This document sets out the behaviour guidelines which we must implement from day to day so that our conduct follows LB’s values.

Those values are:

1. Customer orientation. Experienced staff and constant market research allow us to understand client´s needs.
2. Responsibility vis à vis our stakeholders, who expect a suitable return achieved based on best practices.
3. Our management style as a team is truthful, honest and responsible.
4. Ethical behaviour and personal and professional integrity are inseparable with our activities.
5. ommittment to excellence and ESG values

LB is committed to a truthful and honest business approach: an upright and transparent conduct, performed with prudence and professionalism and a thorough understanding of the industrial and technological renting and leasing finance structures, with a focus on the confidence that our stakeholders and clients have placed in us. 

Breaches of this Code may give rise to disciplinary procedures in accordance with applicable labour laws, apart from any possible applicable legal responsibilities, in addition to internal disciplinary measures.

LB staff undertakes to:

• Observe at all times the behaviour guidelines set out in this Code.
• Raise to the in-house compliance officer and management any doubts as to conduct with clients or in a business transaction, in particular, in the event of a conflict with the rules set out in this Code, or any other applicable internal regulations, report immediately to Compliance by sending an email to: Ccorporativo@lbrent.es
• Act in the manner of a diligent manager at all times, following industry standards and practices, common sense and an honest and upright approach.
• Ensure that any actions or conduct are in compliance with applicable laws, regulations and business standards applicable to our sector, as well as our overarching corporate values
• Commit to excellence: train, research and focus on client development and follow up, to allow us to stay ahead of market and client needs

Table of Contents

1. Conduct with the client
2. Conduct with our colleagues
3. Conduct within the company
4. Conduct with society
5. Application of the Code

1. Conduct with the client

• LB pinpoints client´s interest as the center point of our performance and actions. We seek to establish long-lasting relations, based on mutual trust and respect, maximum professionalism and added value propositions.
• Transparency and client knowledge: understanding of the client´s business and needs is key to our approach. Transparency in our exchanges and communications, as well as expectations, will ensure the absence of conflicts and a smooth approach to the client´s goals.
• When liaising with our clients, plain language and explanations, with a focus on proper understanding by all of any risks involved in a transaction, will be used at all times. We will endeavour to offer a straightforward approach to all issues raised by a client, with understandeable methodologies and processes.
• We will seek to avoid potential conflicts of interest in our relationship with clients, and follow existing internal policies in this context at all times.
• We will not discriminate access to our products and
• We shall assess risk on a consistent basis in accordance with internal risk analysis protocols, on a non discriminatory basis, with professionalism and ethic.
• We shall follow the internal regulations as to restricted sectors, seeking to avoid contact or liaison of any kind with illegal actions or sectors.
• Our relationship with clients will be set out in writing, with clear indication of our scope of work, limitations on liability, relationship with third parties and group companies, and pricing.

2. Conduct with our colleagues

• Our clients trust us because LB trusts its team: acting as a colleague, being part of the company and encouraging team effort and values is a core aspect of LB´s approach to its work environment.
• Diversity is key to our expertise and capabilities, our team integrates different cultures and backgrounds to enrich our know-how and approach to problem solving
• No discrimination policy:
  • We do not discriminate or allow others to discriminate by reason of gender, race, age, nationality, religion, sexual orientation, disability, family origin, language, political ideology, political or trade union affiliation or any other characteristic.
  • We avoid any form of harassment, whether sexual, workplace bullying or
  • Respect between fellow : We behave towards our fellow colleagues in the same way as we expect them to behave with us.
  • A correct communication between fellow colleagues is essential and rules our
  • Objectivity and strict approach to personnel selection processes and evaluation and/or promotion.
  • We encourage, respect and comply with the rules on safety and health in the We report any situation which we consider is not safe or is potential health hazard.
• Our employees well being is cared for: measures allowing conciliation of personal and professional interest are in place and available to all, to ensure personal wellbeing as well as professional growth.

3. Conduct within the company (1)

• We observe all internal codes and rules so that we ensure we are compliant with them at all times.
• There are procedures in place to ensure that any concerns of employees can be raised and resolved confidentialy without repercussion for disclosure.
• We ensure we are accurate and transparent in our internal communications, We account, register and correctly document all operations, income and expenses, without omitting, hiding or altering any data or information. Our accounting and operating records faithfully reflect reality and can be verified by the control areas and responsible internal and auditors.
• When we receive an official notice, demand or injunction from administrative, regulatory or legal authorities, we will immediately notify it to the competent area. We collaborate with supervisors, administrative and judicial authorities attending to their demands and requests for information swiftly and precisely.
• E-mail and computer tools are work instruments that must be used to develop the labour functions in place with legal rules, common sense, ethics and the spirit of this Code and the Employee Handbook. To comply with its obligations, LB may access, monitor and review our activity in those tools and also the information stored there or transmitted with them.
• We respect intellectual and industrial property of third party products and
• We respect free competition in its broadest
• Information about clients, employees or any third party is confidential; we observe it and take the necessary measures to gather, store and access tdata in accordance with applicable rules, avoiding undue access and complying with corporate policies on the matter, including monitoring of confidentiality undertakings and establishing information barriers where required to preserve client interests. Confidentiality remains in place after contract termination for all LB employees.

3. Conduct within the company (2)

• We apply a responsible corporate expenses policy
• We abide by conflict of interests internal policy at all times, to prevent a personal, family or friendship situation or any other kind of external circumstance from affecting our conduct.
• We have a hospitality and gifts policy in place within LB to prevent undue influence on clients or from clients.
• We do not develop professional activities that may collude or compete with those of LB. Before starting to perform any professional activity other than our work at LB, we will formally notify our superiors about this.
• Information about the results and evolution in LB’s business is drafted and communicated by its management bodies and is their responsibility.
• We will make public statements in a responsible, respectful and precise way, following the guidelines established by the Company’s management bodies and respecting the confidentiality of the Company’s information and that of its clients.
• We are responsible in our interactions in social networks and apply the same measures and guidelines as for any other type of corporate communication. Likewise, we are mindful of LB´s reputation and standards in our personal interactions on social networks.
• We are careful with the resources, technical or otherwise, provided by the Company and care for our office, furniture and computers and assets as if they were our own, making sure that no undue access or data breach can take place at any time.

4. Conduct with society (1)

• Our responsibility is to contribute with our work towards the progress and sustainable development of society, its citizens and institutions.
• We carry out a KYC of our clients, in accordance with our internal policies and local laws. We have measures in place to ensure that illegal activities are not channeled through us or with our assistance, so that the financial system is not affected.
• LB in no way tolerates corruption or
• We do not offer or directly or indirectly make any kind of payment, gifts, bonuses, donations, job offers, sponsorships, preferential treatment or any class of benefits, the object of which is to influence or to try and influence, to obtain a benefit or unjustified advantage, in decisions by third parties, private individuals, civil servants or authorities, with regard to LB’s activity or in respect of the persons who work at LB. Our gifts and hospitality policy ensures standard market practice and regulations are complied with in this context.
• All expenses and revenue shall be duly reported for their accounting, documented and authorised. They shall be proportionate, respond to services effectively provided and to a legitimate economic objective.
• We do not employ the services or pay commissions to agents or third parties to carry out actions that are prohibited under this Code.
• We conduct arm´s length relationships with all our suppliers.
• We report any suspicious action to
• We report any suspicious action to Management.

4. Conduct with society (2)

• LB respects human rights according to the International Bill of Human Rights, the United Nations Global Compact and the principles of action and recommendations for the development of the business activity published by the United Nations, the Organisation for Cooperation and Economic Development and the International Labour Organisation.
• We have a restricted sectors policy in place in line with international standards used by financial entities.
• We are responsible with our surroundings and environment. We comply with all applicable laws and regulations in this area.
• We ensure timely compliance with our tax, social security and labour law responsibilities in addition to all other laws and regulations applicable to our services.
• Our communications are transparent and simple, so as to avoid product misunderstanding and fraudulent publicity.
• We maintain a commitment of political

5.- Application of the Code

• This Code of Conduct applies to all of LB´s employees and external collaborators, whether in their interactions as colleagues, with management, with third party advisors or with clients and public institutions.
• Any discrepancy in conduct, contravention or mismanagement of these principles and the Code shall be reported to the Compliance Officer through e-mail to ( Ccorporativo@lbrent.es). The Compliance Officer shall analyse the complaint and report it to General Management and, if applicable, the Board.
• Reports on misconduct will be objectively, impartially and confidentially analysed, with strict secrecy as to the identity of the person reporting such conduct. The analysis of the conduct and its potential repercussions will be carried out by the relevant persons on a need-to -know basis, so as to preserve anonymity and avoid prejudice to the person reporting. Results of the relevant enquiry will be reported to the areas affected so that correction action may take place, and implementation of such corrective action will be monitored by the Compliance Officer.