following date: January 1, 2024, and from that date shall have an indefinite duration.

Article 6.- Amendment of the Regulations

The Company's management may review, amend, exclude, or add new conditions or obligations to these Regulations at any time, provided that such amendments respect the provisions of labor legislation and the applicable agreement where relevant, and are made in writing.

These changes must be duly communicated to the Employees in writing through the Company's usual channels of communication with them.

Article 7.- Interpretation of the Regulations

The interpretation of the Regulations shall be carried out in accordance with the principles that inspire them, as well as with their guidelines and the literal wording of their articles. The provisions herein shall apply to the Employees who are bound as set forth in Article 4, unless different conditions are agreed in writing between the Company and the Employees who so wish.

Article 8.- Sole Agreement

These Regulations supersede and replace all other regulations or agreements, written or verbal, on the matters covered by these Regulations.

Accordingly, prior agreements on these points shall cease to have force and effect as of the entry-into-force date set out in Article 5.

Article 9.- Partial nullity

Any declaration, whether by a judicial or administrative body, of the illegality, invalidity, nullity, or unenforceability of any of the articles of these Regulations, or part thereof, shall not result in the illegality, invalidity, or unenforceability of the remaining articles or the remaining parts thereof, which shall remain valid in all that is applicable, provided always that the articles or parts thereof declared illegal, null, invalid, or unenforceable are not essential.

Article 10.- Applicable law and competent jurisdiction

These Regulations shall be governed by and construed in accordance with Spanish legislation and, in particular, in accordance with the provisions of the Workers' Statute and all related labor regulations, as well as with the provisions of any applicable collective bargaining agreement.

For the resolution of any disputes or claims arising from the interpretation or performance of the Regulations, including all obligations arising from or relating to the Regulations, the Parties submit to the jurisdiction of the Courts and Tribunals having competence in accordance with the law.

III. ORGANIZATION OF THE COMPANY

Article 11.- Hierarchical structure of the Company

In order to ensure the proper management and organization of the Company and enable its correct operation, the following organizational structure is established:

The Company's managementManagement shall correspond to the sole administrator of the Company.

Hereinafter, the person or body responsible for managing the Company shall be referred to as the "Management."

The Company's departments or areasThe remaining structure of the Company shall be organized around the following departments or areas:

Customer Management, Sales, Marketing, Human Resources, Legal, Finance, Technology, Education, Product

Hereinafter, each of the managers or team leaders who direct each area shall be referred to as "Manager" or "Managers."

GENERAL PRINCIPLES

Article 12.- Equality in hiring

The Company undertakes to guarantee equal access to employment for all Employees and all potential candidates, carrying out a human resources policy based on the principles of equality, non-discrimination, and respect for the dignity of the Employees.

This policy applies both to the Company's current Employees and to future candidates or job applicants, with no type of discrimination permitted in their selection and hiring, whether on grounds of gender, race, religion, disability, marital status, age, ideology, pregnancy, identity, or place of residence, among others.

This principle shall inspire the entire human resources policy, as well as the Company's activities relating to staff recruitment, including the receipt of résumés; the screening or selection of candidates; job interviews; the preparation and analysis of tests assessing aptitudes and knowledge; the setting of salaries and supplements; and the establishment of the particular conditions to which the employment contract will be subject.

In this way, the selection process for new employees shall be carried out following objective criteria of merit, experience, knowledge, and ability in accordance with the characteristics and needs of each position offered. All candidates shall have the same opportunities, and the final hiring shall be carried out based on the Employee's aptitude and fit for the position. Working conditions shall likewise be established without any type of discrimination, and there shall be no discriminatory differences between current Employees and future hires.

Finally, the Employees undertake to facilitate the onboarding and integration of new employees into the workforce, assisting as much as possible with their training and adaptation, and respecting in all cases the principle of equal access and non-discrimination cited above.

Article 13.- Prohibition of discrimination and prevention of harassment

The Company undertakes to actively promote and foster the creation of an inclusive and respectful work environment that faithfully complies with all existing current legislation on the prevention of discrimination and harassment, whether on grounds of gender, race, religion, disability, marital status, age, ideology, pregnancy, identity, or place of residence, or for any other reason related to the foregoing.

By virtue of the foregoing, the Employees must provide their services in an inclusive manner, with no type of discrimination or harassment of any kind permitted, whether toward their own colleagues, their superiors, or their subordinate staff.

For the purposes of these Regulations, harassment shall mean any conduct or act by any Employee or by Management, whether verbal, visual, or physical, against one or more Employees based on grounds of gender, race, religion, disability, marital status, age, pregnancy, identity, or place of residence, or any other possible related reason. Such conduct must directly affect the Employee, whether by creating a degrading work climate or environment, by causing psychological or physical disturbance, by forcing their resignation, or by preventing them from being eligible for possible promotions or improvements in their position or working conditions.

By way of example, and on a non-exhaustive basis, situations of harassment shall include off-color comments or jokes, the use of degrading stereotypes, threatening and/or authoritarian behavior, or any non-consensual physical contact. Such conduct shall be sanctionable whether it takes place at the workplace, during social events or business trips, or through electronic means, such as email, mobile phone, etc.

Any type of discrimination or harassing conduct shall give rise to the corresponding disciplinary proceedings, and may lead, in serious situations, to the disciplinary dismissal of the employee as set forth in the Workers' Statute.

Finally, the Employees have the right, and the duty, to report to Management any form of discrimination they may observe in the course of their activity. This communication must be made in accordance with the provisions on the Company's internal communication set out in these Regulations.

Article 14.- Prohibition of child labor

Work by minors under 18 years of age is entirely prohibited at all of the Company's workplaces. Only work by emancipated minors under 18 and over 16 years of age, or by those over 16 who have the corresponding authorization from their parents or legal guardians, shall be permitted.

Article 15.- Internal promotion policies

Following the provisions of Article 12 on "Equality in hiring," the promotion and advancement of Employees shall be carried out by virtue of the principles of non-discrimination, qualification, and experience.

Accordingly, Employees who demonstrate adequate qualifications, who pass the corresponding tests, and who have performed their work diligently—complying in all cases with the provisions of these Regulations, as well as with applicable legislation and collective bargaining agreements—shall be assigned to higher positions.

Article 16.- Occupational risk prevention policies

The Company undertakes to guarantee the safety of the Employees in accordance with the provisions of Law 31/1995 on Occupational Risk Prevention and other legislation related to this matter.

Accordingly, the Employees shall be provided with all the safety and protective means necessary for the performance of their activity. Specifically, the Company undertakes to comply with all occupational risk prevention measures established in labor legislation and the applicable collective bargaining agreement where relevant, providing the Employees with the necessary material and training resources to guarantee the correct performance of their work.

The Employees, as well as future additions to the workforce, shall receive the corresponding instructions on occupational risk prevention, and shall be required to be familiar with all the risk prevention and safety policies implemented by the Company.

In addition, periodic courses or training talks shall be held in order to provide information on new safety measures, and accident prevention policies adapted to the activity carried out by the Employees shall be established.

Article 17.- Promotion of the professional development of the Employees

The Company shall seek, within its means, to foster the advancement of its Employees, providing them with the knowledge and instruction necessary to perform their activity effectively and to grow within the Company. In any case, the internal promotion and hiring policy established in these Regulations shall be followed.

Article 18.- Protection of the Employees' private information

The Company recognizes the importance of protecting all confidential information relating to its Employees in strict compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), as well as Organic Law 3/2018 on the Protection of Personal Data and the guarantee of digital rights and its implementing regulations (LOPDPGDD), and/or any that may replace or update them in the future.

Accordingly, the Company undertakes to manage the Employees' information files in accordance with the aforementioned regulations, and must request authorization from them in order to properly process their data. The Employees' data may be incorporated into a data-collection file of the Company's own, whether automated or not, for the purpose of correctly performing the employment relationship and, where appropriate, allowing the administrative and/or commercial management of the data that the Company may deem necessary.

Finally, the Employees may exercise all the rights of access, rectification, erasure, restriction of processing, portability, or objection to which they may be entitled under the aforementioned legislation.

Article 19.- Reconciliation of professional and family life

One of the guiding principles of the Company's human resources policy shall be the active promotion of measures to reconcile the professional and family life of the Employees in everything that is possible in view of their activity.

Within the Company, the establishment of schedules that take into account the family situation of the Employees shall be promoted, seeking to adapt, as much as possible, the working day to their family needs.

Finally, these Regulations include specific measures aimed at the reconciliation of the family and working life of the Employees, inspired by this principle. In addition, in the future, efforts shall be made to promote new measures that respond to the needs of the Employees.

Article 20.- Compliance with immigration regulations

The Company undertakes to comply at all times with the applicable legislation on the hiring of foreign workers, both those of EU and non-EU origin.

Accordingly, the Company expressly prohibits the hiring of employees who do not hold the proper valid work permit, or who do not demonstrate that it has been duly granted by the competent Administration.

In situations where it is desired to hire personnel who do not hold a work permit, the corresponding administrative procedure must be followed to properly process the employee's work permit before formalizing their hiring.

Finally, any Employee may report to Management any possible breaches of immigration legislation that they may detect in the Company's hiring policy.

Article 21.- Integration of persons with disabilities or at risk of social exclusion

Management shall establish appropriate measures to facilitate the inclusion within the Company and the performance of the activity of persons who are in a situation of physical or psychological disability, as well as persons who are at risk of social exclusion.

RULES OF CONDUCT

Article 22.- Use of the Company's IT resources

The Employees shall use the Company's IT resources diligently and responsibly for the performance of their activity. IT resources include all electronic methods that may enable proper communication between the Employees, including personal computers, mobile phones or tablets, Wi-Fi connections, or corporate email accounts, among others.

Specifically, the following aspects must be respected in relation to the electronic resources provided by the Company:

The installation of software or computer programs other than those provided on the Company's computer or tablet is prohibited, as is the use of software or computer programs without their corresponding license.

The corporate email may not be used for purposes that go beyond what is considered necessary for the strict performance of the duties of one's position. In addition, responsible use of the email account must be made in accordance with the Company's guidelines, and it may not be used to defame or disparage other colleagues or third parties, or to use offensive language.

The Company shall carry out the necessary monitoring of the Employees' email accounts and IT resources. These monitoring activities shall be limited to verifying compliance with the Employees' work obligations and ensuring the integrity of the devices provided. In any case, the Employees shall be informed in advance of the carrying out of these monitoring activities.

The Employees may not encrypt emails sent from the Company's corporate account or install any encryption software or application for that purpose.

Likewise, the Company undertakes to respect the privacy of the Employees in the use of the electronic devices provided, in accordance with the provisions of the LOPDPGDD. Accordingly, the monitoring activities shall be limited to verifying compliance with the Employees' work obligations, as indicated above in this Article.

Article 23.- Use of the Company's resources provided to the Employees

The Employees must care, with due diligence—as they would with their own property, and in a manner appropriate to their work—for all the items or assets provided by the Company, such as laptops, mobile phones, tablets, company vehicles, among others. In relation to this point, the Employees must respect the following rules:

Not to use them for activities unrelated to the tasks assigned for the performance of the professional activity.

The Employees shall be liable for any damage they may cause by engaging in conduct that goes beyond the everyday use of the items or assets provided by the Company, or in cases where the specifically detailed rules of use have not been respected. Improper use or use beyond the everyday use of these assets shall give rise to the corresponding disciplinary sanction.

Article 24.- Protection of the Company's industrial and intellectual property

Given the importance to the Company's activity of all its industrial property (patents, trademarks, etc.) and all its intellectual property (copyrights, computer programs, etc.), the Employees must actively respect and protect this type of Company property.

Specifically, the Company's industrial property includes, among others, patents, utility models, trademarks, trade names, and industrial designs owned by it. On the other hand, intellectual property includes all types of artistic creations, writings, videos, computer programs, know-how, or the like created by or owned by the Company.

The use of this type of property by the Employees shall be strictly limited to the needs of their position and to the instructions of their superiors or Managers, and they may not use any of this type of property for the performance of activities other than those corresponding to them.

Article 25.- Use of personal mobile phones

In order to avoid possible distractions or accidents arising from lack of attention at work, prevent errors in their work, and ensure due collaboration between colleagues for the performance of the activity, the use of the personal phone or any personal mobile device of the Employees during their working day (not including their corresponding rest periods) is expressly prohibited.

The mobile phone may be used in common areas during rest periods provided that it is done respectfully toward the other colleagues and without disrupting the performance of the activity.

The abusive, repetitive, or reckless use of the personal phone may give rise to a serious disciplinary sanction.

Article 26.- Respect in intra-company relations

The Employees undertake to carry out their activity and work diligently and respectfully toward all their colleagues, their Managers or superiors, and/or their subordinate staff, and Management.

In this way, the Company shall seek to promote a good work environment that fosters the performance of the activity based on the principles of respect, cooperation, and help, seeking to avoid possible disputes that may arise within the activity and favoring their peaceful resolution should they arise.

Any disagreement or dispute between the Employees must be communicated through the internal channel established for this purpose, and the Company must provide a prompt and reasoned response in order to resolve it and prevent its recurrence in the future.

Article 27.- Compliance with applicable legislation and internal regulations

The Employees must observe all the rules of conduct set out in these Regulations, as well as the instructions of Management and applicable legislation.

Specifically, the Employees are obliged to respect and comply with the provisions of these Regulations, as well as all applicable current legislation. No breach of the aforementioned rules shall be permitted, whether personally or through the help or collaboration of third parties.

Likewise, the Employees must inform Management or their corresponding Manager of these possible breaches within the Company as soon as they become aware of them.

The Company undertakes to provide the Employees with all the information on the obligations set out in these Regulations, as well as on all applicable legislation, in order to ensure that they can effectively comply with all their obligations.

In the event that, on a specific point, the Employees are unaware of the applicable regulations, or have any doubt about their interpretation or application, they must contact their superiors, Managers, or Management to report such circumstance. The Company undertakes in these cases to provide all the corresponding information and to resolve any existing doubts.

Article 28.- Carrying out other work activities

In the pursuit of performing their activity as effectively as possible and of preventing possible abuses in the use of information acquired in the performance of their work, the Employees may carry out activities outside their working hours provided that they do not cause significant harm to the work they must perform for the Company, and respect any exclusivity or non-competition clauses that may be set out in their respective employment contracts.

The Employees may not, unless otherwise specifically agreed in their respective employment contract, provide advice or services in favor of natural or legal persons engaged in a similar business or that may be considered competitors of the Company, whether under an employment contract—even if it is a special employment relationship—or under a contract for services or internal advisory work, directly or indirectly through interposed legal entities, provided that the information obtained in the performance of their activity is not used to compete unfairly with the Company.

The Employees may also not carry out any other economic activity, in addition to the provision of their services to the Company, whether on their own account or for others, directly or indirectly through interposed legal entities, if this activity may give rise to a possible situation of unfair competition with the Company.

Article 29.- Treatment of confidential information

The Employees acknowledge that all documentation, projects, files, or information of any nature exchanged, provided, or created within the Company or entities and organizations with which it collaborates, that they may acquire or to which they may have access during the course of their employment relationship, is confidential information of the exclusive property of the Company.

Therefore, the employees undertake, both during and after the termination of the employment relationship, indefinitely:

a) to safeguard, not disclose, and not communicate to any person or entity, all or part of this information, acting with the utmost possible diligence;b) not to exploit, on their own behalf or that of a third party, directly or indirectly, all or part of this information; and,c) not to make or keep copies of the information, in any format or medium, for purposes other than those required for the performance of their work.

Upon termination of the employment relationship, the Employees shall hand over to Management and/or their Manager(s) all documents and materials containing confidential information.

Finally, the reputation and continued success of the Company require that the secrecy of confidential information be maintained and safeguarded at all times. For this reason, the Employees shall be liable for all damages that the Company may suffer as a result of the willful or negligent breach of their confidentiality obligation.

Article 30.- Compliance with data protection regulations

All Employees are obliged to strictly comply with the provisions of European Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), as well as Organic Law 3/2018 on the Protection of Personal Data and the guarantee of digital rights (LOPDPGDD) and its implementing regulations, and/or any that may replace or update them in the future.

Accordingly, the Employees undertake not to disclose to third parties the personal data learned in the performance of their activity. Should it become necessary to make any type of communication of personal data, they undertake always, and beforehand, to request the express, informed, and unequivocal consent of the person who is the owner of such personal data, indicating the specific purpose for which the communication of their data will be made.

Article 31.- Care of materials, vehicles, and tools

The Employees shall treat the materials and tools provided by the Company diligently and appropriately to the characteristics of their work.

In the event that certain means, vehicles, or tools require a special qualification for their use (e.g., forklifts, lifting cranes, driver's license, etc.), they shall only be operated by Employees who hold the corresponding qualification. In the event that no Employee holds the corresponding enabling license, the Company shall seek to provide the training to obtain the necessary permits.

Any improper use, use that does not follow the instructions provided, or use carried out without holding the corresponding enabling license shall give rise to a sanction in accordance with the provisions of the Workers' Statute.

Article 32.- Remote work

This matter shall be governed in accordance with the following provisions:

– Remote work must be provided from the Employee's Spanish residence.– When the Employee wishes to change the place of provision of services, they must notify it in writing with sufficient advance notice. The Company reserves the right to assess whether the new location meets sufficient suitability conditions to keep the remote work agreement in force.– The Employee is assigned to the Company's workplace located at one of their residences.– The Company, through the persons it designates or the hierarchical superiors, may monitor and supervise the Employee's activity through electronic, computer, and IT systems. If, for work reasons, the physical presence of Company representatives at the Employee's workplace is necessary and this is their own residence, it must be notified in advance and may not take place without the prior express consent of the Employee.– The Employee freely consents to the holding of meetings and communications via videoconference (for which they must activate the camera) or by any other image and sound transmission system, waiving the right to consider such situation or circumstance as an unlawful intrusion into the private residence, always within their working hours.– The performance of remote tasks by the Employee shall be subject to the following conditions:● Authorization by the Company, enabling them to perform their tasks and functions outside the Company's premises.● The Company must have detailed the period during which teleworking extends, in addition to the working hours and type of working day of each worker.● The transfer of media from the Company's premises must be authorized by the Company. Likewise, each medium shall be linked to a specific worker.● The use of media and systems is subject to compliance with the same security measures that the Company imposes for on-site work.● The Employee shall manage their personal access keys to media and systems with the utmost diligence, not communicating them to third parties and updating the credentials with the frequency indicated by the Company.● The Employee undertakes to report any theft, loss, or unauthorized access to Company information within a maximum period of 24 hours.– The use of personal devices at work is subject to written authorization by the Company.– In the event that the Employee performs teleworking with their own personal devices, they must follow the following guidelines:● Prevent third-party access to devices equipped with access credentials (keys, passwords, permissions, security patterns).● Verify that the antivirus software and firewall are up to date and that the equipment is protected.● Avoid access to insecure wireless connections, such as open Wi-Fi networks.● Delete from their devices all data to which they had legitimately had access. It shall not be possible to keep a copy, even if they had downloaded the information onto their computer or another device.● Report thefts, information losses, and other incidents in the same manner as if they were Company devices.– Access to the Company's computer system must be carried out under the control and responsibility of the Employee, who must follow the procedures established by the Company.– Without prejudice to the travel that they must carry out for their work, the Employee shall refrain from performing their work in a place other than the workplace agreed in the remote work agreement or annex thereto signed for this purpose; in particular, the Employee shall refrain from performing their work from cafeterias, airports, and similar public places, taking special precautions not to compromise the secrecy of the Company's physical or digital documents and not to compromise the IT security of the Company's devices or, where applicable, of the Employee's devices connected to the Company's networks or, in general, to its documents, by connecting to public networks or, in general, networks of dubious IT security, without prejudice to general compliance with the IT security and confidentiality policies.– The Company shall implement and coordinate teleworking with respect for and recognition of the workers' right to digital disconnection, in accordance with Article 88 of the Organic Law on the Protection of Personal Data and the guarantee of digital rights (LOPDGDD).– The aim is to guarantee the reconciliation of work and family life. Therefore, it is understood that workers have the right to exercise digital disconnection, outside the working hours agreed with the Company for teleworking.– The employee shall have the right to adequate protection in matters of occupational health and safety, in accordance with the provisions of Law 31/1995 of November 8 on the Prevention of Occupational Risks, and its implementing regulations.– The employee authorizes the technicians of the prevention service to access the workplace to carry out the occupational risk assessment or, failing that, undertakes to take the necessary data required of them by the prevention service to carry out the occupational risk assessment.

PREVENTION OF CORRUPTION AND FRAUD

Article 33.- Conflict of interest situations

The Employees are obliged to disclose any potential conflict of interest situation during the performance of their activity. A conflict of interest shall mean those situations in which the Employee competes in the same sector as the Company, or those cases in which they may use confidential information or knowledge acquired in the performance of their activity to compete with the Company, among others.

Accordingly, the Employees may not carry out any activity or transaction that may potentially harm the interests of the Company, unless expressly authorized by Management.

In the event that any Employee detects a potential conflict situation, it must be communicated to their immediate superior, Manager(s), or Management as soon as they become aware of it.

Article 34.- Hiring of relatives

The Company shall seek to guarantee respect for the hiring principles based on equal access, experience, and training established in these Regulations. In order to guarantee such principles and prevent possible situations of abuse of power or conflict of interest, the hiring of persons with close affinity to the Employees and/or Manager(s)—which includes relatives, friends, or persons with whom they may have romantic relationships—is prohibited unless they have the express consent of Management.

In accordance with these Regulations, the following shall be considered relatives of an employee: fathers, mothers, children, siblings, nieces and nephews, cousins, grandparents, grandchildren, great-grandchildren, brothers- and sisters-in-law, sons-in-law, mothers-in-law, and any other similar relative.

On the other hand, persons with affinity shall be considered all those with whom one has a relationship of friendship, partners, boyfriends/girlfriends, or any other relationship that has been maintained for a period of time.

The Employees undertake to inform their hierarchical superior of any new addition of a relative or a person with affinity, whether as employed or freelance staff, or as a supplier or collaborator of the Company.

In this situation, the Company may take the measures it deems necessary, and may even request the termination of the contract signed with the Employee's relative or person with affinity, or even reject their candidacy.

Article 35.- Acceptance of gifts

In order to guarantee the proper functioning of the Company and compliance with all criminal legislation on economic crimes, the Employees may accept potential gifts or advantages from third parties who may have interests in the Company, such as, among others, suppliers, clients, or collaborators of the Company (hereinafter, "Related Persons"), provided that the following conditions are respected:

Employees may only accept small gifts whose value does not exceed, in aggregate (in the case of several), 50 euros.

Article 36.- Giving of gifts by the Employees

The Employees may not give any type of gift or gratuity in favor of Related Persons that is intended to buy their goodwill or receive an advantage from them and that goes beyond what is considered appropriate or customary in the sector. Specifically, the giving of gifts shall be considered appropriate in accordance with the following conditions:

Employees may give gifts provided that a superior has approved it.

On the other hand, gifts or advantages directed at public officials or civil servants shall be entirely prohibited, regardless of whether or not they are directly intended to obtain greater advantages or facilities from the administration.

In the event that any Employee becomes aware of these practices, they shall have the right, and the duty, to immediately inform Management in order to help eradicate this type of conduct.

Article 37.- Treatment of clients

In line with the image and principles of the Company, the Employees are obliged to treat all clients with complete courtesy, respect, and professionalism. The Employees shall provide clients with all the information requested of them, except for information protected as confidential and that regulated by data protection legislation.

In any case, all information sent to clients about products and services must be truthful and accurate, and the provision of false information to clients in the communications and promotional activities carried out by the Employees is expressly prohibited.

On the other hand, in accordance with data protection legislation and the provisions of these Regulations, the Employees shall treat clients' personal data confidentially.

Finally, the Employees must follow the provisions of this Section on the prevention of corruption and fraud in all related activities they carry out with clients.

Article 38.- Relations with suppliers

The Employees shall maintain an appropriate, respectful, and lawful relationship with all of the Company's suppliers.

The hiring and management of suppliers by the Employees shall be carried out transparently, attending to the interests and needs of the Company, and avoiding any possible situation of conflict of interest or personal benefit in relation to their hiring or management.

Any Employee's knowledge of an advantage received by their colleagues or superiors from current or potential suppliers must be brought to the attention of the Manager and/or Management as soon as possible.

Article 39.- Market practices

The Company undertakes to compete in the market fairly, complying with all currently applicable regulations on unfair competition and free competition at both national and European levels. Accordingly, no type of deceptive conduct that may harm free competition shall be permitted, nor the issuance by the Employees of any malicious or false information about the Company's competitors.

On this point, this type of fraudulent conduct is also prohibited in relation to any other market operator other than competitors or to possible public regulators.

Article 40.- Compliance with accounting and tax regulations

The Employees shall carefully respect all applicable accounting, tax, and Social Security regulations in each of the operations and transactions they carry out. Thus, clients must be invoiced in accordance with the provisions of current legislation, and all expenses must be justified by the corresponding invoice or contract. These supporting documents must be sent to the personnel in charge of keeping and managing the Company's accounts as soon as they are available.

On the other hand, the Employees are expressly prohibited from carrying out any activity or transaction that is intended to breach applicable tax or Social Security regulations or to evade the payment of any fee, levy, or tax, whether state, regional, or municipal, that the Company is obliged to pay.

In relation to the foregoing, the Company undertakes to respect at all times applicable tax and Social Security legislation, keeping the accounting books clearly and in accordance with applicable accounting and tax principles and obligations. The persons responsible for the preparation of these documents must guarantee the reliable collection of data and the correct preparation of all financial statements.

Article 41.- Compliance with environmental regulations

The Employees undertake to comply with all environmental, pollution prevention, and environmental protection regulations applicable to the Company's activity, as well as with all of the Company's instructions or codes of conduct in relation to the handling of materials, recycling, and pollution prevention.

Article 42.- Compliance with the Regulations and the Company's instructions

The Employees are obliged to comply with all the provisions of these Regulations, as well as with all the instructions they receive from Management or their Manager(s).

Accordingly, the work procedure must conform to what is established by the superiors in charge or Managers, as well as to the guidelines, work guides, or manuals prepared by the Company. In the event that any doubt arises about such guidelines or instructions, the Employee must contact their Manager(s) or, if not possible, Management, in order to resolve all possible existing doubts.

The Company undertakes to provide the courses and training necessary to guarantee the correct performance of the Employees' work and their adaptation to new work procedures or to the new technical tools acquired by the Company. The Employee shall in turn be obliged to attend all these training courses or sessions, as well as to pay full attention and interest to ensure their correct understanding.

Finally, the Employees must permit and facilitate all audit work that Management may carry out in order to analyze the current situation of the Company, establish the rate of compliance with the Regulations, and assess the possibility of implementing new improvements that may be deemed necessary.

Article 43.- Responsibility of the Managers

All Employees who have other employees or workers under their direction, including all Managers, must faithfully respect the provisions of these Regulations and be an example of their application for their subordinate employees.

In general, the Managers shall act respectfully and inclusively, with full respect for the principles of non-discrimination and equality, and for the other principles set out in these Regulations, always ensuring the well-being of the Employees and the interest of the Company.

In addition, they shall provide all their support to the Employees in everything they need for the correct provision of their services, resolving their doubts diligently and motivating them appropriately.

As regards the performance of the activity, the Managers shall provide their Employees with all the information necessary so that they can carry out their work effectively and with complete safety, as well as clearly understand all their obligations.

On the other hand, they shall ensure that their subordinate employees respect at all times the provisions of these Regulations, as well as the other corresponding instructions or guidelines of action or behavior. In the event that they detect any serious or repeated breach of the Regulations, this situation must be communicated immediately to the body or person in charge of supervising it or to Management.

VII. EMPLOYEE HEALTH AND SAFETY

Article 44.- Consumption of narcotic and psychotropic substances

The consumption of any narcotic or psychotropic substance during working hours, or coming to the workplace under the effects of the consumption of this type of substance, is prohibited.

For the purposes of these Regulations, narcotic or psychotropic substances shall be considered to include alcohol, cannabis, methamphetamines, cocaine, opiates, and any other similar substance that alters the physical and mental condition of the Employee.

The Company may carry out the appropriate analyses periodically for the detection of the consumption of this type of substance.

The consumption of this type of substance may be considered a serious offense, following in all cases the provisions of the applicable collective bargaining agreement, and may lead to the disciplinary dismissal of the employee in the event that the habitual consumption of this type of substance affects the performance of their activity.

Article 45.- Safety measures

Given the importance of safety and protection measures for the physical and mental integrity of the Employees, and in compliance with the provisions of Law 31/1995 on the Prevention of Occupational Risks and other legislation applicable to this matter, the Employees are obliged to use all protective means and to act in accordance with the safety instructions provided by the Company throughout their working day.

The breach of these measures shall give rise to the initiation of disciplinary proceedings in accordance with the provisions of the corresponding section of these Regulations.

Article 46.- Monitoring of medical leave

Employees who are on medical leave due to illness must request the corresponding leave certificate from their doctor. This leave certificate shall be sent to the Company's management in the shortest possible time.

The leave certificate must include the Employee's medical condition as well as the possible estimated duration of the Employee's recovery.

On the other hand, in cases of work accidents, the Employees must go to their corresponding mutual insurance company so that their clinical situation can be correctly assessed.

Article 47.- Emergency plans

In order to guarantee the greatest safety for the Employees in the face of potential emergency situations, the Company undertakes to establish action and evacuation plans depending on the situation, in cooperation with the emergency services of the area where the workplaces are located.

These plans, and their subsequent modifications, shall be duly communicated and taught through the preparation of courses or training sessions for the Employees, who shall in turn have the obligation to be familiar with them and to act in accordance with them in emergency situations.

Likewise, the Company may establish, when it deems appropriate, possible drills to guarantee the correct implementation of the emergency plan in the Company.

VIII. MONITORING OF ACTIVITY

Article 48.- Video surveillance

In accordance with the current regulation established in the LOPDPGDD, the Company shall inform the Employees, and their legal representatives, expressly, clearly, and concisely, of the existence of video surveillance cameras at the workplaces or in the Company's vehicles.

In any case, this duty of prior information shall not be necessary when an Employee is recorded committing an unlawful act and the recording device is located in a sufficiently visible place with a sign informing of the Employee's right to be able to exercise their rights of access, rectification, erasure, and restriction of the filmed information.

The video surveillance devices shall be used only for security measures and to verify the correct performance of the work, and they shall be placed at the places where the service is provided, avoiding locations that may violate the privacy of the Employees, such as, by way of example, changing rooms, break rooms, kitchens, among others.

Finally, sound recording devices may be installed provided that, given the circumstances of the activity, or of the facilities where the activity is provided, the establishment of these devices becomes necessary in order to monitor the activity of the Employees. In any case, as mentioned with reference to the video cameras, the installation of this type of device must be duly notified to the Employees, as well as to their corresponding representatives.

Article 49.- Geolocation systems

The Company may use, if it deems appropriate, geolocation systems in its vehicles or mobile devices for the sole purpose of ensuring and verifying the correct performance of the work activity by the Employees.

In any case, the Company shall duly inform in advance, expressly, clearly, and concisely, of the installation of these geolocation devices and their operation to the Employees.

Article 50.- Monitoring of compliance with safety measures

The Company may establish the measures necessary to verify and guarantee the correct compliance with the safety measures established by the Company. These surveillance and monitoring tasks shall be carried out in order to guarantee the integrity and safety of the Employees.

In the event of the establishment of video surveillance or geolocation systems, the provisions on these points in this Section shall apply.

Article 51.- Reporting breaches of safety measures

In the event that any Employee detects a failure or breach of the necessary safety measures established in these Regulations, as well as in occupational risk prevention legislation or in the provisions of the applicable collective bargaining agreement where relevant, they shall have the right and the duty to communicate such situation to their Manager(s) or Management diligently in accordance with the provisions of the corresponding Section on internal communication.

Article 52.- Use of the Company's Wi-Fi networks

The Company decides to specifically regulate the rules of use that the Employees must follow with respect to the Company's Wi-Fi networks.

This matter shall be governed by the following provisions:

The company's Wi-Fi may be used only for professional activity.

REMUNERATION POLICY

Article 53.- Remuneration

The setting of the amount corresponding to the remuneration of the Employees shall be carried out fairly and equitably, taking into account the position and level of each Employee, their responsibilities and training, their functions, and the characteristics of the position, avoiding any type of discrimination, whether on grounds of gender, race, religion, disability, marital status, age, ideology, pregnancy, identity, or place of residence, or based on any other similar factor or trait.

In any case, the Company undertakes to comply with the provisions on the remuneration of the Employees in labor legislation, and above all, in the applicable collective bargaining agreement.

Article 54.- Payment of salaries

The payment of salaries to the Employees shall be carried out as follows:

Salaries shall be paid between the 28th and the 4th of each month by bank transfer to the account provided by the employee.

In the event that the payment day is a weekend or a national, regional, or local holiday, payment shall be made on the immediately following business day.

Article 55.- Salary increases

The Employees may receive, periodically or not, increases in their base salaries, supplements, or incentives at the Company's free discretion. In any case, a one-time salary increase shall not imply that it must be repeated periodically.

Finally, the Company shall respect the salary increases agreed in the applicable collective bargaining agreement.

Article 56.- Per diems and travel expenses

The Company shall establish compensation for the travel of the Employees outside their usual workplace in accordance with the provisions of legislation and the applicable collective bargaining agreement. These expenses shall include the costs of meals, accommodation, and transportation necessary for the performance of the activity.

Article 57.- Bonuses or financial incentives

Regardless of the supplements and extraordinary payments due to the Employees by virtue of their employment contract, as well as current labor legislation and the applicable collective bargaining agreement, the Company may, at its sole discretion, establish the payment of bonuses or incentives to the Employees, without being, in any case, obliged to establish a specific bonus or to establish one-time bonuses periodically.

Article 58.- Other salary supplements

The Employees shall receive salary supplements in accordance with the provisions of current legislation, and where applicable, in accordance with the provisions of the collective bargaining agreement applicable to the company.

Article 59.- Request for payslips

The Employees may access their corresponding payslips as follows:

Payslips may be requested from the payroll management firm (gestoría).

WORKING DAY

Article 60.- The working day

The Employees shall provide their services without being subject to a specific schedule. In this way, the Employees may carry out their activity within the schedule most appropriate to their personal situation, provided that the objectives established by the Company are met.

Article 61.- Work calendar

The Company shall establish the work calendar of the Employees in accordance with its power to direct the activity set out in Article 20 of the Workers' Statute, and in respect of legislation and, where applicable, the applicable collective bargaining agreement.

Article 62.- Meal and rest times

In order to guarantee the cleanliness of the workplace and avoid possible distractions or accidents, the intake of food during working hours is prohibited, unless it is necessary for the Employee for health reasons.

Meals shall be taken during the corresponding rest periods that shall be set in each Employee's employment contract.

Article 63.- Punctuality of the Employees

The Employees are not required to comply with specific punctuality rules.

Article 64.- Self-management of time and overtime

You can organize yourself effectively by taking advantage of the flexibility of the remote or hybrid schedule without losing focus or discipline.

Define your work schedule: Even if you work flexibly, establish a clear schedule so that you can structure your working day and maintain a balance between personal and professional life. You know that to coordinate with the team you must be available between 10:00 and 16:00.

Prioritize your tasks: Use management tools to plan your tasks and ensure that you meet important deadlines.

Overtime: Zepo does not promote working overtime. Should it be necessary for productivity or business needs, it must be requested and approved by the respective Area Manager.

Article 65.- Recording of the working day

The Company undertakes to comply with the current regulation on the monitoring of the working day, making the corresponding time-control sheet available to the Employees.

The Employees must complete these working-day control sheets, truthfully indicating the start and end times of their working day, as well as the corresponding breaks.

Article 66.- Geographic and functional mobility of the Employees

The Employees must have the necessary flexibility to perform their work outside the workplace in situations where it may be necessary for the Company.

On the other hand, some of the functions or tasks of the Employees may be modified or altered in cases where it is necessary due to operational, procedural, or organizational aspects of the Company. In any case, it shall be their hierarchical superior or Manager who justifies this one-time change of functions, respecting labor legislation and, where applicable, the provisions of the applicable collective bargaining agreement.

VACATION AND RECONCILIATION OF PROFESSIONAL AND FAMILY LIFE

Article 67.- Vacation period

The taking of vacation must be carried out respecting current labor legislation and the applicable collective bargaining agreement, as well as by virtue of the following instructions:

As indicated in the internal vacation planning.

Failure to comply with the above instructions may mean that the taking of vacation does not fully conform to the dates desired by the Employee.

Article 68.- Remote work and teleworking

In order to facilitate the reconciliation of the work and family life of the Employees, the Company shall promote, provided that it is technologically and economically possible, and the Employees voluntarily so wish, the performance of their work through electronic means.

On the other hand, in accordance with the provisions of Article 38.8 of the Workers' Statute, the Employees may request, as part of their right to the reconciliation of family and working life, the provision of all or part of their services electronically. In these cases, the Company shall attend to the request and shall seek to facilitate, as much as possible, the provision of these services electronically within its means and to the extent that its activity allows.

The Employees subject to this type of work shall provide their services with equal rights and obligations as the other Employees. In addition, they shall be provided with the necessary training so that they can provide their services through the electronic means provided in an appropriate manner.

The Company may maintain control over the activity carried out by the Employees provided that the requirements mentioned in the preceding articles are observed and the private life of the Employees is respected.

Finally, the Company undertakes to promote the right to digital disconnection of the Employees in order to guarantee the reconciliation of their work and family life. In this way, the Employees shall only be required to be connected and active during their working day to the electronic means provided. The Employees may not be required to remain connected outside such hours or once the objectives set by the Company have been achieved.

Article 69.- Maternity leave and breastfeeding leave

One of the guiding principles of the Company's relationship with its Employees is to facilitate and promote the reconciliation of the professional and family life of the Employees. In this way, the Company undertakes to comply with the provisions of the Workers' Statute and other applicable regulations or collective bargaining agreements in order to facilitate the corresponding leave periods needed by the Employees and the taking of breastfeeding leave that is requested.

Article 70.- Requests for leave of absence

The Company shall attend to all requests for leave of absence (whether voluntary leave, leave to care for relatives, etc.) that are sent to it by the Employees, resolving them in accordance with the provisions of applicable legislation, as well as the provisions of the collective bargaining agreement where applicable.

In the event that Management denies a leave of absence at a given time, provided that applicable legislation or collective bargaining agreement allows it, such denial shall be duly justified on the basis of objective reasons by the Company.

Article 71.- Adaptation of the working day

The Company undertakes to negotiate with the Employees who so request possible changes or adaptations to their working day based on their personal needs. The request for this change would imply reducing their working hours within the Company's means.

The Company shall respond in writing to the Employee's request, justifying the possible acceptance or rejection of the Employee's request, and may, where applicable, propose an alternative change to the one requested by the Employee based on a series of objective reasons relating to the Company's activity or organization.

XII. INTERNAL AND EXTERNAL COMMUNICATION

Article 72.- Reporting of discrimination and harassment situations

As mentioned above, the Employees have the right and, at the same time, the duty to report any type of discrimination or harassment situation against themselves, against any colleague, or against any superior or subordinate staff, that they may become aware of or witness. No Employee shall be exempt from this obligation. Specifically, this communication must be made through the following channel:

confidential@zepo.app

In any case, the existence of this channel does not prevent the communication of these situations through any other type of previously established or usual means for the Employees' representatives.

Given the importance to the Company of preventing all these possible situations of harassment and discrimination, they shall be communicated immediately. Management undertakes to initiate the corresponding internal investigation in order to establish the facts and apply the corresponding sanction where applicable.

In any case, if the Employee or Employees who report a situation of discrimination or harassment consider that the Company has not acted with complete diligence, they may take the legal actions they deem appropriate in order to eliminate this situation and prevent it from recurring in the future.

Article 73.- Reporting of other breaches of the Regulations

Likewise, the Employees have the right and, at the same time, the duty to report any possible breach of the provisions of these Regulations of which they become aware. Specifically, this type of breach must be reported through the following channel:

confidential@zepo.app

In any case, the existence of this channel does not prevent the communication of these situations through any other type of previously established or usual means for the Employees' representatives.

The communication shall be made as soon as the breach situation is known, and it shall not prevent the Employee from adopting the judicial measures or communication to the Employees' representatives that they deem necessary.

Article 74.- Communication of any other circumstance

In the event that the Employees wish to communicate any aspect related to their work or any personal circumstance (such as the inability to come to their position due to illness, the request for a personal day, etc.) that may affect their activity, they may address their immediate superior or Manager(s) directly in writing or contact the following email account: rrhh@zepo.app.

Article 75.- Participation in conferences and congresses

In respect of the right to personal and family privacy, the Employees may participate in those conferences and congresses to which they are invited as speakers without needing to obtain prior authorization from the Company.

In any case, the speaker Employee must respect their obligations regarding the disclosure of confidential Company information and data protection set out in these Regulations as well as in their corresponding employment contract.

Article 76.- Contact with the media

Likewise, the Employees may maintain dialogue or contact with journalists or external communicators without needing to obtain prior authorization from Management.

In the event that information related to the Company is shared with these professionals, the Employees must respect their confidentiality and data protection obligations, and follow in all cases the corresponding communication guidelines established where applicable by the personnel competent for this within the Company or Management, as well as the provisions of these Regulations.

Article 77.- Corporate image and reputation

Corporate image and reputation is one of the Company's greatest assets, the result of its years of activity and the correct provision of its service. For this reason, the protection of this image and the prevention of any conduct by the Employees that may damage or harm such reputation is of vital importance to the Company.

In this way, the Employees must act in the most appropriate manner in the performance of their activity and, above all, in their relationship with clients, suppliers, and any other collaborator of the Company.

Article 78.- Communication policy

The Company wishes to guarantee the establishment of an effective external communication policy that guarantees and protects the integrity of its image and reputation.

External communication shall mean any information directed to the media, clients, or the Company's social networks, including all promotional and advertising campaigns.

Any contact received by any Employee from journalists or the media to deal with matters referring directly to the Company and its activity must be forwarded to the person or body in charge of communication.

Article 79.- Use of social networks

The Company is part of various platforms in order to maintain effective communication with its clients, and to effectively communicate and promote the activity it carries out.

In any case, alongside these profiles, new corporate profiles may be created in the future (hereinafter, the "Platforms").

In this way, the Employees undertake to respect the prestige and image of the Company on these Platforms, undertaking to make appropriate use of the Company's social networks, and not to defame, insult, or leak confidential information through personal profiles on such platforms.

With respect to the Company's corporate profiles, the Employees undertake to interact with the other users and clients in a cordial, polite, and professional manner, without at any time resorting to insult or disparagement, and providing information appropriate to the client's needs. The guidelines of the persons in charge of client management shall be followed in all cases.

On the other hand, the confidentiality of the data that clients may share with the Employees through these Platforms shall be respected at all times, in accordance with the provisions of these Regulations, their employment contract, any confidentiality agreements signed, and current data protection legislation.

In addition, the use of the Platforms for the publication of any type of dishonest or offensive video toward the Employees or toward third parties is prohibited, giving rise to the corresponding sanctions where applicable.

Finally, the Employees may have personal profiles on social networks without needing to obtain prior authorization from the Company. In any case, the Employees must comply with all the confidentiality protection rules and data protection rules for all information disclosed in relation to the Company.

XIII. COMPLIANCE WITH THE REGULATIONS AND DISCIPLINARY REGIME

Article 80.- Supervisory body

In order to guarantee that the measures set out in these Regulations will be duly followed and applied by all the Employees, as well as by Management, it is agreed that their oversight be carried out by: the Human Resources Department (hereinafter, the "Supervisor").

The functions of the Supervisor shall be limited to the control and management of the correct functioning of the Regulations, as well as to the receipt of the Employees' suggestions on possible incidents or aspects that should be regulated therein, the preparation of periodic reports on the application of the Regulations, or the preparation of proposals or recommendations for modification or expansion of the content of the Regulations. In any case, the decision on their modification or the inclusion of new aspects in the Regulations shall correspond solely to Management.

Finally, this body may act at the request of any Employee who suffers or detects any breach of any of the rights or rules set out in these Regulations, as well as on its own initiative in the event that it deems it necessary.

Article 81.- Functioning of the collegiate body

In this case, the Supervisory body established in these Regulations shall approve its decisions and act as follows:

All members of the body must be present and decisions must be approved by simple majority.

Article 82.- Sanctions for breach of the Regulations

The breach of the obligations set out in these Regulations shall give rise to the establishment of a sanction that shall depend on the seriousness of the breach and its possible consequences.

The seriousness of the breach shall be assessed by the Supervisor and/or Management, truthfully describing the facts, the evidence that justifies the facts, the provisions of the Regulations breached, and the possible consequences thereof.

In any case, this possible sanction shall conform to the provisions of these Regulations, and above all, to the provisions of the Workers' Statute, and where applicable, to the provisions of the applicable collective bargaining agreement.

Article 83.- Content of breach reports

Any report sent to the Supervisor for study must contain the following information:

• name of the person or persons submitting the report;
• description of the facts or possible situation that gives rise to a breach of the Regulations; and,
• details of the possible person in breach.

The submission of any report without the aforementioned information shall not be valid and shall be returned to the reporting party so that, within a maximum period of 15 calendar days, they may resubmit the report complying with all the above requirements.

Article 84.- Disciplinary procedure

The sanctions for the breach of any of the aspects set out in these Regulations shall be established by the Supervisor or Management following their rules of operation set out in the previous Section.

The Supervisor or Management shall conduct the corresponding investigation of the reported facts, so that the necessary testimonies and evidence can be gathered. After the collection of data, the Supervisor shall hear the parties and finally, with all the information collected and the testimonies, the Supervisor shall make the decision in accordance with the provisions of the previous Section.

In any case, this procedure shall guarantee the participation of the potential party in breach, and the possible decision adopted must be duly substantiated and proven, following in all cases the provisions of legislation and the applicable collective bargaining agreement where relevant.

Article 85.- Prevention of criminal activities

All persons subject hereto must be aware that, as a result of the current legislative framework on criminal matters, any legal entity may be convicted of crimes committed by its directors and employees when the commission thereof has resulted in some type of benefit for the legal entity in question. Zepo Intelligence rejects any benefit obtained unlawfully or as a result of the breach of any of the ethical standards and commitments contained in this Code/Regulations. Consequently, the persons subject hereto must comply with extreme rigor with the established rules and procedures.

Article 86.- Anti-corruption rules

The giving, promise, or offer of any kind of payment, commission, gift, or remuneration to any authorities, public officials, or employees or executives of public companies or bodies is prohibited, whether made directly to them or indirectly through persons or companies linked to them, and whether the recipient is the official or public employee themselves or another person indicated by them. This prohibition refers both to the authorities, officials, or public employees of Spain and of any other country. In all cases, the procedure established in the entity's Gifts Policy shall be followed, with regard to the authorization procedure in the case of gifts or invitations that are considered appropriate to commercial practice.

The giving, promise, or offer of any kind of payment, commission, gift, or remuneration to any employees, executives, or directors of other companies or entities is prohibited, whether made directly to them or indirectly through persons or companies linked to them, for the purpose of favoring Zepo Intelligence or third-party companies over their competitors by breaching their obligations in the contracting of products, services, or the purchase and sale of goods. In all cases, the procedure established in the entity's Gifts Policy shall be followed, with regard to the authorization procedure in the case of gifts or invitations that are considered appropriate to commercial practice.

Participation in public tenders and auctions shall be carried out following the participation conditions established for each case. The giving, promise, or offer of any kind of payment, commission, gift, or remuneration to any employees, executives, or directors of other companies or entities is expressly prohibited, whether made directly to them or indirectly through persons or companies linked to them, for the purpose of, in breach of their obligations, not participating in a tender or altering its price, with the aim of favoring Zepo Intelligence over its competitors.

Article 86.- Anti–money laundering rules

When establishing relationships with the following types of clients or operations, the approval of General Management shall be requested:

• Operations involving natural or legal persons domiciled in tax havens or at-risk territories.
• Operations carried out in the name of minors, persons over 70 years of age, or persons who show signs of mental disability or with evident indications of a lack of economic capacity for such acquisitions.
• Operations involving natural persons or legal entities whose owners hold or have held prominent political positions, senior posts, or the like in generally non-democratic countries, including their close family circle.
• Operations involving persons who are being prosecuted or convicted of crimes, or where it is public or notorious or there is suspicion of their alleged connection to criminal activities, provided that such activities allow for unlawful enrichment and may be considered predicate offenses of money laundering, as well as operations carried out by persons related to the foregoing (for example, through family, professional, or origin ties, where there is a coincidence of address or a coincidence of representatives or proxies, etc.).
• Operations involving natural or legal persons with an unknown address or a mere correspondence address (for example, a post office box, shared offices, professional offices, etc.), or with allegedly false or probably untrue data.
• Operations involving recently incorporated legal entities, when the amount is high in relation to their assets.
• Operations involving legal entities when there does not appear to be a relationship between the characteristics of the operation and the activity carried out by the purchasing company, or when the latter does not carry out any activity.
• Operations involving Foundations, Cultural and Recreational Associations, and, in general, non-profit entities, when the characteristics of the operation do not correspond to the objectives of the entity.
• Operations involving legal entities that, even though registered in Spain, are made up mainly of foreign citizens or non-residents of Spain.
• Cash deliveries of a value exceeding two thousand five hundred euros, or payment by negotiable instruments in which the true identity of the payer does not appear.

All of the foregoing in the prevention and application of the anti–money laundering rules.

A couple of notes on the source text:

• There are two articles numbered "Article 86" (Anti-corruption rules and Anti–money laundering rules) — the second should likely be Article 87. I kept the numbering as-is in the original.
• The phrase "renuncia a considerar tal situación como una intromisión ilegítima en el domicilio" (Art. 32) and the 50-euro gift limit (Art. 35) are worth flagging to your legal reviewer, as is the duplicated article number.

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