Internal Code of Conduct Regulations

The present Internal Code of Conduct Regulations (hereinafter, the "COC") is drafted in compliance with the regulations contained in Regulation (EU) 2020/1503 of the European Parliament and the Council of October 7, 2020 (hereinafter, the "EU Regulation") and in the newly amended Title V of Law 5/2015 on the promotion of business financing, as amended by Law 18/2022 of September 28, on the Creation and Growth of Companies.

The Code of Conduct applies to all URBIX personnel. It constitutes a basic rule of conduct that complements the existing official and legal texts, procedures, and safety instructions already in force at URBIX and on which it is based.

The Code of Conduct is a procedure that defines the principles of conduct for each employee concerning attitude and modus operandi in the daily operations of URBIX PSFP, S.L. (hereinafter “URBIX” or “the company”).

Above all, it serves as a guide and an incentive to instill a sense of responsibility in personnel and raise awareness.

The rules and recommendations of these regulations are applicable to any of the following persons:

1. All members of the Board of Directors, whether natural or legal persons, as well as the representatives of the latter, regardless of whether they are employees or provide their services without compensation.
2. Executives, employees, and proxies of URBIX.
3. Other individuals and/or entities providing services to URBIX who, at the discretion of the Control Body of the COC (hereinafter, the "Control Body"), are temporarily subject to the COC due to their involvement or knowledge of an operation related to URBIX, in which case they will sign the corresponding addendum to their service provision contract.
4. No individual or entity, regardless of their level or position, is authorized to request that a professional commit an illegal act or contravene the provisions of the Code of Conduct.
5. Likewise, no professional may justify improper, illegal conduct, or any behavior contrary to the Code of Conduct, by claiming to follow the orders of a superior.

Corporate loyalty in the context of the internal rules of conduct refers to the unwavering commitment of employees to the interests, values and objectives of the company.

This implies acting in the best interest of the company, maintaining the confidentiality of business information, avoiding any conflict of interest and promoting conduct that supports the image and reputation of the organization.

Corporate loyalty is crucial to internal cohesion, mutual trust and the long-term sustainability of the company, as it fosters a work environment based on trust, commitment and collaboration.

By fostering corporate loyalty, the company solidifies employees' emotional connection to the organization's mission and vision, aligning their actions with the company's strategic and financial objectives.

In addition, this loyalty contributes to stability and the building of strong relationships with investors, promoters, suppliers and other business partners, which drives the company's sustainable success in the equity financial market.

Honesty, in the context of a financial company's internal rules of conduct, is defined as the quality of acting with integrity, transparency and truthfulness in all actions and transactions.

This principle is fundamental because of its impact on internal and external trust and credibility, regulatory compliance, organizational culture, customer loyalty and market integrity.

Prioritizing honesty in all operations and working relationships demonstrates the company's commitment to transparency, ethics and respect for all stakeholders. The company believes that honesty is the fundamental basis on which to build strong relationships with investors, promoters, business partners, suppliers, generating a trustworthy image and establishing long-term relationships.

Moreover, honesty is crucial for maintaining financial market confidence and for compliance with rules and regulations, which is essential to avoid legal sanctions and reputational risks. By fostering an environment in which honesty is valued and rewarded, the company promotes an organizational culture based on ethical principles and integrity, which in turn strengthens team cohesion and responsible decision-making.

In short, honesty is not only an essential component of the internal code of conduct, but also serves as a pillar for building a solid reputation, maintaining lasting relationships and contributing to a stable and reliable financial market.

Impartiality, in the context of the internal rules of conduct, refers to the practice of making decisions and taking actions based solely on objective and fair criteria, without undue influence, bias or favoritism.

It is fundamental to ensuring fairness in all aspects of the company's operation, including management decision-making, resource allocation and interaction with investors, promoters, business partners, suppliers and employees.

Fairness promotes a work environment in which equal opportunity, diversity, and non-discrimination are valued and respected, contributing to the creation of a fair and harmonious work environment.

By integrating fairness into the internal code of conduct, the company is committed to ensuring that all decisions are made in a fair and equitable manner, regardless of factors such as origin, gender, sexual orientation, religion or any other personal characteristic.

This strengthens the company's integrity, increases employee confidence and fosters a corporate culture based on fairness, respect and equality.

Confidentiality within the framework of the internal rules of conduct refers to the protection and preservation of sensitive and private information of the company, its investors, promoters, business partners, suppliers and employees.

This principle involves ensuring that confidential data, such as financial information, business strategies, personal data and any other sensitive material, is kept secure and disclosed only to authorized internal or external parties.

Confidentiality promotes the trust and loyalty of investors, promoters, business partners, suppliers by demonstrating the company's commitment to privacy and information security. It also protects the company's reputation by preventing data leaks, fraud or conflicts of interest.

Effective implementation of confidentiality policies and procedures not only complies with current regulations and standards, but also strengthens the company's relationship with its investors, sponsors, business partners, suppliers and employees by ensuring the protection of their data and the integrity of confidential information at all levels of the organization.

Confidentiality is essential for credibility and business ethics, building a secure working environment and mutual trust among all those involved in the financial company.

Insider trading refers to the unlawful practice of using confidential and non-public information to gain unfair advantage in the marketplace. This misconduct involves taking advantage of inside information, which may include confidential financial data, strategic plans, upcoming mergers, pending acquisitions or other events that have not yet been publicly disclosed.

Misuse of this information to conduct financial transactions, manipulate the market or influence investment decisions constitutes a serious violation of business ethics and can result in severe legal penalties, as well as significant damage to the company's reputation and investor confidence.

It is critical that all employees of the financial firm understand the importance of protecting the confidentiality of inside information and strictly adhere to the policies and regulations established to prevent the misuse of such inside information to ensure transparency, fairness and integrity in all financial transactions.

The definition of "talent value" in a financial company's internal code of conduct is the appreciation and promotion of employees' unique capabilities, skills and individual contributions.

This involves recognizing that each employee's talent is a fundamental asset to corporate success, and that its development, training and retention are a priority. The value of talent is reflected in the creation of a work environment that fosters professional growth, diversity, inclusion and equity.

The company recognizes that a diversity of talents and perspectives enriches decision-making and innovation. It is also committed to providing opportunities for development and equitable recognition, thereby aligning the valuing of talent with long-term business strategy.

This approach reaffirms a commitment to fairness and equality, while promoting a culture of high performance and workplace wellness, which contributes to the attraction and retention of the best talent in the participatory finance industry.

Fair competition" refers to the practice of competing in the marketplace in an ethical manner, respecting the laws and regulations in force, without resorting to unfair practices such as sabotage, deception or defamation of competitors.

In a secure financial environment, fair competition is directly related to transparency in business operations, respect for intellectual property and compliance with antitrust regulations, among other aspects.

The inclusion of this definition in the internal rules of conduct reflects the company's commitment to integrity and ethics in its business activities, which in turn contributes to trust and credibility in the marketplace.

Diligence and precision in the execution of tasks and contracts refers to the responsibility and thoroughness with which employees approach their duties and commitments.

This ethical dimension requires employees to perform their tasks with meticulousness, attention to detail and professionalism, ensuring accuracy and quality in each step of the processes.

Adhering to this principle means complying with established deadlines, respecting internal and external procedures, and ensuring accuracy and reliability in all actions performed.

Diligence and accuracy are essential to safeguard the company's integrity and reputation, as well as to avoid possible errors, misunderstandings or non-compliance that could negatively affect the parties involved.

By maintaining high standards of execution in all activities, employees reflect a commitment to operational excellence and transparency, strengthening the confidence of investors, promoters, business partners and regulators in the organization. These values also contribute to efficiency and effectiveness in risk management and informed decision making, promoting an ethical and responsible work environment in the financial company.

Environmental protection in the context of the internal rules of conduct is the adoption of practices and policies that ensure that business operations and decisions are carried out in a sustainable and environmentally friendly manner.

This involves considering environmental impacts in decision making, adopting proactive measures to minimize the ecological footprint, promoting conscious consumption practices and participating in environmental conservation initiatives.

Environmental protection in the financial company goes beyond regulatory compliance, representing an active commitment to environmental responsibility and contributing to the preservation of natural resources for future generations.

This integration of environmental protection into the internal code of conduct reflects the company's conviction that environmental sustainability is an essential component of corporate responsibility and long-term value creation.

The Permanent Control Body is a body composed of a minimum of two members and a maximum of five, with appropriate professional experience and conduct for the role.

The composition of the Permanent Control Body shall include at least the following:

1. A member of the Legal Department.
2. A member of the Compliance Department.
3. The power to appoint and remove members rests with the Board of Directors of URBIX.

Any of the “Subject Persons” may contact the Conduct Channel, subject to the COC, via the email address: canal_etico@urbix.es, in order to raise any questions or request special approvals and authorizations.

The Control Body is responsible for ensuring the application and compliance with the rules established in the COC. Additionally, the Control Body will be in charge of:

1. Responding to queries raised by Subject Persons through the Conduct Channel regarding the rules contained in the COC, as well as informing about the prohibition of certain conduct and the potential sanctions resulting from non-compliance.
2. Controlling the requested authorizations, resolving queries raised through the Conduct Channel, and respecting and enforcing the information duties established in the COC.
3. Determining, at any given time, the Subject Persons to whom the COC applies.
4. Any other powers expressly attributed to it in the COC, as well as any other duties that may be necessary to reduce the risk of non-compliance.

Subject Persons must comply with the Control Body's requirements to ensure adherence to the rules established in the COC. Any action or omission intended to obstruct the functions of the Control Body will be considered a serious offense.

The Control Body will report periodically, at least annually, to the Board of Directors of URBIX on the status of compliance with the COC.

The Control Body will inform the Board of Directors of URBIX of any relevant incidents related to compliance with the COC. At least annually, the Control Body must prepare a report addressed to the Board of Directors, for their review, which contains an assessment of COC compliance, along with a description of the main incidents that occurred.

Non-compliance with the provisions of the COC will be considered a violation, the severity of which will be determined in accordance with the applicable procedure. Non-compliance by individuals subject to the COC who have an employment contract with URBIX will be treated as a labor offense. Non-compliance by individuals involved under a service or work execution contract will be considered a breach of said contract.

This will be understood without prejudice to the liability that may arise from the provisions of the regulations applicable to Crowdfunding Service Providers, and the rules that develop them, as well as the civil or criminal liability that may be imposed on the non-compliant party.

Internal Code of Conduct (COC) - URBIX PSFP, S.L. version 1.0

In case of any doubt, clarification, or interpretation, the original texts in Spanish shall always take precedence.