Galde

Ethics and Compliance

Galde Analytics, S.L. ("Galde") works with integrity and does not tolerate bribery or corruption, in any country or with anyone. This page sets out its Code of Ethics and its Anti-Corruption Policy, which apply to its whole team and to anyone acting on its behalf.

Code of Ethics

Our Code of Ethics sets out the commitments we work by every day: we obey the law, tell our clients the truth and protect the information they entrust to us.

1. Who it applies to

  • Galde and everyone who works for it, whatever their role.
  • Anyone acting on Galde's behalf, such as freelancers, agencies and partners, in what they do for Galde. We tell them about it and include it in their contracts.
  • Where a country's law is stricter than this Code, the law applies; where the Code is stricter, the Code applies.

2. Honesty with clients

  • We only promise what we know how to deliver, and we flag it early when something is not going as expected.
  • We only cite real certifications, awards, trademarks and references, and we only name a client with their permission.
  • We invoice the work actually done, backed by reliable time records.
  • We work without black boxes: clients receive the code, documentation and know-how for what we build for them, as their contract provides.

3. Confidentiality and data protection

  • We process personal data in line with the GDPR and the laws of each country where we work.
  • We only access the information each engagement needs, with least-privilege access, and use it only for that engagement, never to trade securities or to share it with others.
  • We do not use a client's data to train our own or third-party AI models, only the models that client commissions from us.
  • We keep client and partner information confidential after the relationship ends, return or delete their data as agreed, and tell the client without delay about any security incident that affects them.

4. Responsible artificial intelligence

  • We design AI systems so that a person reviews and approves their outputs when they affect people or regulatory compliance decisions.
  • We document which model and version each system we deliver uses.
  • We tell clients and users when they are interacting with an AI system or receiving AI-generated outputs in our products.
  • We comply with the EU Artificial Intelligence Act and respect the licenses of the models we use.

5. Conflicts of interest

  • A conflict of interest arises when a personal, family or financial interest may influence, or appear to influence, a work decision.
  • Whoever has one reports it to the director before deciding and steps aside from that decision. If it concerns the director, it is put in writing, Galde's external advisers are consulted and, where appropriate, it is disclosed to the client.
  • We do not work for two clients with conflicting interests in the same matter at the same time unless both know and agree.

6. Public funding and legal obligations

  • Our applications for public grants and subsidies, from any public body, are truthful and verifiable.
  • Each grant is used for the purpose it was awarded for, and the same cost is never funded twice.
  • We keep the supporting documents and cooperate with any check or audit.
  • We meet our tax and social security obligations, and we do not help anyone evade taxes or commit fraud.

7. Fair competition and intellectual property

  • We compete on the quality of our work: we do not fix prices or share out clients with competitors.
  • We do not use confidential information from competitors, former employers or former clients.
  • We respect intellectual property and the licenses of the software, data and AI models we use.

8. People

  • We treat everyone with respect, without discrimination on any personal or social ground, and we do not tolerate harassment.
  • We value people for their work and support work-life balance and safe remote working.

9. Environment

  • We work remotely and in the cloud, and we travel when a trip achieves something that cannot be done remotely.
  • We measure our contribution to the Sustainable Development Goals with an improvement plan that sets targets and indicators.

Anti-Corruption Policy

At Galde we do not offer, promise, give, request or accept bribes, to or from anyone, in any country, either directly or through third parties.

1. What we prohibit

  • Offering, promising, giving, requesting or accepting anything of value to improperly obtain or keep business, an advantage or a favorable decision, or as an improper reward for one.
  • "Anything of value" includes money, gifts, hospitality, travel, discounts, loans, donations, contracts or jobs, for the recipient or their relatives.
  • The prohibition applies to public officials and employees and to people in private companies, in Spain and in any other country.
  • Nor do we use influence over a public official to obtain a favorable decision.

2. Legal framework

We comply with the Spanish Criminal Code, which punishes bribery of public officials, influence peddling and commercial bribery, including bribery of foreign public officials. We also comply with the UK Bribery Act 2010, the US Foreign Corrupt Practices Act and the laws of each country where we work. Where two rules overlap, we apply the stricter one.

3. Facilitation payments

We do not make facilitation payments: small payments to an official to speed up a routine procedure one is already entitled to. The only exception is a threat to someone's physical safety; in that case, the payment is reported to the director as soon as possible and recorded.

4. Gifts and hospitality

Courtesy gifts and hospitality are allowed if they are modest, occasional and transparent, and never aim to influence a decision.

  • Up to €100 per person and occasion, with no further formality.
  • Above €100, the director's approval is needed, before offering it or as soon as it is received, and it is entered in the gifts and hospitality register. If it is not approved, it is returned with a note of thanks.
  • Never cash or cash equivalents, such as gift cards or vouchers.
  • While a bid, negotiation or tender involving that person or their organization is under way, no gifts and, at most, a modest business meal.
  • Always within the rules of the client or the other party, which are often stricter.
  • For public officials and employees, nothing beyond a token item with the Galde logo, always entered in the register.
  • Invitations to professional events are accepted when they have a clear business purpose. Travel and accommodation paid by third parties only with the director's approval.

5. Public authorities and officials

  • We deal with public authorities, public bodies and state-owned companies only through formal channels, in Spain and abroad.
  • We offer nothing to anyone who processes, assesses or decides a grant, license, contract or inspection that affects us, or to their relatives.
  • We do not hire public officials or their relatives as a favor or to influence a decision.
  • Contracts with the public sector follow its procedures and are documented.

6. Intermediaries and partners

This policy also binds anyone acting on our behalf: sales and lead-generation agencies, freelancers, platforms, partners and, in the future, agents in other countries.

  • Before engaging them, we check who they are, their reputation and that they are not on sanctions lists, in proportion to the risk.
  • The contract includes an anti-corruption clause and allows termination if it is breached. Where they only accept their standard terms, we check that those terms prohibit bribery.
  • We pay only for real services, at market rates, against an invoice and by bank transfer to an account in the supplier's name.
  • We stop and ask at any red flag: requests to be paid in cash, to a third party or in a country other than their own; unexplained commissions or expenses; refusal to sign the clause; or a recommendation from a public official connected with the decision.

7. Donations and sponsorships

  • We make no contributions to political parties, their foundations or their candidates.
  • Donations and sponsorships go to registered organizations with a legitimate purpose. The director approves them, they are documented and they are never linked to a business decision.

8. International sanctions

We do not work with people, companies or countries under European Union, United Nations, United States or United Kingdom sanctions that prevent us from doing so. Before working with a new client or partner from another country, we check.

9. Accounting records

  • Every payment has an invoice or supporting document and is recorded in the accounts, which faithfully reflect every transaction.
  • There are no off-the-books payments or accounts.
  • We keep the gifts and hospitality register, third-party checks and supporting documents for at least six years, or longer if the law or grant terms so require.

How it works

Galde's director makes sure this Code and this Policy are followed, answers questions about them and reviews them every year.

Questions and breaches

  • When in doubt, we ask before acting. Questions, possible risks and any possible breach are reported to the director.
  • Anyone who receives a request for, or an offer of, a bribe refuses it and reports it to the director.
  • If the matter concerns the director, it is put in writing and Galde's external advisers are consulted.
  • No one will suffer retaliation for raising a question or reporting a possible breach in good faith.

Training

  • Everyone receives this document when they join and confirms in writing that they have read it.
  • Every year we go through the Code and the Policy together, with practical cases, and keep a record.

Consequences

  • Breaching this Code or this Policy may lead to disciplinary action under employment law and, for contractors and suppliers, to termination of their contract.
  • If a breach may be a crime, Galde will cooperate with the authorities.

Approval, validity and review

  • Version 1.0, approved by the director of Galde Analytics, S.L. in October 2026 and in force since its approval.
  • The director reviews it every year and whenever the law, Galde's activity or its organization changes, or a significant breach comes to light.
  • This page always shows the current version.
  • This text exists in Spanish and English; if the two versions differ, the Spanish version prevails.