This Code of Ethical and Professional Conduct defines the values and standards that govern the activities of Estrategos, a consulting firm specializing in public affairs, in the exercise of its professional work in Spain.

Our fundamental commitment is to act with transparency, integrity, and professional excellence, promoting trust and legitimacy in public processes and ensuring the highest ethical standards in our relationships with institutions, clients, the media, and, especially, with our society.

• Internally: This code will be signed by all employees and collaborators upon joining Estrategos.
• Externally: We will comply with the transparency records required by institutions, maintaining theinformación actualizada y accesible, en línea con la normativa vigente y el respeto a las entidades públicas y sus representantes.

1. Principles of Our Activity
   • Integrity: We act with honesty and clarity in all our interactions, always identifying ourselves as representatives of specific interests and declaring the client we represent to public officials or civil servants.
   • Confidentiality: We protect our clients’ sensitive information, guaranteeing professional secrecy at all times, adopting the relevant security measures to protect this information, and ensuring control in the supply chain.
   • Regulatory compliance: We scrupulously respect all applicable laws and regulations, including regulations on lobbying, data protection, intellectual property, and other relevant areas.
   • Independence: We make business decisions by anticipating potential conflicts of interest, always maintaining maximum business transparency. We reject projects or clients that may compromise our ethical principles.
   • Diversity and inclusion: We foster an inclusive work environment, free from any type of discrimination, that values diversity of opinions and experiences as an essential part of responsible consulting.
2. Commitment to Society and Democratic Institutions
   • Contribution to public debate: We participate constructively in social dialogue, presenting our clients’ perspectives with transparency and substance.
   • Respect for institutions: We value and support democratic, legislative, and regulatory processes, always acting within the legal framework.
   • Sustainability: We integrate social and environmental considerations into our operations, promoting responsible practices.
3. Interaction with Key Stakeholders
   • Regulated access: All our meetings with public officials are conducted through official channels and established protocols.
   • Active transparency: We comply with the required stakeholder registries, providing accurate and complete information at all administrative levels (federal, state, and local).
   • Informative rigor: We base our arguments on verifiable data, rejecting any form of undue pressure or manipulation.
4. Ethical Customer Management
   • Clarity in agreements: We establish detailed contracts that specify objectives, fees, and success metrics, avoiding payments in cash or in kind.
   • Prior assessment: We conduct an ethical and legal assessment of each potential client, rejecting collaborations with entities linked to corruption and money laundering, organized crime, or human rights violations, both in Spain and abroad.
   • Periodic review: We periodically evaluate our client relationships every 6–8 months to ensure alignment with our principles.
   • Expectation management: We inform clients realistically about the possibilities and limitations of our work.
   • Professional autonomy: We maintain our independence in our advice, always prioritizing ethics and this code.

This Code of Ethical and Professional Conduct is not a symbolic document. The consulting firm’s management team is actively committed to ethics, promoting an organizational culture based on integrity and responsibility.

Compliance with this code is mandatory for all Estrategos members, and any violation will be subject to disciplinary action, without prejudice to any legal liabilities that may arise.