To our stakeholders:

I am pleased to confirm that AEORUM reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Jesus Garcia Merino.
CEO AEORUM.

AEORUM ethical principles and values are set out as a standard of ethical conduct. The company Code of Conduct helps all employees to understand and uphold to the company principles. This code is the reflection of our enhanced commitment to making a positive impact on society, at the same time that ensures we work with integrity while delivering real results to clients.
Human rights are basic rights aimed at securing dignity and equality for all, regardless of a person’s race, religion, gender, age, or language. Respecting people and their human rights are a fundamental part of responsible business practices. At AEORUM, we believe that corporate responsibility means conducting business with the highest level of professionalism. Integrity, diversity and inclusion, environmental sustainability and corporate citizenship are key drivers to success, so these areas are fully aligned with our values and culture, integrated into our business strategy.
We are committed to respecting and protecting human rights in all business practices. We recognise our responsibility to help ensure fair business practices in our overall value chain and direct and indirect supply chain. AEORUM believes that respect for human rights is a basic responsibility; both towards our own employees, as well as towards those people who are affected indirectly through our action. Our approach is to uphold and promote human rights in three ways:
- In our operations by upholding our values and standards.
- In our relationships with our suppliers and other business partners.
- By working through external initiatives, such as the UN Global Compact.
AEORUM recognises that human rights are an integral part of corporate citizenship and we respect and support the Universal Declaration of Human Rights and the Guiding Principles on Business and Human Rights: Implementing the United Nations’ “Protect, Respect and Remedy Framework”. AEORUM activity is in-line with UN’s Guiding Principles and Human Rights. The company has a strong commitment to respecting human rights and our support for the UN Global Compact. The policies and procedures implemented in AEORUM are consistent with the UN Declaration of Human Rights, the Guiding Principles and the International Labour Organization.

In following the Guiding Principles, AEORUM:
 Undertakes to avoid causing or contributing to adverse human rights impacts through their own activities, and address such impacts when they occur.
 Seeks to prevent and mitigate human rights impacts that are directly related to their operations, products or services through its business relationships.
 Follows high standards of ethical conduct.
 Works with clients, suppliers and subcontractors that live up to AEORUM’s core ethical standards.
 Acts lawfully, ethically, and in the public interest.
 Champions an inclusive and collaborative culture that is free from bullying, discrimination and harassment, where everyone is treated with respect and dignity.
All the actions undertaken by AEORUM share asset of values that define how we work with our clients, in our community and with our employees. The values established by the company are our core beliefs, aiming to guide and unify our actions and behaviours.
Respect for the individuals: we respect people for who they are and for their knowledge, skills and experience as individuals, as well as team members.
Seek trust: we seek the facts and provide insight, in a way of strengthening the company reputation.
Open and honest communication.
Lead by example: we act in a way that exemplifies what we expect of each other at all levels.
Working together: we always try to bring out the best in each other and create strong and successful working relationships.
Act with integrity: we are constantly striving to uphold the highest professional standards.
AEORUM will refrain from doing business with stakeholders who have consistently demonstrated to violate the human rights and labour standards and do not provide any commitment to improve. AEORUM will not engage in direct business activities with countries that are responsible for violations of international human rights, including torture, genocide, crimes against humanity or war crimes.
All AEORUM employees must:
 Respect the dignity and human rights of colleagues and all others they come into contact with as part of their jobs.
 Treat everyone fairly and equally, without discrimination on the grounds of race, age, role, gender, gender identity, colour, religion, country of origin, sexual orientation, marital status, dependants, disability, social class or political views. This includes consideration for recruitment, redundancy, promotion, reward and benefits, training or retirement which must be based on merit.

AEORUM carries out a periodic review of results by senior management.

AEORUM is committed to respecting labour rights in all of its activities. AEORUM process ensure that forced and compulsory labour are not present in our value chain. AEORUM supports freedom of association and recognises the right to collective bargaining. AEORUM holds zero tolerance for all forms of gender discrimination, including verbal, physical and sexual harassment. AEORUM ensures child labour is effectively abolished.

AEORUM ensures that all employees’ work is conducted on the basis of freely agreed and documented terms of employment, clearly understood by and made available to relevant employees and others working for the company.
AEORUM respects employees’ rights to join or not to join a legally recognised trade union, or any other body representing their collective interests, and establish constructive dialogue and bargain in good faith with trade unions or representative bodies on employment conditions, labour management relations and matters of AEORUM Code of Conduct VIII advocates for equality and no discrimination. AEORUM encourages and respects individuals. Our drive to create a global culture of inclusion and diversity is fundamental to who we are, and critical to retaining our best employees. The company’s core value is to empower its employees to be themselves and respect others. We believe in a future where everyone feels included as a better future for all.
AEORUM fosters diversity and inclusiveness for everyone. We believe diversity is critical to our ability to succeed and achieve sustainable success. AEORUM is committed to creating a stimulating work environment for people from all backgrounds and an environment that is open to different ways of thinking. Fully engaged teams are both inclusive and diverse where everyone is free to contribute equally. Thus, a core component of our strategy is the development of inclusive leaders that proactively champion inclusion and build diverse teams who respect and support each other:
 Build teams that are balanced and well-rounded, reflecting all aspects of diversity: thought, skills, appearance and background. Mixed gender teams tend to be more successful because they consider different experiences and perspectives and, in the end, have a positive effect on the company success.
 Lead and support the business and moral imperative of inclusion and diversity by collaborating with likeminded diverse and purpose-led stakeholders.
 Work collaboratively with clients and other stakeholders to improve the inclusiveness of our workplace.
We continue to take steps to increase diversity throughout the company in our recruitment processes. We will recruit, employ and promote employees on the sole basis of the qualifications and abilities needed for the work to be performed. This way, we enrich the diversity of our teams, increase our own understanding of diverse markets and create new opportunities with our clients, stakeholders, media, regulators and civil society as a whole.
AEORUM maintains a clear and transparent system of employee and management communication that enables employees to consult and have an effective dialogue with management. The company provides transparent, fair and confidential procedures for employees to raise relevant concerns. These must enable employees to discuss any situation where they believe they have been discriminated against or treated unfairly or without respect or dignity, with their line manager – or an independent manager – without fear of retaliation.
mutual concern, to the extent practicable taking national laws into consideration.
AEORUM respects its employees and aims to be a good employer. We offer a healthy and safe workplace, where discrimination and unfair treatment are not tolerated. AEORUM complies with all applicable legislation and regulations and aims to continuously improve health and safety performance.

AEORUM carries out a periodic review of results by its board of Directors, including the specific progress made in the area of Labour during the last reporting period.

AEORUM recognises our corporate responsibility to respect the environment, protect biodiversity, and take action to mitigate climate change.

Our approach towards the environment, including biodiversity and climate change is an integral part of our commitment to take into account sustainability criteria in every aspect of our business. During the last year, we have integrated sustainability into the way we run our business. The company has managed to integrate several internationally recognised management systems in terms of quality (UNE-EN ISO 9001), environment (UNE-EN ISO 14001) and information security management (UNE-ISO/IEC 27001).
ISO 14001 has helped AEORUM to manage its environmental impact proactively. In 2020, the company has a global ambition to reduce our net greenhouse gas emissions by 20 percent per full-time equivalent by 2017. We also seek to have the majority of our purchased electricity to come from renewable sources by 2020. We aim to be carbon neutral in terms of direct emissions from our own operations. Some of the measures implemented include: reducing our carbon footprint, reducing waste, using responsibly-sourced paper, and further increasing our energy efficiency.
In coming years, AEORUM expects the following:
 Managing operations and supply chain impacts on biodiversity.
 Reducing net greenhouse gas emissions.
 Avoiding pollution to air, ground water and land resulting from the company’s operations.
 Avoiding operations in locations where the consequences of accidents cannot be responsible managed.
 Managing and processing waste in a responsible manger (recycle and reuse).
 Environmental impact assessment and taking appropriate measures to manage environmental impacts, including policies, management systems, and supply chain and procurement criteria.
AEORUM employees receive training on environmental risks, developments and sustainability framework.
Environmental aspects are considered in our client and supplier assessment and risk management processes. This helps to ensure well informed decision-making and that our client interactions do not the environment.

AEORUM carries out external audits of environmental performance (ISO 14001 yearly audits).

AEORUM Code of Conduct is designed to ensure the company upholds the highest standards of professional integrity. AEORUM’s position is that bribery and corruption are unethical and unacceptable, and are inconsistent with our values, thus the company works against corruption in all forms. We do not accept nor tolerate any instance of bribery, corruption or fraud.

In relation to anti-bribery and corruption, the Code of Conduct commits all AEORUM employees to:
Act lawfully, ethically and in the public interest.
Prohibit bribery and corruption.
Not tolerate illegal or unethical behaviour by clients, suppliers or by public officials.
Follow high standards of ethical conduct around the world, including aspiring to the ten principles of the UN Global Compact (including anti-bribery).
AEORUM commitment to doing business with integrity requires consistently high global standards. Dealing with public officials are particularly high risk: even the appearance of illegal conduct could cause significant damage to AEORUM’s reputation. Any contact by employees or other representatives with government, legislators or regulators must be done with honesty, integrity, openness and in compliance with local and international laws. This is why all AEORUM employees receive training on anti-bribery and corruption. This Compliance & Integrity training is obligatory for all new employees when they join AEORUM. Employees must:
 Always make clear, internally and when dealing with third parties, that AEORUM has zero tolerance approach to bribery and corruption and will not (directly or indirectly) offer, pay, seek or accept a payment, gift or favour to improperly influence a business outcome.
 Immediate notify the Direction of the company if they become aware of any suggested or actual payment or other transaction which has the potential to be in breach of AEORUM Code of Conduct.
 Ensure that before employing or entering into contracts with any third parties to represent AEORUM or its interests externally, they have undertaken appropriate due diligence checks to assess the third party’s integrity. The outcome of such checks must be considered carefully before deciding whether to appoint the third party.
 Ensure gifts and hospitality are never considered to be excessive, confer improper advantage or create an actual or perceived conflict of interest. All gifts by employees that take the form of AEORUM branded merchandising materials must be legitimate and proportionate.
 Ensure that any contributions towards, and support for, political parties are clearly personal and give no impression of being connected to AEORUM.
 Ensure that any personal political support or contributions do not affect their performance or objectivity at work.
AEORUM employees must not, directly or indirectly (e.g. via suppliers, agents, distributors, consultants, lawyers, intermediaries or anyone else):
 Offer or give bribes or improper advantages (including facilitation payments) to any public official or other individual or third party, which are, or give the impression that they are, intended to influence decisions by any person about AEORUM.
 Request or receive bribes or improper advantages from any third party, which may, or give the impression that they may be, intended to influence decisions by AEORUM about that third party.
 Offer or accept any gifts or hospitality, or any other favours which are intended or might be seen to influence business decisions or create an obligation to do something in return.
 Offer or accept any gifts that are in cash or a cash equivalent, such as lottery tickets, gift certificates, vouchers, loans, guarantees or any other granting of credit, shares or options.

AEORUM carries out internal audits to ensure consistency with anti-corruption commitment, including periodic review by senior management.