We respect the confidentiality and privacy of everyone. UP respects the privacy 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 contractual obligations.
• Will only use said information for legitimate purposes.
• Will avoid disclosing unauthorised 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 unauthorised individuals. 
• Will also avoid accessing external systems, so as not to discover personal third-party data. 
• 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 Lawrence Masle, CEO of UP -  lawrence@upthereeverywhere.com  

When promoting UP on social networks, we always strive to adopt an appropriate tone, bearing in mind that any comments will be associated with UP.

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 maintain UP’s reputation and that of its members and partners and encourage achievement of their objectives.

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 cloud-based 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 governing compliance, legal matters or for reasons of business continuity.

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 authorisations. 


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 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 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 for photoshoots), we have obtained prior written consent from the parents. Likewise, we will take special care with scripts or content aimed at young audiences.

If a member establishes a business relationship with family members or friends that could cause a conflict of interest, they are asked to 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. 



Cleanliness in the workplace directly affects everyone’s safety and wellbeing and can impact people’s health. We ensure appropriate levels of cleanliness so as not to affect people’s health and wellbeing. Members are also supplied with a remote working Health and Safety checklist to refer to when working from home.

We encourage courteous and respectful treatment of members and strive toward providing people with an enhanced working environment.  We avoid any type of work-related or sexual harassment in the workplace (or whilst providing services within UP). Any kind of verbal or physical offence will not be tolerated. Anyone who finds themselves in this situation should report it immediately to UP’s CEO - Lawrence Masle (lawrence@upthereeverywhere.com) or using the channels specified in this Code. 

Alcoholic drinks, drugs and abuse of prescription medication can negatively impact performance and can cause accidents. Therefore, we will avoid the consumption of alcohol or any other substances that affect our health (unless officially prescribed) when providing services for UP.



Being a cloud-based agency is one of the key ways in which we help to create a healthy work environment for everyone at UP, whilst concurrently minimising our environmental impact by limiting travel and an office presence. We respect the environment, aiming to limit our greenhouse gas emissions wherever possible. We regularly engage with members regarding improvements to UP’s carbon footprint via our internal communications channels and we have a Sustainable Procurement Policy.

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 dispose of items surplus to requirements by the correct means, 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.

When doing business, we aim to deliver 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 favourable 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 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 favour us, or so that we favour them, in some way, over others. 


Overall, we will not give gifts without justifiable reason, nor will we accept any gifts offered by customers, suppliers or third parties that go beyond common courtesy.
 However, attendance at hospitality events or business meals with clients or suppliers are an acceptable and normal business practice, provided they are within UP’s stated financial limits (these can be checked by liaising with Anna Flossing, UP’s Chief Financial Officer). Therefore, we will avoid accepting trips, holidays or similar favours from our customers and suppliers, or offering them ourselves, unless they support UP’s legitimate business interests and fall within our stated limits.

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 authorisation, 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 via 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 examples. 



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

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 programmes. 

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 Leadership Team) of any urgent situation that cannot wait for a periodic report. The UP Leadership team is at the disposal of members, partners, suppliers, clients and other stakeholders to resolve any queries or clarify matters relating to this Code of Conduct. 


• Work-related or sexual harassment and verbal and/or physical offences against other members.
• 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 and exceed our stated limits.
• Accessing 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 authorises, directs, approves, participates in or intentionally does not report those activities that go against those 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 offence(s) committed. In the event of minor offence(s), a verbal or written warning may be given. For serious offences, the sanction may range from termination of the relationship with UP to being reported (on criminal, civil or corporate grounds) to the relevant authorities.