At MEDIA INTERACTIVA, we pride ourselves on working for a better future for people. In our company, our values inspire our activity. Integrity, corporate responsibility, and full compliance with all laws have always guided our actions and play a key part in the foundation of our organization and the pillars of its reputation.
Acting according to these values represents a key commitment within the Organization to our customers, business partners, and society, and it illustrates the basis on which this company wants to continue growing.
We present you this Code approved by our Governing Body that, together with the Manifesto of Values and Organizational Culture in Human Resources Management, establishes the patterns that we must follow to adjust our behavior to the values of the Organization and to the law.
This Code is a direct reflection of the strong commitment that guides the MEDIA INTERACTIVA Group in creating and fostering a culture of compliance that extends to all its areas. All of us behave in an upright and professional manner, in compliance with applicable laws and regulations. This Code is the reference framework that should be present in the daily development of our functions.
If you have any question regarding this Compliance framework, feel free to contact our Compliance Committee at firstname.lastname@example.org.
1 What are our values?
Commitment to education as an essential value of MEDIA INTERACTIVA.
The main purpose of MEDIA INTERACTIVA SOLUTIONS S.L., and the Group of companies of which it forms part (hereinafter, “MEDIA INTERACTIVA“, the “Organization”, or the “Company”), is to contribute to the world of educational technology: “Theory and practice of the design, development, use, administration, and evaluation of processes and resources for learning”.
Access to the so-called society of knowledge requires profound transformations from schools, which must be able to provide quality compulsory education to all children everywhere on the planet. The risks of social exclusion are increasing for those left behind from new technologies. Schools must take charge of using and teaching these technologies.
Being involved in global projects is rewarding, but it can also be somewhat dizzying. Despite being a great responsibility, it is a great satisfaction for us to be the ones that carry out the creation of exams, certifications, and educational material that allow millions of people from all cultures to obtain new knowledge or validate the knowledge that they already possess. The feeling that a minuscule part of that personal success is thanks to MEDIA INTERACTIVA is something that fills us with pride.
At MEDIA INTERACTIVA, we want to join the new challenge in the world of education, backing e-learning. This requires opening up to new alternatives by expanding the ideological and pedagogical vision for a reform in education.
At MEDIA INTERACTIVA, we believe in technology as a method of learning and evaluation, which is why, for more than 15 years, we have been contributing to education with the highest quality services and solutions that incorporate the most advanced technologies on the market.
This commitment that MEDIA INTERACTIVA takes with the continuous improvement of the world of education is achieved by the assumption of the essential values that direct the effective development of our daily activity:
IMPROVEMENT AND INNOVATION: The ability to modify things based on unplanned situations, which involves coming up with new and different solutions to solve problems, applying creativity to implement actions that are advantageous in any process.
COMMITMENT: The idea of feeling common goals as one own’s, preventing and overcoming obstacles that interfere with the achievement of such goals and cultivating team culture to respond efficiently as a single, organized entity.
COLLABORATION AND PEOPLE DEVELOPMENT: Helping people grow intellectually and morally, focusing our efforts on providing growth opportunities to our employees, business partners, and the communities in which we develop our operations.
INTEGRITY: : Acting with honesty and integrity in line with what is deemed right involves communicating intentions, ideas, and feelings openly and directly. As part of this value, all MEDIA INTERACTIVA Members must act honestly in the performance of their duties, including in difficult negotiations with external agents.
2 Who does this Code affect?
This Code of Ethics is the reference framework for our activity and interaction. It is applicable to our entire corporate structure, from the Management Body, through each of the Group’s companies to each individual employee. In addition, we ensure that third parties related to MEDIA INTERACTIVA (suppliers, distributors, and business partners) also comply with it.
As a member of MEDIA INTERACTIVA, it is your personal responsibility and obligation to:
Know this Code and act in accordance with it, as well as in accordance with the provisions of the policies and procedures that develop and complement it.
Ask in case of doubt. Although this Code contains many operational guidelines, situations may arise that create doubts. If you don’t know how to proceed in such cases, you should consult with your superiors or the compliance supervisory body before taking any action.
Do not tolerate behavior contrary to this Code, nor actions that may affect the reputation of a member of the Organization or of MEDIA INTERACTIVA itself.
Communicate whenever you have the suspicion that an action that may be contrary to the internal regulations of the company, this Code, or the Law is either occurring or has occurred. Use the channels enabled for this purpose or inform your line manager or the human resources department.
The Code will always be accessible to the members of MEDIA INTERACTIVA, and any modifications to it will be communicated to all recipients through the established channels.
3 How should I behave with my colleagues?
3.1. Create a good working environment
All MEDIA INTERACTIVA members count and need to participate in the activities of the Company in an orderly and structured way, without prioritizing individual interests of one member over those of another.
Our working system must promote the social-labor relations in our shared workplace, given that the tasks performed by each of us are always part of a total project that is the result of teamwork.
Our day-to-day life should be governed by the premise that our behavior with other MEDIA INTERACTIVA members should be identical to that you would expect to receive.
Listen to all opinions and keep your team and everyone who must participate in the process duly informed, providing the information needed to make an informed decision in time.
The integration of new people into the Company is important. Try to welcome new employees in a way that helps their skills and personality merge into the business culture and values of MEDIA INTERACTIVA.
In case you have other teams or company members who depend on you, provide instructions in a clear and respectful way, taking into account the contributions of every member, promoting the particular skills of each person to contribute to their training and development, and distributing the workload fairly and accordingly.
3.2. You must not tolerate harassment or discrimination
Having an adequate working climate is essential for each member of the Organization to perform their duties correctly and in a satisfactory environment.
Zero tolerance to harassment: Sexual, professional, personal
Respect and demand respect in your working relationships.
Avoid any hostile, intimidating, or offensive behavior or attitude.
Do not discriminate or tolerate discriminatory attitudes based on race, religion, sexual orientation, language, family origin, political ideology, disability, gender, or any other reason that is not objectively related to working conditions.
Communicate any situation that you consider may constitute harassment or discrimination, acting responsibly, whether the action is carried out by a colleague or by a third party related to the Organization.
For MEDIA INTERACTIVA, the principle of non-discrimination is based on recognizing the importance of promoting equal social relations, prohibiting any unfair, disproportionate, or arbitrary difference involving the stereotypical acceptance of designated social roles to men or women, denying them a right or benefit, imposing a burden, infringing on their dignity, or socially marginalizing them.
3.3. Objectivity in selection and evaluation criteria
It is essential that you act objectively in the selection and evaluation processes that affect other members or potential members of the company, assessing the candidate’s ability, merit, and professional qualifications. Do not let other subjective factors influence your decisions.
Hire people with the personality and professional skills that allow them to develop a long-term relationship with the company. This is the reason why the potential for professional development will be an essential criterion at the time of hiring.
The importance of the values of the MEDIA INTERACTIVA Group. Special attention will be paid to the adequacy between a candidate’s qualities and the values of the company. These principles and values are clearly communicated from the beginning of the recruitment process.
3.4. Promote safety in your work environment
Comply with reliability, hygiene, and safety standards, and take care of your own safety, as well as that of your colleagues.
Ensure that occupational risk prevention standards are respected by all members of the Organization, communicating any circumstances that you believe puts your own or third-party health or safety at risk.
Under no circumstances is it permitted to come to work under the influence of alcohol or psychotropic substances. If you, due to medical prescription, need to take some kind of medication with effects that affect normal performance or behavior, consume responsibly and avoid risks for you and others.
4. How should I behave with the company?
4.1. Processing of data and information
All information about customers, employees, or any third party that you become aware of due to your position within the company is confidential. It is your responsibility to take the necessary measures to keep it confidential in compliance with the procedures established by MEDIA INTERACTIVA.
Even in the even that your relationship with MEDIA INTERACTIVA ends, keep all information you have learned on account of your job confidential: financial information, projects, programs, and any other information of a strictly professional nature.
4.2. Using MEDIA INTERACTIVA resources
Use in an appropriate and efficient way the resources that MEDIA INTERACTIVA makes available to you, dedicating them exclusively to the development of your functions. You must return the material made available to you when your relationship with the company ends.
Regarding technological means (computers, e-mail etc.):
Remember that MEDIA INTERACTIVA will be able to access, monitor, and review your activity with these tools, as well as the information you store on them.
They are not your property. But treat them like they were.
Use them in a way appropriate to their nature and professional purposes. Do not use them for personal purposes.
You are responsible for keeping and not transferring user and password data to access them to third parties.
Likewise, you are not allowed to install any application or software on the company’s computers without the prior authorization of the Organization.
4.3. Intellectual and industrial property
All company information, (economic information, projects, ideas, programs, processes etc.) belong to MEDIA INTERACTIVA and should only be used for the professional purposes of MEDIA INTERACTIVA.
Use the logo, the MEDIA INTERACTIVA brand and its corporate identity only in the proper development of your professional activity within the Organization according to established standards.
Maintain the utmost confidentiality of this information and take the necessary measures to prevent anyone from accessing, obtaining, or disseminating this information.
The work carried out and the products generated that are delivered to MEDIA INTERACTIVA must be original. They must not have been previously published in whole or in part, or violate any law. They must have not been previously assigned any license or otherwise been taxed.
Respect the intellectual and industrial property of third-party products and services. Do not use any third party patent, copyright, trademark, or registered trade name.
In the event that a product or products contain information or materials to which a third party is entitled, whether by patent, copyright, trade or other secrets, the worker must obtain, at no cost to MEDIA INTERACTIVA, written permission to include such materials in the course of their work.
This written permission must be consistent with all rights granted to MEDIA INTERACTIVA.
Do not use images that belong to third parties. If you want to make use of images, there are free websites that contain royalty-free images that can be used for all kinds of purposes.
Do not disclose any trade secrets or other confidential information of any third party you know due to your position.
4.4. Responsible management of company funds
Use or authorize MEDIA INTERACTIVA funds following relevant approvals and in reasonable amounts. In any event, make sure that the expenditure is appropriate and proportionate to the circumstances and standards set by the Organization in its policies.
4.5. Conflicts of interest
There is a conflict of interest when a situation of a personal, family, friendship, or similar nature or can influence your objectivity when making decisions or hiring.
Communication: If you find yourself in a situation of conflict of interest, or believe that it may be perceived as a conflict, please communicate it properly to resolve your doubts and apply the internal regulations.
Abstention: Refrain from participating in decision-making processing on matters affected by a conflict of interest.
4.6. Anti-corruption policy and gift reception
Refrain from participating in situations, activities, or interests that are incompatible with your duties, and from intervening in matters where there is a cause that may affect your objectivity.
Refrain from using your membership of the Organization with third parties to obtain personal or material advantages.
In the exercise of your duties, do not request or accept payments, gifts, commissions, or personal benefits from customers, suppliers, officials, business partners, or partners of MEDIA INTERACTIVA, be current or potential.
Never accept a gift to influence your or the Company’s decisions.
Never accept money or gift cards regardless of their amount.
Gifts given to family members on your instructions are subject to the same conditions as if they were given to you.
Promotional gifts, courtesy details, or usual business offerings may be accepted as an exception, provided that:
- You have not requested them.
- They are proportionate to social circumstances and uses, taking as reference the fact that you can communicate it openly without it being deemed inappropriate and without it causing you shame.
How to act upon reception of a gift? Answer yourself.
Is this a sincere gift for my performance in the scope of my duties?
Do I feel committed to any consideration for accepting the gift?
If I accept the gift, can my independence be affected in the future? And in relation to the person who gave me the gift?
Would I make the existence of the gift public to my colleagues, third parties or clients?
4.7. Social Networks
Do not make any statements publicly or through social networks on behalf of MEDIA INTERACTIVA without having been expressly authorized to do so. Any personal publication must always respect the rules of data protection and confidentiality. Before publishing photographs or data related to the organization or its facilities, you must seek permission.
Comply with the ongoing training required of your job. Innovation is a fundamental pillar in MEDIA INTERACTIVA, and the Company requires a commitment on your part to continuously improve, to help the company position itself in the market and meet customer expectations.
5. How should I behave with customers?
5.1. Respectful assistance
Always address the customer in a respectful and professional way.
Do not discriminate any person on the basis of gender, race, age, nationality, religion, sexual orientation, disability, family origin, language, political ideology, political or trade union affiliation, or economic or social situation.
Value customer reviews. Resolve your communications and complaints diligently and as soon as possible or, where relevant, contact the appropriate person.
5.2. Truthful information
Provide clear and truthful information. Do not offer or advertise MEDIA INTERACTIVA products and services that are false, misrepresented, opaque, or that omit a part of the information.
Value the real needs of customers to offer them the products or services of MEDIA INTERACTIVA that best suit their characteristics and needs.
You must provide equal treatment to all customers in their rights to access the products and Services of MEDIA INTERACTIVA, avoiding any treatment of favor, or any situation resulting in a conflict of interest.
The activity of MEDIA INTERACTIVA towards its customers must be aimed at build lasting relationships. To do this, you must comply with the contractual commitments that have been agreed.
6 How should I behave with third parties?
6.1. In relation to suppliers and partners
MEDIA INTERACTIVA suppliers and partners must be selected according to the following criteria:
Merit and professionalism: comparing the different offers from the participants and choosing the one that best suits the interests and needs of the Organization.
Equal treatment: refraining from participating in the selection process in case of a conflict of interest, and in no case accepting gifts in exchange for selection.
Culture of compliance: monitoring and ensuring that the values of the supplier or partner are aligned with those of MEDIA INTERACTIVA.
6.2. Relationships with public administrations
Relations with authorities and officials shall be governed by the following criteria:
Honesty: be sure to convey truthful and complete information when applying for a grant.
Commitment: if you obtain a benefit or grant from a public administration fulfill the destination for which it was granted.
Legality: respect procedures and free concurrency. Succeeding in such procedures must always come from lawful, legal, and transparent action. Never make payments to get a favorable resolution or the facilitation or expedition of payments.
Security: be sure to record your legal and diligent actions, striving for communication with officials to be in writing and verified by a colleague, by either copying them in your correspondence or having them witness your conversations.
7. How should I behave in society?
7.1. Rigorous compliance with current regulations
Without exception, all workers who make up the MEDIA INTERACTIVA team commit themselves to conduct their activities in accordance with the legality in force in the jurisdiction where their activity takes place.
Acting in compliance with the rules is crucial to maintain the trust and credibility of our customers, employees, and the community in which we act. Therefore, employees must adhere to the rules established by the company, avoiding any conduct or actions that may lead to the violation of the law or that, although lawful, may compromise the respect for the principle of legality or that are not ethically acceptable under the strict criteria of the company.
7.2. Compliance with tax obligations
Avoid any practices that involve the unlawful avoidance of tax payments.
Carry out your professional activity with transparency and following the procedures of the Company so that MEDIA INTERACTIVA can adequately comply with its tax obligations and public social protection systems.
7.3. Political neutrality
Relations with the Administration, Public Institutions and Political Parties should always be conducted in accordance with the principles of political neutral professionalism and respect for political pluralism.
The political neutrality of the organization will not constitute an obstacle to the personal exercise of your ideological freedom, expression, thought, or association, provided that you do not act on behalf of MEDIA INTERACTIVA, or associate the Organization with a certain ideology or political party, or use its funds in doing so.
8. Communication and report
In order to promote and favor a climate of compliance, an Internal Communication Channel has been established in the company to serve as a nexus between the members of MEDIA INTERACTIVA and the body responsible for overseeing compliance with this Code.
You should use this Communication Channel to communicate:
Any doubts regarding the correct application of this Code of Ethics.
Any conduct that may be considered unlawful, unprofessional, or inappropriate, and therefore contrary to this Code or Company policies.
Make a responsible and appropriate use of the reporting channel. Its use will always be in good faith and will never be used to cause harm to any member of MEDIA INTERACTIVA or third parties.
All received communications and inquiries will be treated in total confidentiality. MEDIA INTERACTIVA prohibits and will not tolerate retaliation or threat of retaliation against an employee who reports in good faith a possible violation of the internal laws, regulations, policies, or procedures of the Organization.
9. In short, what are my obligations as a member of MEDIA INTERACTIVA?
Know and apply these behavior guidelines. Get familiar with the content of this document and the established behavioral procedures or protocols, and apply them in your day-to-day life within MEDIA INTERACTIVA.
Reject any conduct that may be contrary to this Code of Ethics or the internal policies of the company, and if you are aware of any, please inform us through the channels provided.
Consult in case of doubt on any issues that relate to the application of this Code of Ethics or its development policies whenever you deem it appropriate.