Code of conduct

Why this document exists

A group with brands in several sectors and activity in eight markets needs a written rule, not a shared intention. This code applies to every company in the group, to its team and to anyone working on our behalf.

It is not decorative. When a client, a partner or a financial institution asks how we operate, this is the answer we give in writing.

Integrity in business

• We neither offer nor accept payments, gifts or favours intended to influence a decision.
• We do not take part in arrangements that unlawfully restrict competition.
• We decline any engagement whose purpose is to conceal the real nature of a transaction.
• If a business only works by hiding information from a regulator, a bank or a partner, we do not do it.

Anti-money-laundering

We identify our clients and the source of funds before starting a relationship. Where the activity requires it, we apply the procedures of Spanish Law 10/2010 and coordinate with the relevant firms in each jurisdiction.

We decline transactions when a client cannot or will not evidence the source of funds, or when the proposed structure has no economic logic beyond opacity.

Transparency with financial institutions

We describe our activity to banks and payment institutions exactly as it is. We do not split transactions, we do not use ambiguous descriptions and we do not open structures to avoid controls.

That is a practical decision as much as an ethical one: a group that grows on opacity ends up without banking access, and without banking access there is no business.

Client relationships

• We say no when an engagement does not match what we know how to execute.
• We quote with a closed scope: no open hours, no surprise overruns.
• We deliver what was promised, or explain why not before the deadline arrives.
• Ownership of delivered work transfers as agreed by contract.

Confidentiality and data

One client's information is never shared with another, nor used as a commercial example without express authorisation. Confidentiality agreements are signed before accessing systems or documentation.

Personal data processing is governed by Regulation (EU) 2016/679 and by our privacy policy.

People and conduct

• We do not tolerate harassment, discrimination or retaliation in any form.
• Decisions about people are made on professional grounds.
• Anyone who raises a concern in good faith faces no consequence for doing so.

Conflicts of interest

Anyone with a personal or financial interest that could condition a professional decision must declare it and step aside from that decision. Where the group both invests in a project and provides services to it, that dual position is disclosed in writing to everyone involved.

How to raise a breach

Anyone — inside or outside the group — may report conduct they believe contrary to this code by writing to info@riveenterprises.com with the subject “Code of conduct”.

Every report is reviewed. Anyone raising a concern in good faith is protected from retaliation, regardless of whether the facts are confirmed.

Approved by the management of Rive Enterprises, S.L. · In force since August 2026. This document is reviewed annually and must be validated by legal counsel before each update.