Code of conduct

6 June 2023
Version 1.0

1. Purpose

The Code of Conduct of FUTURE CONNECTIONS is the document that establishes the performance criteria that must be observed by the Group in the performance of its professional responsibilities with employees, customers, suppliers and any other interested party that may interact with the group.

This Code of Conduct has been drawn up taking into account internationally recognised general considerations of good governance.

2. Scope of application

This Code of Conduct applies to all companies in the Future Connections Group and to all persons asóciate with it. The following are linked: management, partners, employees, investors, suppliers and customers.

Those companies in the Group that have other applicable Codes of Conduct derived from the legislation of the country in which they operate, shall also comply with them.

No person, regardless of level or position, is authorized to request non-compliance with the provisions of this Code, just as no person may justify improper or illegal conduct on the grounds of a superior order.

3. Compliance with laws and regulations

Our professionals and suppliers must comply with all applicable laws, regulations, and standards in their work. They must understand and follow the company’s policies, procedures and guidelines related to safety, security and quality. Employees should also report any violations or potential violations of laws or company policies.

4. General ethical principles

4.1 Mission

Our mission is to help businesses in the telco industry and beyond to achieve improved levels of performance and end-customer satisfaction. We do so by helping them along their digital transformation journey towards network and operations automation, simplification and efficiency, through the implementation of leading technology and first-hand network knowledge.

4.2 Vision

We envision becoming one of the best digital transformation enablers in the telco industry. We achieve this by helping the ecosystem and beyond to consolidate and push further their move from manual dependency and legacy processes to more efficient and automated operations through the implementation of leading technology.

4.3 Values

4.3.1 Quality

Quality, quality, quality: Consistent delivery of high-quality services and products that satisfy and delight our customers and colleagues.

4.3.2 Seamless service

Optimal customer experience: Service experience that feels almost invisible and natural to our customers with the removal of all potential stress points in our delivery.

4.3.3 Innovation

Continuous innovation and improvement: Going beyond the status quo with cutting-edge technology to constantly improve, advance, innovate and deliver game-changing ideas and creative solutions.

4.3.4 Flexibility

Agile and flexible methodology: Quick adjustment and adaptation of our processes and responses to the different and ever-changing situations of the customers in their fast-paced environment.

4.3.5 Commitment

Total commitment to customers: Result-oriented approach based on a genuine understanding of customer’s challenges and the commitment to deliver practical and successful solutions.

4.3.6 Human factor

Our people are our best asset: Firm belief that the beating heart of our success is our people, with their collaborative spirit, creativity that breaks boundaries and passion for what they do.

5. Business ethics and professionalism

The Future Connections Group is totally against any type of conduct that could be considered irregular or against the Law.

All companies in the Group will strictly comply with applicable accounting, tax and labour regulations, avoiding risks of inefficiencies in decision-making.

Furthermore, the Group is particularly committed to fighting corruption and fraud. As a result, it will develop specific training plans related to these matters to raise awareness among its staff.

We expect our members to behave professionally at all times. This includes being respectful and courteous to colleagues, customers and all stakeholders. Professionals should act with integrity, honesty and transparency in all their dealings and communicate effectively and clearly.

6. Group personnel

6.1 Selection, recruitment, assessment and promotion

The Future Connections Group will have objective selection, recruitment, assessment and promotion processes that exclusively meet the criteria of academic merits and ability of candidates according to the knowledge, aptitudes, skills and competencies required for the different jobs.

Each company in the Group is responsible for the assessment, growth, development and promotion of its team. For this reason, its priority is to create adequate working conditions, as well as to offer support and advice, and to deliver recurrent, high-level training.

Such processes shall promote diversity, equal opportunities, equity and inclusion, prioritise the recruitment of the best qualified persons and have mechanisms in place to avoid any interference or conflict of interest between the parties necessarily involved.

The employees and collaborators shall be involved in the definition of its objectives and shall be aware of the evaluations and criteria applicable to them.

6.2 Training

The Future Connections Group will promote the training and development of its employees. It will develop training plans aligned with the business objectives, providing equal opportunities.

Based on this, an annual budget per professional is approved to promote external training aimed at updating the knowledge and the professional skills of the staff.

All staff members have the duty to actively participate in the training plans made available to them, applying themselves to their own development and committing themselves to keep up to date the knowledge and skills necessary to provide value, maintain an excellent performance and promote their professional progress.

6.3 Resources and means for the performance of duties

The Future Connections Group undertakes to make available to its members the resources and means required and appropriate for the performance of their duties.

Without prejudice to the mandatory compliance with the specific rules and procedures on resources and means, the persons who are part of the Group undertake to make responsible use of the resources and means made available to them, using them exclusively for activities in the interest of the company. That is to say, such resources and means will not be used or applied for private purposes.

The use of equipment, systems and software that the Group makes available to the members for the performance of their duties, including the facility to access and operate on the internet, must comply with security and efficiency criteria, excluding any use, action or computer function that is unlawful or contrary to the rules or instructions of the company. In other words, it is not permitted to use the equipment for computer programs or applications whose use is illegal, which may damage the Group’s image or reputation, or to access, download or distribute illegal or offensive content.

6.4 Reconciliation of personal, family and working life

The Future Connections Group encourages and promotes the reconciliation between the professional and personal lives of all its members, as it recognises the need for and importance of maintaining a work-life balance for the benefit of the professional, the Group and the customer.
In this sense, the Group is committed to the implementation of all those measures that can achieve an effective work-life balance, such as implementing teleworking.

6.5 Human rights: equality and non-discrimination, dignity, integrity and privacy

The Future Connections Group fully embraces a policy of respect for human rights. In particular, the group is against child labour and forced labour, and is committed to treating all people with dignity and respect, and to non-discrimination in all circumstances.

Future Connections will base its remuneration policy, overtime policy, social benefits policy and vacation policy on the applicable legislation, without prejudice to any improvements it may wish to implement to improve the welfare of its employees and its competitive position as an employer brand.

The Group does not allow or tolerate discrimination based on gender, race, colour, nationality, social origin, age, marital status, sexual orientation, ideology, political opinions, religion or any other personal, physical or social condition of its members, and promotes equal opportunities.

In particular, the Group promotes equal treatment between men and women and rejects any manifestation of harassment, abuse of authority, violence or any other conduct that generates an intimidating or offensive working environment for the rights of its members, regardless of its form of expression. On this basis, the Group has approved a Harassment Prevention Plan.

All Group members are committed to maintaining a work environment that respects personal dignity and freedom. Likewise, relations between members of the Group and external companies or collaborators shall be based on professional respect and mutual collaboration.

6.6 Labour rights: health and safety

The objectives of the Future Connections Group in terms of health and safety are:

  • the prevention of incidents as a guarantee of safeguarding the health and safety of members
  • the promotion of health and safety of professionals through the prevention of risks arising from work

In this way, all companies in the Group comply with occupational health and safety regulations in accordance with the country’s current regulations. Likewise, all professionals are aware of and comply with occupational risk prevention regulations, ensuring compliance with the prevention measures adopted for their health and safety in accordance with their training and instructions from the Group.

Thus, members are forced to:

  • contribute to comply with the obligations established to protect the health and safety of the professionals at work
  • cooperate with the respective company to ensure safe working conditions that do not entail risks to the health and safety of the professionals

7. External activities

The provision of employment, professional or academic services by employees to companies outside the Group, whether for their own account or on behalf of others, must be authorized in advance by the Human Resources Management if these activities are related to the business of Future Connections.

Future Connections respects the social and public activities of its employees, provided that these do not affect their work or the reputation of the company.

8. Social networks, blogs, and other communication media

Future Connections understands the use of social networks as an institutional communication tool that, in line with the Group’s strategy and objectives, can contribute to enhance the organization’s identity and corporate culture, as well as to make the Group known in the environment in which it operates.

It is a misuse of computer systems and resources (and therefore expressly prohibited) to use social networks and media to disseminate information, make statements or show images that may be imprudent, inadequate, inappropriate, offensive, discriminatory, defamatory or that may in any way affect the prestige and reputation of the Group, its professionals, its customers or third parties.

9. Confidential information

9.1 Information transparency and privacy policy

Future Connections Group considers the collection and proper use of information a competitive advantage. Consequently, the administration and management of information must be responsible, safe, objective and in accordance with current legislation.

Like all companies, during the course of its activities the Group generates valuable reserved or confidential technical and commercial information whose disclosure could harm its interests, those of its customers and suppliers, or its operations in the market. The Group is committed to regulating in a clear and reasonable manner the identification, handling and protection of its reserved, confidential or secret information. In particular, the Spanish subsidiary company in the Group is certified in the Information Security Management System based on UNE-EN ISO-27001:2017.All the recipients of the Code of Conduct who are employed by the Spanish subsidiary and are based in Spain must know and comply with the provisions of this system.

9.2 Treatment of information

The information handled by the members of the Group must be treated and recorded in an accurate, truthful and clear manner. In particular, all economic transactions, all operations carried out and all income and expenses incurred must be clearly and accurately reflected in the corresponding accounting records, in accordance with accounting and contracting procedures.
In addition, each company of the Group must preserve its information, facilitate its dissemination to other members with due transparency when required, and make it available to the knowledge management systems set up for this purpose, in order to facilitate the management of activities and enhance the development of people.

9.3 Handling of confidential information

Professionals have the obligation to protect the information and knowledge generated within the Group, either by ownership or by obligation of custody of such information.

Staff members shall refrain from using any data, information or document obtained during the exercise of their professional duties. They can´t communicate information to third parties, except in compliance with applicable regulations, internal regulations or when expressly authorized to do so. Likewise, they shall not use data, information or documents of a confidential nature from a third-party company without their written authorization.
Staff members undertake to maintain confidentiality and to use any data, information or document obtained during the exercise of their duties in accordance with the internal regulations on the matter.

In general, unless instructed otherwise, the information to which they have access must be considered confidential and may only be used for the purpose for which it was obtained.

Staff members must not make duplicates, reproduce it or make any use of the information other than that necessary for the performance of their duties.  

The obligation of confidentiality shall remain in place after the termination of their engagement and shall include the obligation to return any material related to the Group in their possession at the time of contract termination.

9.4 Data protection

The Future Connections Group respects the personal and family privacy of all persons, whether employees or others, whose data it has access to. Authorizations to use such data must be in response to specific and justified requests. Professionals must strictly comply with the internal and external rules established to ensure the proper handling of information and data provided to the company by third parties.

All staff must obtain the required consents and authorizations for the collection of personal data from customers, employees, suppliers or any person or entity with whom a contractual or other relationship exists. Personnel must also undertake to use the data in accordance with the purpose authorized by the grantor of such consent.

Likewise, all internal procedures implemented for the storage, custody and access of data intended to ensure the different levels of security required according to the nature of the data, must be known and respected.

All professionals will communicate to their superior any incident related to information confidentiality or to personal data protection.

10. Intellectual and industrial property

Future Connections owns the ownership and the rights to use and exploit software and computer systems, licenses, brands, know-how and other works and rights that it has acquired or developed as a result of its professional activity or that of third parties.

All persons associated with Future Connections must respect and preserve the intellectual and industrial property rights of the Group and of the third parties. Material protected by intellectual and industrial property rights may not be copied, disclosed, distributed, uploaded, downloaded or hosted without the appropriate authorizations. The Legal Department of the relevant member of the Group should be consulted in case of doubt about the availability of a certain element protected under the regulations governing intellectual or industrial property.

11. Competition

Future Connections undertakes to compete fairly and to promote free competition.
Likewise, the information that it will obtain from its competitors will be used within the framework of the law.

12. Conflicts of interest

A conflict of interest arises when the personal interests of professionals are directly or indirectly contrary to the interests of the Group, interfere with the fulfilment of their professional duties and responsibilities, or involve them personally in any transaction or economic operation of the Group. Members of staff must therefore avoid situations that give rise to a conflict of interest.

In situations where there may be doubts, the professionals must inform their superior and the Human Resources Management of the company to which they belong and avoid taking a decision that may make them suspected of having acted against the interests of the company.

Without prejudice to the provisions of specific clauses in each contract, no professional within the Group may provide services to another competing company if it gives rise to a conflict of interest.

13. Environmental protection

The Future Connections Group is fully aware of the importance of conserving natural resources and protecting the environment.

To this end, it promotes recycling and the implementation of paperless policies that have as a main benefit the respect and protection of the environment and, as a secondary benefit, the ease of finding, storing and sharing any file, the increase of productivity and the reduction of purchasing costs for paper and storage furniture.

14. Prevention of fraud and corruption

The members of the Group base their relationship with all external personnel on the principles of integrity, professionalism and transparency and undertake to avoid and prevent fraudulent or corrupt conduct.

On this basis, all members of the Future Connections Group may not accept or give gifts or advantages in the course of their business, except when they are a business courtesy considered customary in accordance with social customs. Gifts or entertainment are not acceptable if they may affect professionalism or independence or, indeed, may influence professional decision-making, in particular those that involve obtaining an undue advantage from public officials, authorities, political parties, suppliers or staff of other companies.

Likewise, professionals may not, directly or through an intermediary, offer or grant or request or accept any unjustified advantages or benefits for the immediate or indirect purpose of obtaining a benefit, present or future, for the organization, for themselves or for a third party. In particular, they may not give or receive any form of bribe or commission from any other party, such as public officials, personnel of other companies, political parties, authorities, customers, suppliers and providers. Acts of bribery, which are expressly prohibited, include the offer or promise, directly or indirectly, of any kind of improper advantage.

15. Professional relations

15.1 Employees

The conduct of the Group’s employees shall conform to the principles of professionalism and integrity, as well as to this Code of Conduct and the ethical values detailed in point 4.3., as well as to such texts as may be complementary thereto.

Professional behaviour refers to a diligent, responsible, efficient conduct, focused on quality, excellence and innovation within own sphere of competence.

Likewise, conduct based on integrity refers to acting honestly, loyally, fairly, in good faith and in line with the interests and values of the Group.

15.2 Customers

The Future Connections Group shall draw up its service contracts clearly and simply so that they are easily understood by its customers, especially with regard to pricing plans and payment formulas.

Future Connections staff shall avoid any kind of influence from clients that may affect their impartiality and professional objectivity.

15.3 Partners

Future Connections is a Group of companies whose holding company is Future Connections Holding B.V. and the various subsidiaries are located in the Netherlands, United Kingdom and Spain, where they carry out their activities in accordance with the provisions of the legislation of the country in which they operate.

The status of partner of Future Connections Holding, B.V. is acquired after a strict and rigorous process of analysis and evaluation of the professional merits of the candidates.

The information transmitted to the partners will be objective, transparent, truthful, complete, current and will adequately reflect the situation of the Group. This maxim shall be complied to in a particular scrupulous manner in relation to financial information.

15.4 Suppliers and partners

The Future Connections Group will carry out supplier and partner selection processes in accordance with criteria of transparency, equal opportunities and objectivity.

The companies in the Group shall avoid any kind of influence from suppliers and collaborators that may affect their impartiality and professional objectivity.

15.5 Public authorities

The relations of the companies in the Group with public administrations shall be governed by the principles of legality, collaboration, transparency, professionalism and good faith.

Future Connections shall comply with the administrative or judicial decisions that are issued in each case and shall retain the right to appeal in the event that it is considered that these decisions are not in accordance with the law.

16. Communications

In the event of violations or irregularities with respect to compliance with the rules of this Code of Conduct, such violations must be reported to the immediate superior and to the Director of the Human Resources department within 48 hours of becoming aware of them.

All information related to the management of the complaints received will be treated as confidential and will be managed by the Human Resources department. Nobody is allowed to retaliate in any way against those persons who have reported violations in good faith.

Notwithstanding the foregoing, Future Connections may provide this information to those administrative or judicial authorities that require it as a result of any proceedings arising from the purpose of the management of the violation, always in full compliance with current legislation on data protection.

17. Disciplinary regime

If a breach of the Code of Conduct or any other internal or external regulations is detected by any person associated with the Group, the conduct must be investigated and the possibility of taking appropriate measures must be assessed to

  • punish the behaviour
  • prevent its repetition
  • repair the damage caused

If the facts have criminal legal significance, the necessary measures will be taken so that, as soon as possible, the facts and all the evidence that accredits them are brought to the attention of the Administration of Justice.

For the adoption of the above decisions, the Group may seek the internal or external legal advice it deems necessary.

In all cases, the rights to:

  • the presumption of innocence
  • be informed of the accusation made against him/her
  • an adequate defence

shall be respected.

18. Approval, dissemination and modification

This Code of Conduct has been approved by the Management Body of the Future Connections Group and by the General Meeting of Future Connections.

This Code of Conduct, which must be complied with, has been communicated to all members of Future Connections by e-mail, it will be maintained on the corporate intranet, and on the website

All professionals of the Group, current and future, accept the values, principles, standards and guidelines for conduct set out in this Code. No one, regardless of position, may ask a member of the Group to contravene the provisions of this Code of Conduct. If a member receives an order from a superior contrary to the Code of Conduct, he/she must report it through the Human Resource department.

This statement of principles shall be updated periodically, adopting all proposals that are likely to be incorporated into this document.
The modification of this Code of Conduct will be the responsibility of the Human Resources and Legal departments of Future Connections.