Code of Ethics

INTRODUCTION

This document summarizes the ethical principles on which the activity of Grupo Planeta is based. It includes a description of the behaviors that should be promoted and those that should be avoided.

The Code of Ethics constitutes the highest normative instrument in the regulatory structure of Grupo Planeta. Its principles are developed in policies, standards, and procedures. It represents the Group's commitment to complying with the laws and the ethical values they defend.

At all levels of Grupo Planeta, the real and effective application of the ethical principles will be ensured, so that this self-regulation system achieves the elimination of any act that may jeopardize the values and legal assets to be protected.

The promotion of a compliance culture should be driven not only through the Compliance function but also by the senior management of the Group and the companies that are part of it.

The Group adopts a zero-tolerance policy at all levels of its structure, considering that any level of tolerance could lead to non-compliance. At all levels of Grupo Planeta, there is an obligation to report any risk situations that may occur, either inside or outside the Group, involving the violation of laws, the Code of Ethics, or the regulations derived from it, which may cause harm to any individual or legal entity.

For this purpose, Grupo Planeta has an Office of Good Practices and an Internal Information System, managed by the Group's Ethics Committee, to which communications regarding any type of non-compliance can be directed. The Ethics Committee handles all communications sent to the Office of Good Practices and the Internal Information System, which are protected by the highest confidentiality.

The Code of Ethics must be accepted by anyone joining the organizational structure of Grupo Planeta companies as a prerequisite for their incorporation.

Suppliers must be aware of the Code of Ethics and the Anti-Corruption Policy before accepting the Group as a supplier, and must declare that they comply with the Group's General Contracting Conditions and that their organizations apply ethical and compliance principles equivalent to those applied by Grupo Planeta.

The Code of Ethics will be published on the Grupo Planeta website. It will also be translated into French and English to ensure that all members of Grupo Planeta and third parties associated with the Group can understand its scope and content.

SCOPE OF APPLICATION

This Code of Ethics applies to all Grupo Planeta companies regardless of their registered office, as well as to the subsidiaries over which the Group exercises effective control and to all levels of the company, including management bodies, executive positions, control bodies, and all employees.

CORPORATE PRINCIPLES THAT FORM THE CODE OF ETHICS

The Code of Ethics, which forms the culture of Grupo Planeta, is based on the following principles:

People

The people who make up Grupo Planeta are the decisive factor in our success. Therefore, we are committed to their continuous development, both personally and professionally, while recognizing and valuing their contribution to the company by involving them in decision-making processes.

Ethics

We base our activity on the legal frameworks of the markets in which we operate, respecting social values and acting honestly toward individuals and their surroundings.

Quality

We conceive of quality as the full satisfaction of our clients' needs, an essential premise of our products and services.

Market

We orient our products and services to fully meet the cultural, leisure, education, and information needs of our clients.

Profitability

We strive to achieve continuous profitability as a guarantee of future development and value creation for our shareholders.

Innovation

We consider innovation, in all areas, as one of the fundamental elements for our current consolidation and future growth. That is why we dedicate our greatest efforts to research and occupy a leading position in the development and research of new content, products, and services.

Strategy

We lead all the sectors in which we have proven experience and establish the most suitable strategic alliances for the development of new businesses.

Image

Our products define us as a group of prestigious brands. Our leadership vocation in content and education is based on respecting the personality and development of each of them, while we are aware of the great importance our businesses have in our environment.

Organization

We form a complex group with a service vocation, based on a participatory management style, with clear and firm structures and procedures.

These principles will be developed in the following areas:

  • Protection of labor rights
  • Protection of equality and non-discrimination
  • Protection of privacy
  • Protection of the market and consumers
  • Respect for intellectual and industrial property
  • Protection of cybersecurity
  • Compliance with tax obligations, and prevention of money laundering
  • Prevention of corruption
  • Protection of health and safety in the workplace
  • Protection of the environment, collective security, and public health
  • Protection of urban planning
  • Provision of a prevention and control model, and an internal communication system

LABOR RIGHTS

Grupo Planeta strictly complies with the labor regulations that apply to it, including the corresponding collective agreements and/or contracts. Under no circumstances will labor conditions be imposed that ignore, suppress, or restrict these rights.

The enrollment in the corresponding social security systems will be communicated for all hired workers. Under no circumstances will contract simulation techniques be applied. Regarding foreign workers, the corresponding work authorization will be requested prior to hiring. No person under the legal age established in the applicable legislation will be hired.

The company will respect the workers' right to freedom of association and the right to strike.

Furthermore, Grupo Planeta will ensure a safe and respectful work environment by establishing procedures to prevent workplace harassment or sexual harassment.

In recruitment processes, a methodology will be used that guarantees the accuracy of job offers, and no misleading or false work conditions will be offered.

Likewise, the privacy and dignity of people applying for a job will be guaranteed in the verification of references provided directly or through social media and former employers, as well as in the handling of data related to their CV.

Grupo Planeta will respect current immigration laws concerning the entry, transit, and/or residence of foreign nationals in national territory.

RIGHT TO EQUALITY AND NON-DISCRIMINATION

Employment relationships in Grupo Planeta companies are based on mutual respect and equality.

No discrimination will be tolerated against any person on the grounds of their ideology, religion or beliefs, language, ethnicity, race, or nationality, sex, sexual orientation, sexual identity, gender, aporophobia or social exclusion, family situation, illness or disability, legal or trade union representation, age, or family ties with other Grupo Planeta employees.

Grupo Planeta will provide and ensure a safe environment free from violence and discrimination by establishing specific procedures for their prevention.

RIGHT TO PRIVACY

Grupo Planeta respects and protects the privacy of individuals who provide personal or confidential information in their relationship with the company and extends this protection to employees, clients, and collaborators.

Marketing campaigns will apply measures to ensure the correct collection of data and information necessary for interested parties to understand the scope and purpose of their data processing.

Grupo Planeta's websites will have a privacy policy, a cookie policy, and any other required by current legislation, which will inform users about the scope and purpose of the processing of their data.

Grupo Planeta companies control the channels through which personal data is obtained and ensure that all necessary requirements for compliance with applicable regulations are met.

Data will be kept with appropriate security measures corresponding to its nature.

MARKET AND CONSUMERS, AND PUBLIC HEALTH

Grupo Planeta bases its market activities on the principles of free competition and equal opportunities, rejecting any actions aimed at gaining an unfair or illegitimate advantage over clients, suppliers, competitors, and other market players.

Regarding these activities, special attention will be paid to the following prohibited behaviors:

  • Accessing data or technical product information or business strategies of a competitor through a common supplier, a family member, a trusted contact, or research that goes beyond publicly available information.
  • Making false claims or promises to a client or the market about the qualities or characteristics of one's own product or a competitor's product.
  • Spreading rumors on social media, in the media, or directly to clients about a competitor, their products and services, or any other company.
  • Exploiting confidential information accessed due to one's position or work within the company to pass it to third parties, sell it, or use it to buy or sell stocks or for any other transaction or business.
  • Falsifying Grupo Planeta's financial information, especially the annual accounts.
  • Engaging in any kind of unfair act.
  • Falsifying payment methods.
  • Engaging in actions that could lead Grupo Planeta into insolvency or hiding its financial situation.

Grupo Planeta will actively cooperate with any request from the relevant public administration bodies if requested. Under no circumstances will any request be left unaddressed, always respecting the rights of the affected individuals.

Grupo Planeta will protect all confidential information, whether technical, commercial, financial, etc., maintaining its confidentiality at all times and preventing unauthorized disclosure.

INTELLECTUAL AND INDUSTRIAL PROPERTY

Grupo Planeta bases its policy for creating intangible assets on promoting creativity and innovation.

Without prior authorization, the copying or reproduction, in whole or in part, of third-party intangible assets is not permitted, nor is the transformation or modification, in whole or in part, importation, or distribution of such assets.

Assets protected by intellectual property include books, translations, videos, musical works, typefaces, advertising campaigns, slogans, brochures, catalogs, writings, speeches, presentations, reports, studies, drawings, graphics, paintings, comics, projects, plans, maps, models, architectural or engineering designs, computer programs, and any other protected work, even if the copyright symbol or rights reservation is not displayed.

All content and programs downloaded from the Internet must have the appropriate license from the intellectual property rights holder. All programs installed on company computers and mobile devices must have the corresponding usage license.

The same protection will apply to trademarks, patents, industrial designs, domain names, and other intangible assets protected by industrial property.

Trade secrets must also be respected in the same manner as intellectual or industrial property assets.

INFORMATION SECURITY

Grupo Planeta ensures the prevention and control of crimes that may be committed through the use of information technology, particularly the following actions are not permitted:

Unauthorized access to the computer systems of competitors, clients, or any other public or private companies or organizations.

Distribution of viruses or programs that may damage tangible or intangible assets.

Denial of service attacks.

Manipulation of online auctions.

Electronic fraud and any type of deception based on the use of information technology or social engineering.

Unauthorized transfer of databases.

Obtaining or transferring unauthorized personal data of a confidential nature.

Child pornography.

Any other form of computer damage, including sabotage or simple alteration of data or information contained in another computer system.

The Group has rules that regulate in detail the use of corporate technological resources by internal and external users.

TAX ORGANIZATIONS, SOCIAL SECURITY, AND MONEY LAUNDERING PREVENTION

Grupo Planeta promptly fulfills its obligations regarding tax and social security matters and anti-money laundering. The financial statements of its companies faithfully reflect their economic situation.

  • At all levels within the Group, efforts will be made to prevent any client or supplier from using the Group's structure for a money laundering operation. In this regard, the acquisition, possession, use, or transfer of goods known to have originated from criminal activity is prohibited, as well as any other act aimed at concealing or covering up the illicit origin of goods.
  • Grupo Planeta will avoid collaborating with any member or terrorist organization, for example, through the purchase, contracting, or provision of services to companies linked to terrorist organizations.
  • Any transaction or payment to an organization or company that may be related to financing terrorist activities must be reported to the relevant authorities.

Whenever possible, the use of cash for payments and collections will be limited, and, in the case of cash use, the necessary controls will be established to ensure compliance with current legislation.

TAX ORGANIZATIONS, SOCIAL SECURITY, AND MONEY LAUNDERING PREVENTION

Grupo Planeta promptly fulfills its obligations regarding tax and social security matters and anti-money laundering. The financial statements of its companies faithfully reflect their economic situation.

At all levels within the Group, efforts will be made to prevent any client or supplier from using the Group's structure for a money laundering operation. In this regard, the acquisition, possession, use, or transfer of goods known to have originated from criminal activity is prohibited, as well as any other act aimed at concealing or covering up the illicit origin of goods.

Grupo Planeta will avoid collaborating with any member or terrorist organization, for example, through the purchase, contracting, or provision of services to companies linked to terrorist organizations.

Any transaction or payment to an organization or company that may be related to financing terrorist activities must be reported to the relevant authorities.

Whenever possible, the use of cash for payments and collections will be limited, and, in the case of cash use, the necessary controls will be established to ensure compliance with current legislation.

CORRUPTION

Public and private corruption, both domestic and international

Grupo Planeta bases its relationships with both the public and private sectors, at both the national and international levels, on the principles of transparency and equal opportunities. It rejects any action aimed at gaining an advantage over competitors, in the market or in public or private contracts, based on illicit conduct.

Consequently, it is not permitted to offer public officials or private company executives money, gifts, or any other economic or patrimonial benefit in order to obtain any type of advantage for the company.

Conflict of interest

All employees must communicate any conflict of interest they may be in, which is understood as a situation where a business action or decision may be influenced by the personal interest of the individuals involved or any third parties they are personally connected with. At all levels of Grupo Planeta, there is a duty to avoid situations of conflict of interest.

Illegal political party financing

Grupo Planeta does not allow any action that could lead to the illegal financing of political parties. In this regard, it may engage with political parties within the framework of the legal regulations of the countries in which it operates, and in compliance with national laws on political party financing.

WORKPLACE SAFETY

All work carried out in Grupo Planeta's companies must comply with the safety conditions required by the applicable occupational health and safety regulations.

The Group has established the safety measures required by law, and all employees are obligated to respect them.

ENVIRONMENT, PUBLIC SAFETY, AND PUBLIC HEALTH

The companies of Grupo Planeta, directly or indirectly through their suppliers, will develop their activities while always considering the respect for the natural environment, minimal resource consumption, and control of environmental impact, especially regarding discharges, emissions, noise, vibrations, waste, ozone-depleting gases, and any other environmental threat.

Grupo Planeta will establish controls regarding discharges, emissions, noise, vibrations, waste, ozone-depleting gases, and any other environmental threat.

Controls will also be established for any activity or product that may create, directly or indirectly, a risk to public safety and public health due to the toxicity of its components or any other threat to individuals.

At all levels of Grupo Planeta, efforts will be made for rational use of resources, respect for the environment, and sustainability.

URBAN PLANNING

Grupo Planeta bases the management of its properties, real estate transactions, and construction, development, and urbanization initiatives on respecting urban planning and the regulations set by the various authorities governing them.

Grupo Planeta will not carry out unauthorized urban development, construction, or development on land designated for roads, green areas, public domain goods, or areas legally or administratively recognized for their landscape, ecological, artistic, historical, or cultural value, or for any other reason have been considered under special protection.

Grupo Planeta will not promote land requalification or modification of planning instruments, urban development projects, subdivision, rezoning, construction, or issuance of licenses contrary to current land use or urban planning regulations. It will also not illegally obtain urban planning permits, activity licenses, or building permits.

PREVENTION AND CONTROL MODEL

Grupo Planeta has a Prevention and Control Model designed to avoid criminal activities in all its companies. This model is developed in the Prevention and Control Policy, which includes a description of the key human, organizational, and documentary elements applied by the companies to prevent legal violations, especially acts that may be classified as crimes under the Criminal Code or similar regulations.

At all levels of Grupo Planeta, real and effective application of the prevention and control measures outlined in this policy will be ensured, so that this self-regulation system can eliminate behaviors that may jeopardize the organization’s reputation and its material and intangible assets.

This policy will be updated to adapt to jurisprudential trends and legal changes regarding the prevention and control requirements.

INTERNAL INFORMATION SYSTEM

Violating the Code of Ethics can risk the reputation of Grupo Planeta and hinder its activities.

At all levels of the organization, there is an obligation to report any risk situations that may arise inside or outside the Group related to violations of the law, the Code of Ethics, or the regulations that develop it.

Grupo Planeta provides its employees with the Good Practices Office, the Internal Information System, and the Confidential Mailbox to channel inquiries about interpreting the Code of Ethics, as well as to report any violations or bad practices known, ensuring confidentiality of the communications.

The Good Practices Office also has a Confidential Mailbox to report cases of workplace and/or sexual harassment or discrimination based on gender.

The investigation procedure for suspected violations will be confidential, without prejudice to reporting to the competent authorities, if necessary. Protection will also be provided to whistleblowers against retaliation for submitting internal complaints.

Violating the law, the Code of Ethics, or the regulations that develop it will be considered an infraction, with its severity and sanction carried out in accordance with current legislation.

The disciplinary procedure will be initiated based on a complaint, communication, investigation, or knowledge of the alleged violation by the Ethics Committee.

UPDATING AND IMPROVEMENT

This Code of Ethics will be updated periodically to include improvements deemed appropriate to define the ideal conduct to be developed in Grupo Planeta.

The Ethics Committee will continuously monitor the application of the Code of Ethics and the Prevention and Control Model, and propose necessary modifications in the following circumstances:

  1. When significant violations of the Code of Ethics or the regulatory framework that develops it come to light.
  2. When significant changes occur in Grupo Planeta, in its control structure, or in the activities it develops.
  3. When relevant legal or jurisprudential modifications suggest such modifications.