Our Ethics

We do what is right: act ethically, honestly, responsibly and with integrity and quality. All our internal activities reflect on and are relevant to the external environment. 

Our Code of Conduct describes how we must act when performing our professional duties, whenever we act in representation of UP, whether in any of out Creative Spaces or in any location, either at home or abroad, so we avoid committing a crime or breaching legislation that may lead to undesired consequences for individuals or UP.

Our Code of Conduct reflects the principles that serve to guide us in acting responsibly and helping us when making decisions at work:

Scope of Application

The Code of Conduct applies to the following: 

• All individuals who work with UP, regardless of their geographic location, post held or contractual relationship (membership, partnership). This also includes the owners and board members.
• Internship students.
• Third parties who have interactions with the UP, whether they are suppliers, contractors, collaborators or customers, insofar as this is applicable and provided that UP has the ability to enforce it. 
• If there is any practice in the Code of Conduct that conflicts with the law of the country where a subsidiary company is based, this practice will be revised to comply with local legislation. 

Everyone will immediately inform the UP-Leadership team of any irregular or unethical actions relating to this Code of Conduct. The channels for contacting the Committee are outlined later in this document. 

Operating Standards

We respect the confidentiality and privacy of everyone.

UP respects the privacy and intimacy of all our members, partners, customers, suppliers, collaborators and all those whose data we process in order to perform our work. 

Individuals who process personal information: 

• Will act responsibly and in accordance with the Law. 
• Will act in accordance with all their contractual obligations. 
• Will use said information only for legitimate purposes. 
• Will avoid disclosing unauthorized confidential and/or personal information. 

Will limit access to the information only to those who have a legitimate use for said information. Will take special care with information stored in our IT systems, preventing access to unauthorized individuals. Will also avoid accessing external systems so as not to discover personal third-party data. We will not record or reproduce external images or conversations in which we have not participated. 

For journalistic work or films, the use of hidden cameras is considered unacceptable, as is any other deceptive procedure for obtaining information, images or witnesses. The interception and dissemination of private material from mobile phones, emails and other means of communication without consent is also inadmissible. An exception to this could be situations relating to facts or events that are unmistakably in the public interest and when there is no other option in order to properly comply with the right to information.

When their use is required in productions for third-parties, the Ethical Code of the company that has contracted the professional services will apply. Any queries in this area should be directed to the Legal Advice department.

When managing UP on social networks, we will always try to use a suitable tone, bearing in mind that any comments will be associated with UP.

We guarantee transparency in our financial and accounting data 

We guarantee accuracy in our financial data. In internal relationships, relationships with third parties and with the Government, we ensure that the accounting data faithfully reflects the financial reality of each department. 

The accounting data will be updated and will always agree with UP’s actual status. To do this, we ensure that all our records are accurate, paying particular attention to the information provided to the Public Administration due to its official nature. This will help boost the reputation of UP and its members and partners and encourage the fulfillment of their objectives. 

We aim to make proper use of new technology

The use of the Internet and new technology constitutes vital tools for UP as a digital communications agency, not only in our external relations, but also internally. 

Our work is stored on IT systems and so we consider new technologies to be a fundamental asset for UP. Therefore, we will take special care when using the IT systems so as not to delete or corrupt our own data and/or that of third parties. We must remember that the IT systems are the property of UP and their use should be limited to the performance of the professional tasks entrusted. 

UP may access the corresponding equipment and systems, as well as the corporate email in extraordinary circumstances for the purposes of verifying the proper use of the IT resources or for reasons of business continuity. 

We respect third-party intellectual and industrial property rights 

The results of our work are particularly valuable for UP. The work we create and which we make public to third parties, due to the activity that we perform, is the result of our daily efforts and is UP´s important products, together with our brand. 

We will take care to ensure and guarantee that our products are covered by intellectual and industrial property rights. Likewise, we will protect and respect these rights when the creators are external third parties. In order to use these, we will ensure that we have obtained the appropriate authorizations. 

We protect consumers 

We will not participate in projects that disregard the values that inspire us at UP. 
We will also ensure that our advertising is truthful, legal, honest and fair. We will be guided by the principle of transparency, clearly communicating contracting conditions and rights. 

We demand fair working conditions

We all have the right to be protected against discrimination and harassment of any kind, therefore we will be courteous and respectful in our relationships with colleagues and third parties. Likewise, we will ensure that our working relationships are in accordance with the laws and that they do not promote or encourage hiring people without the relevant work permits. 

We protect children 

We protect minors by preventing their participation in exhibitionist spectacles and always ensuring the best conditions possible. We will take special care when processing information concerning minors ensuring that if children are hired for work, for example, photoshoots, we have prior consent from the parents. Likewise, we will take special care with scripts or content aimed at young audiences. 

We correctly manage conflicts of interest

If we establish business relationships with family members or friends that could cause a conflict of interest, we will inform the UP-Leadership team. We will avoid using confidential information for our own benefit or that of third parties.  The internal and external relationships arising as a result of performing work for UP will not be used for our own benefit or for the benefit of friends or family members. 

We maintain cleanliness and order in the Creative Spaces

Cleanliness in the workplace directly affects everyone’s safety. We will avoid lack of cleanliness and personal hygiene that may affect the production process or image of UP. 

We ensure proper treatment of colleagues

We encourage courteous and respectful treatment of colleagues for a better working environment.  We avoid any type of work-related or sexual harassment in the workplace or that occurs while providing services within UP. Any kind of verbal or physical offense must also be avoided. Anyone who finds themselves in this situation should report it to the UP- Leadership Team or using the channels specified in this Code.

We don’t work under the influence of alcohol or drugs

Alcoholic drinks, drugs and abuse of prescription medication may negatively affect performance and can cause accidents. Therefore, we will avoid the consumption of alcoholic drinks or any other substances that affect our health when providing services for UP. 

We protect natural resources and the environment

Being a cloud-based agency is our way of creating a healthy work environment for everyone at UP, at the same time as we minimize our environmental impact by minimizing travel and office space. We respect the environment, avoiding emissions, spillages, radiation, extraction or excavation, silting, noise, vibrations, injections or deposits in the atmosphere, soil, subsoil or surface water, underground water and sea water. 

We respect the balance between the natural systems and the health of individuals by avoiding deposits and the dumping of waste and solid or liquid residues that may be toxic or hazardous. We will dispose of those things we no longer need in the areas indicated, always respecting the environment. If we use explosives to create an atmosphere for a fictional production, we will ensure that we comply with all the legal requirements in this regard. In all cases, we will always act with the administrative permits necessary for performing our activities. 

We act with integrity in our business dealings

When doing business, we aim to results in a legal, fair and honest manner. We look for competitive benefits using our own merits, never through unethical or illegal commercial practices. This means that in relationships with suppliers, customers, collaborators and public officials we will maintain business integrity and respect the law.

We will avoid offering or promising any compensation to a public official, whether directly or indirectly, in exchange for favorable or beneficial treatment.

Our relationships with other companies, customers, external collaborators and suppliers will be based on the strictest sense of integrity and fairness in business dealings. In this regard, we will avoid offering, promising or accepting tokens or gifts from individuals or companies that are currently or may in the future be involved in commercial activities with us, so that said individuals favor us, or so that we favor them, in some way, over others. In general, we will not give gifts for any reason, nor will we accept any gifts offered by customers, suppliers or third parties that go beyond common courtesy. 

However, attendance at sporting or leisure events or business meals with the customer or supplier are an acceptable and normal business practice, provided they are within the previously stated financial limits. Therefore, we will avoid accepting trips, holidays or similar favors from our customers and suppliers, or offering them ourselves, unless they support UP’s legitimate business interests and fall within the previously stated limits. 

We protect and maintain free competition

Protection of free competition in the markets, is part of our philosophy, our commercial policy and our way of interacting within the market. It is very important that we all respect this free competition, and ultimately, that we undertake to compete fairly with all other companies in the market. We want to compete in quality, services and content, without taking advantage of benefits obtained illegally or fraudulently. 

A way of violating free competition could be to access the data, documents or resources of other companies without authorization, or to intercept any kind of communication to obtain secret or confidential information about other companies, whether for the purpose of obtaining an advantage over such companies or for personal benefit, or for the purpose of damaging said companies or their staff by disclosing the information, even if in theory there is no apparent purpose. We will avoid these types of action, whether said confidential information has come into our possession directly or through a third party. 

The concept of corporate “trade secrets” and “confidential information” are wide-ranging and cover all data and information that any company wants to keep secret, related, for example, to client information or internal information such as personal data of members or partners, financial data and other financial results of the company that are not public, and any other data or information that is private and is important for the proper functioning of the company. It may often be information marked as “Confidential” or “Secret”, however it will not be limited to these cases. 

Another form of violating free competition may be to use, directly or through a third party, privileged information relating to the pricing of any type of shares or securities traded on a stock market, or to provide or disseminate such information for personal benefit or that of third parties. 

Privileged information is information that is generally not public and relates to a company or and to which an individual has had access for the performance of their professional or business activity, for example, by being involved. 

We have a transparent relationship with the Government

We must ensure complete transparency regarding the information we are required communicate to public bodies at all times.

UP Policies

The policies are available on our internal Administration System: SuperSystem and Base Camp

UP Leadership team heads compliance

UP has appointed the UP-Leadership team to handle compliance and the responsibility is shared between the members for the daily activities as regards regulatory risk prevention with the following duties: 

1. To encourage dissemination and awareness of and compliance with the Code of Conduct and the compliance standards and procedures and fraud prevention.
2. To ensure the operation and effectiveness of and adherence to the Compliance Model.
3. To ensure the approval and application of the procedures necessary for the proper functioning of the prevention model. 
4. To encourage the preparation and implementation of suitable Compliance training and communication programs.
5. To establish the tools necessary to ensure the recording of the necessary activities.
6. To keep files and documentation on the work performed.
7. To periodically prepare a report on the activities of the Compliance Function for the Audit Committee and, at least once a year, for the Board of Directors.
8. To read the reports prepared by the UP Leadership team relating to reports or investigations that they have drafted/carried out and decide if there has been a breach of the Code of Conduct and propose a sanction.
9. To appoint and inform an Audit Committee and, where appropriate, the senior management, of any urgent situation that cannot wait for a periodic report. 

The UP-Leadership team is at the disposal to members, partners, suppliers, clients and other stakeholders to resolve any queries or clarify matters relating to this Code of Conduct. 

Inquiries and Reports

For the purpose of highlighting what are considered violations of the Code of Conduct the following is a non-exhaustive list of violations: 

• Work-related or sexual harassment and verbal and/or physical offences against other colleagues. 
• Performing operations for personal benefit, or for the benefit of family members or third parties, to the detriment of UP. 
• Reaching agreements with competing companies in the submission of tender offers. 
• Accepting or sending gifts that go beyond the bounds of common courtesy. 
• Access and disclosure of confidential information to third parties. 
• Not reporting a breach of the Code of Conduct when aware of said breach. 
• Falsifying accounting data. 
• Being noticeably drunk or under the influence of drugs in UP´s facilities during work. 
• Sending repeated malicious Code of Conduct reports. 
• Reporting fictitious transactions, among others, regarding sales, purchases, loans, credits and expenses. 
• Making unnecessary purchases of goods and services to the detriment of UP. 
• Discriminating against, intimidating or harassing another individual because of their race, gender, age, origin, religion, beliefs, sexuality or state of health. 

Any individual who authorizes, directs, approves, participates in or intentionally does not report those activities that go against that established in the Code of Conduct may be subject to applicable disciplinary measures according to local legislation applicable in each case. The severity of the sanctions will depend on the severity of the offenses committed. 

In the event of minor offenses, a simple verbal or written warning may be given, and for serious and very serious offences, the sanction may range from termination of the relationship with UP to being reported (on criminal, civil or corporate grounds) to the competent authorities.