6.1 Relationships with customers

MAPFRE is constantly striving to improve the range and quality of its products and services, as well as to establish relationships of trust and mutual respect with its customers.

All those who work for MAPFRE must make it a priority to ensure that, in all aspects over which they have influence, customers receive attentive and conscientious treatment and service of the highest quality, characterised by efficiency, promptness and rigour in the fulfilment of the commitments acquired and the obligations arising from the contracts signed.

Excellence in service requires a constant effort to attend to and understand customers, to anticipate their needs and strive to satisfy them, offering them, with clear and truthful information, the products and services that are most beneficial and best suited to their needs.

Commercial practices that involve providing incomplete, ambiguous or misleading information or practices that by action or omission are likely to mislead the customer as to the characteristics of the products or their suitability shall be avoided. It is contrary to MAPFRE’s policy to engage in advertising activities or use marketing methods that omit information that is relevant for the customer or that, for any other reason, could be considered misleading.

Under no circumstances shall those involved in the commercial function put their own interests before those of the company and the customer.

6.2 Information for shareholders

MAPFRE S.A., a listed company and head of the MAPFRE Group, has established a Communication Policy with Shareholders, Institutional Investors and Proxy Advisors based on the following principles:

Strict compliance, in both time and form, with the legally established communication and information obligations, as well as with the recommendations of corporate governance in this matter.
Truthfulness and transparency of the information communicated.
Provision of adequate channels of communication for shareholders to exercise their right to information.

6.3 Relations with suppliers and collaborating companies

MAPFRE intends for suppliers and external collaborators, to the extent that they have a continuous and close relationship with the company, to maintain principles and policies of conduct that are similar in essence to those established in the Code, and will refuse to relate, even in an occasional manner, with those whose conduct is incompatible with said principles.

Employees and managers who participate in selection processes for suppliers and collaborating companies must:

Strictly apply the procedures and rules set out in the Procurement Rules, bearing in mind in particular that the selection and contracting of products or services must be carried out via a fair procedure and on the basis of objective technical, professional and economic criteria.
Refuse and, under no circumstances, solicit incentives, commissions, gratuities, favours or advantages and avoid any behaviour that may be considered inappropriate or unlawful.

Providers and collaborating companies may confidentially file a complaint via the Internal Reporting System of the corresponding entity if they believe that the practices of MAPFRE employees are not in conformity with the provisions of this Code.

6.4 Relationships with competitors

The company and its employees must take care not to engage in any unlawful or unfair competition conduct or any conduct that is in breach of antitrust law.

In relationships with competitor companies, any conversation, understanding or agreement relating to services, products, prices, customers or markets must be avoided, and the internal regulations on the matter and MAPFRE’s instructions must always be followed.

Within the framework of the duties of loyalty that must govern relationships with competitors, any action or commercial or advertising practice that is misleading, aggressive or denigrating of the competition and any action contrary to good faith or that, for any other reason, may be considered unfair or unlawful, is expressly prohibited.

6.5 Relations with governments and authorities

MAPFRE carries out its business activities with full respect for the regulations in force, the regulatory bodies and all the authorities of the countries in which it operates, remaining neutral with regard to the various political options.

MAPFRE does not make any kind of contribution to political campaigns, nor does it finance or donate to political parties or their representatives or candidates.

Employees who, in the exercise of their rights, participate in political activities shall always do so in a strictly personal capacity and shall prevent their activities in this field from being attributed or associated with MAPFRE.

In order to be able to determine the existence of possible incompatibilities, MAPFRE employees shall inform their immediate superiors of their acceptance of any public or political office.

6.6 Relationships with partners

MAPFRE’s relationships with its partners must be based on loyalty and integrity in their respective practices, transparency of information, a spirit of collaboration and mutual benefit.

Consequently, MAPFRE employees must act towards partners in accordance with these principles of respect, a favourable environment and teamwork.

MAPFRE will promote awareness of this code of ethics and conduct and the adoption of guidelines consistent with this code among its members.

6.7 Gifts, hospitality and courtesies

MAPFRE employees and managers may not, in their capacity as such or on the grounds of their professional activity, request or accept, either directly or indirectly, gifts, commissions, discounts, invitations or any other type of advantages or favours from suppliers, customers or any person or entity related to or that intends to be related to MAPFRE.

Without prejudice to the generality of the foregoing, courtesies or gifts of mere courtesy or of symbolic or reduced value that simultaneously meet the following requirements may be accepted:

Are not contrary to the principles of ethical conduct and transparency adopted by MAPFRE.
Do not damage MAPFRE’s image or reputation.
Are permitted both by the applicable domestic legislation and regulations of each country as well as by local customs and practices.
Do not consist of sums of money or of securities and assets that can be readily settled in cash.
Are given or received in a transparent manner and on an occasional basis, as per generally accepted commercial practice or social courtesy, or consist of objects or hospitality with a symbolic or economically irrelevant value and, in any case, less than 150 euros (or its equivalent in the corresponding currency) or the specific amount established, as the case may be, in relation to a specific country; limits applicable to periods of six months and in relation to each supplier, customer or related person or entity.

If an employee receives a gift that exceeds the maximum established amount, they must inform their immediate superior, who will decide whether the gift should be returned or, where appropriate, how it should be used.

In case of doubt as to whether it is appropriate to accept a gift or an invitation, the situation should be brought to the attention of the superior and acted upon in accordance with their instructions. If it is not possible to do so or the responsible person also has doubts, the case may be raised with the entity’s Compliance Officer.

Gifts made on behalf of MAPFRE are characterised by the fact that they are intended to promote the company’s brand image and shall be made solely and exclusively by employees expressly authorised to do so under the conditions established in the Expenditures Regulations. Therefore, and apart from the provisions of the aforementioned regulations, employees may not offer, directly or indirectly, gifts, services or any other kind of favour to customers, suppliers, partners or any other person or entity that has or may have dealings with the company.

6.8 Conflicts of interest

Conflicts of interest arise when the personal interests of employees or persons associated with them, either directly or indirectly, are contrary to or collide with the interests of MAPFRE, interfere with the proper performance of their professional duties and responsibilities or involve them personally in any transaction or economic operation of the company.

MAPFRE employees must act in a loyal manner in defence of the company’s interests and refrain from engaging in any professional or personal activity that may give rise to a conflict of interest with their work at MAPFRE. In particular, they shall not participate in or influence procedures for the procurement of products or services with companies or persons with whom they have a personal or economic connection, nor shall they give special treatment or working conditions to persons with whom they have said connection. They shall also refrain from representing the company or intervening in or influencing decision-making on matters in which, directly or indirectly, they or persons related to them have a personal interest or economic connection.

Connected persons are those who have such status by virtue of the legal provisions applicable to the relevant conflict situation. The spouse or persons in a similar sentimental relationship, the ascendants, descendants and siblings of the employee themselves and of their spouse or person in a similar sentimental relationship, the spouses of the ascendants, descendants and siblings of the employee and the companies controlled, directly or indirectly, by the employee or person connected to them, either directly or through an intermediary, or in which the employee or person connected to them holds a position of administration or management or receives emoluments of any kind, shall also be considered as connected persons.

Employees who may be affected by a conflict of interest shall, prior to any decision on the matter in question, inform the Management of their company via their immediate superior, so that the necessary measures can be taken to prevent their impartiality from being compromised. The employee must refrain from taking any action in this regard until they have received a reply to their query.

6.9 Anti-corruption, bribery

Corruption and bribery occur when employees use unethical practices to obtain some benefit or advantage for the company, for themselves or for third parties.

MAPFRE is against unethical practices aimed at inappropriately influencing people’s actions and will in order to obtain advantages or benefits. Nor does the company allow other persons or entities to use such practices with their employees. MAPFRE’s Anti-Corruption Policy establishes the basic rules and framework for preventing and detecting corrupt practices in operations related to the Group’s activities.

Employees may not directly or indirectly solicit or accept, nor may they promise, offer or give gifts, payments, invitations, commissions, compensation, favours or advantages of any kind to obtain a consideration or in an attempt to inappropriately influence their commercial or professional relationships with public or private entities, public officials, employees, managers or directors of public or private companies or bodies, organisations and political parties, politicians or candidates for public office.

In the case of courtesy gifts, the provisions of section 6.7. of this Code and the relevant internal regulations shall apply.

Employees must report to the company, via their immediate superior or the Internal Reporting System of the entity concerned, any instances of corruption or attempted corruption of which they are aware or of which they have a reasonable indication.

6.10 Transparency of information

The trust placed in MAPFRE by the various stakeholders is based on the transparent, truthful and complete information that the company provides in all areas of its activity.

All employees must ensure that the information they provide, both internally and externally, is accurate, clear and truthful, and under no circumstances shall they knowingly provide information that is incorrect, incomplete, inaccurate or that may mislead the recipient.

All information, whether financial or otherwise, disclosed to shareholders, to the markets on which MAPFRE’s shares are listed, to the regulatory bodies of said markets and to the Public Administrations, shall be truthful and complete and communicated within the deadlines and other requirements established in the applicable regulations and general principles governing the operation of the markets and good governance that the MAPFRE Group has assumed. In particular, the application for any subsidies, aid or funds from the Public Administrations shall be processed in accordance with the aforementioned principles of truthfulness and transparency with regard to compliance with the conditions required for their award and with strict application of the amounts received in this respect to the purposes or activities for which the subsidy, aid or funds have been granted.

This principle of transparency and truthfulness of information shall also apply to internal communication.

Employees who enter any type of information into MAPFRE’s computer systems must ensure that it is rigorous and reliable. In particular, all MAPFRE’s economic transactions must be clearly and accurately reflected in the corresponding registers, systems and/or files, ensuring the proper custody and conservation of the information within the periods provided for by law. Most notably, the annual accounts shall give a true and fair view of the economic, financial and equity situation of the entity to which they relate in accordance with generally accepted accounting principles and applicable international financial reporting standards and shall be available to the entity’s internal and external auditors.

6.11 Prevention of money laundering and terrorist financing

MAPFRE has established appropriate policies, procedures and internal control bodies to prevent and avoid operations related to money laundering or the financing of terrorism that all MAPFRE employees and agents are required to know and apply.

These policies and procedures establish specific controls over transactions that are complex or of an unusual nature or amount, or that have no apparent economic or lawful purpose or that present indications of fraud or deceit. These include, for example, and among many others, those made in cash or with bearer cheques, or through banks domiciled in tax havens or non-cooperative territories, by third parties unrelated to the contract or where it is not possible to identify the holders.

All employees and agents of MAPFRE Group entities bound by the regulations on the prevention of money laundering and the financing of terrorism receive specific training on the subject (with varying degrees of depth depending on the level of risk in the area of the activities they carry out), with details of how to proceed in the event that any suspicious transaction is detected.

Likewise, the manual containing the internal prevention policies and procedures established in the Group as well as the exemplary catalogues of operations that may be related to money laundering or the financing of terrorism for insurance companies and investment service companies are permanently accessible via the MAPFRE intranet.

In the event that employees or agents detect or suspect or doubt that a transaction may conceal or be used as a means of money laundering or terrorist financing, they must inform their immediate superior (employees), the director of the direct office or the director of resources (agents) or the Technical Unit for the Prevention of Money Laundering directly (in both cases), following the procedure detailed in the aforementioned internal regulations.

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