Social responsibility makes it possible to reconcile the company’s social interest with the legitimate interests of the various stakeholders that may be affected, and also to assume the impact of Gabitel’s activities on the community and the environment.

This Corporate Social Responsibility Policy (hereinafter, “CSR Policy”) aims to establish a reference framework from which Gabitel can develop and promote socially responsible behavior, regardless of the country in which it operates, adapting the actions necessary for compliance locally.

OBJECTIVES

GABITEL defines its social responsibility as “a voluntary and strategic commitment that involves striving to achieve its business objectives, strictly complying with its contractual and legal obligations, applying criteria of equity and stability in relations with its stakeholders, thus contributing to the satisfaction of present and future societal needs”.

Promoting CSR in GABITEL, has to be perceived as a means:

• To achieve the social interest of GABITEL and its strategic objectives.
• Manage the company from the values defined by GABITEL: solvency, integrity, vocation for service, innovation for leadership and team commitment, which must be present in any business project.
• Establish stable and equitable relationships with its stakeholders, mainly employees, suppliers, customers and society.
• Manage the risks and business opportunities derived from the evolution of the environment in which GABITEL carries out its commercial activity, assuming the impact it generates on society and the environment, maximising the positive ones and minimising the negative ones.
• To convey the social value of the company, in each territory, which reconciles the value of its operating activity with the value of the non-profit activities carried out.

For all these reasons, and in order to adequately develop these objectives, the following general and specific action principles are established:

GENERAL PRINCIPLES OF ACTION

1. Fulfillment of International Commitments related to Social Responsibility:

Gabitel adheres to the UN Global Compact: to promote social dialogue for the creation of a global corporate citizenship, which allows the conciliation of the interests of companies, with the values and demands of civil society, UN projects, the approaches of trade unions and non-governmental organizations.

2. Compliance with national and international laws and regulations in force in the countries in which Gabitel operates.

3. Maintenance of corporate governance practices based on ethics, corporate transparency and diversity; respecting the rules of free market and free competition, and rejecting any illegal or fraudulent practices, contrary to the rules of good governance, GABITEL corporate rules and policies and the guidelines of the Code of Ethics and Conduct, to obtain business advantage. GABITEL has internal mechanisms for prevention, monitoring, reporting and sanction of any practice described in the preceding paragraph that may occur.

4. Communication and dialogue with all stakeholders, based on transparency, truthfulness and commitment, as fundamental axes for building stable relationships that generate trust. GABITEL needs the involvement of its stakeholders in order to achieve its business and social objectives, and for this reason it has established specific channels of communication and dialogue that also allow us to know their needs and expectations.

5. Commitment to transparency, as a way of transmitting and generating trust and credibility to our stakeholders. Which implies:

a) To disseminate relevant and truthful information on Gabitel’s performance and activities,

b) To prepare and publish financial and non-financial information that is considered appropriate guaranteeing its reliability and encouraging continuous improvement.

6. Commitment to Human Rights. GABITEL’s adherence to the United Nations Global Compact, and its ten principles, commits us directly to the respect, defence and protection of Human Rights contained in the “International Bill of Human Rights”, in the conventions of the International Labour Organization (ILO) and in the Declaration of Fundamental Principles and Rights at Work.

For all these reasons, GABITEL is committed within the field of Human Rights:

a) To avoid practices that are discriminatory or undermine the dignity of any person:

Seeking a dignified, safe and healthy work environment, adopting rules and procedures in matters of occupational health and prevention of occupational risks, avoiding any type of discriminatory attitude, intimidation or violence, in any of its manifestations for reasons of sex, ethnic origin, creed, religion, age, disability, political affinity, sexual orientation, nationality, citizenship, marital status or socioeconomic status.

b) To respect its employees’ right to unionize, their freedom of association and collective bargaining, as well as to respect the role and responsibilities of workers’ representatives in accordance with current legislation.

c) To offer decent employment:

c.1. GABITEL compensates its employees in a dignified manner, adjusted to their competences, responsibilities and functions. Such remuneration shall be aligned with the applicable legislation and with the conditions of the markets in which it operates, enabling them to meet their basic needs and those of their families.

c.2. GABITEL guarantees the right of its employees to a working schedule that respects the right to rest and will facilitate flexible working practices, recognizing the need for employees to balance and reconcile their working life with other interests and responsibilities.

c.3. GABITEL also guarantees the right of individuals to the privacy of their personal data (information security manual).

7. Fiscal responsibility. GABITEL, aware that the payment of taxes has a direct impact on the economic and social development of the countries in which it operates, complies with its tax obligations in accordance with the corresponding tax legislation.

8. Conservation and promotion of the environment. GABITEL develops its activity under the unwavering commitment to contribute to sustainability from an environmental perspective, materializing through the integration of the environment into the business, the promotion of environmental responsibility, preservation of biodiversity, pollution prevention, efficient management of resources and adaptation and mitigation of climate change, in accordance with the provisions of the company’s Environmental Policy and the certification of its environmental management system: ISO 14001:15.

SPECIFIC OPERATING PRINCIPLES

1. Employees: GABITEL has a Code of Ethics and Conduct, which establishes the rules that must govern the behavior and actions among employees and in their relationship with third parties. In addition, it promotes a working environment based on trust and mutual commitment, which implies:

a) Consolidating a culture of respect for people and favorable behavior open to diversity towards any of the company’s stakeholders.

b) Guaranteeing the right to effective equality of opportunity and treatment for all workers in order to enable them, without exception, to develop personally and professionally.

c) To avoid any type of labor discrimination in the areas of access to employment, promotion, professional classification, training, remuneration, conciliation of work and family life and personal and other labor conditions.

d) Contributing to the maintenance of work environments free from harassment and violent or offensive behavior towards the rights and dignity of individuals, and ensuring that, should such behavior occur, adequate procedures are in place to address and correct the problem.

e) Achieving an optimum level of occupational safety, and creating a working environment that allows GABITEL professionals to carry out their work in the best physical, mental and welfare conditions. (OHSAS Certified).

f) Promoting the establishment of retributive conditions that guarantee a dignified salary, recognizing the performance and contribution of the employees in the results of the company.

g) Offering employees the opportunity to channel and develop their solidarity through the social work in which GABITEL participates.

2. Customers. They are the basis of the business, including the potential customer, and therefore GABITEL assumes the following commitments:

a) Provide honest advice and complete information on the characteristics and qualities of GABITEL’s products and services, prior to contracting.

b) Providing an accessible, quality service in the agreed timeframe, monitoring the customer’s experience, by means of surveys that measure their satisfaction and by other means and systems that allow the customer to be actively and permanently heard in all those processes and operations in which the customer relates to GABITEL.

c) Maintaining due confidentiality in the treatment of their data.

d) Manage and resolve your complaints in the shortest possible time.

e) Maintain adequate and efficient communication channels.

f) Continuous innovation in value-added products and services.

g) Respect and comply with the rules that regulate communication and marketing activities and assume the voluntary codes that give transparency and veracity to such actions.

3. Suppliers. GABITEL has a management model and relationship with suppliers that seeks to ensure an ethical and socially responsible process in its actions with all stakeholders in the value chain.

That implies:

a) In addition to focusing on the efficiency and quality of the products and/or services provided by GABITEL’s suppliers, the adoption of responsible practices that generate mutual value is promoted.

b) Ensuring that the value chain complies with GABITEL’s principles and values, with the Code of Ethics and Conduct and with the principles established in this policy.

4. Society. GABITEL is committed to the economic and social development in which it develops its activity, and for this reason:

a) It assumes the impact that its activity generates on society, evaluating and managing non-financial, ethical, governance, reputational, social and environmental risks, in accordance with the provisions of its policy, as well as the provisions of general principle six of this policy, related to Human Rights.

b) It commits to those social initiatives or activities that benefit society.

The Social Responsibility Committee, with executive functions and powers of information, advice and proposal within its sphere of action, shall be the one that, acting in accordance with the competences it has established, approves and develops this Policy.