Code of Ethics

1. Introduction

The HLM Group (Holmusic) is committed to operating in accordance with a set of ethical and behavioral principles that ensure the social responsibility expected of every company and uphold an impeccable reputation. Clarifying, communicating, adhering to, and updating these principles is an essential part of how we work.

This Code of Ethics sets forth our commitments to the people who make up HLM, to our customers, to our suppliers and business partners, and to the sustainability of society and the environment in which we operate.

HLM maintains a zero-tolerance policy regarding violations of these principles and any unethical behavior, both within the company and within its sphere of influence.

2. Purpose, Scope, and Term of Effecta

This Code applies to all companies in the HLM Group, including HOL MUSIC DRAL, S.L. and HOL MUSIC ITALY, S.R.L., as well as any current or future subsidiaries of the group.

Everyone in the organization, its governing bodies, and the external entities that collaborate with us are committed to understanding and adhering to these guidelines for conduct in the course of their professional activities with HLM.

These values and policies emanate from the Board and Senior Management, who are expected to set the highest standard of example and commitment. HLM will keep the Code up to date and make it available to anyone, both inside and outside the company, by publishing it on its websites, the intranet, and the employee portal.

3. Pillars and Values

The Code establishes mandatory minimum standards for all our internal and external partners, in any situation and in any country. Each individual, supplier, or customer may go beyond these standards with their own actions or policies that are consistent with these principles.

The Code is based on three pillars:

The protection of internationally recognized human rights.
Compliance with national and international law, always taking into account its purpose.
The values that inspire HLM’s vision and mission.

In situations not expressly provided for that require a decision, that decision is expected to be guided by the Company’s principles and values.

4. Our Commitments to Conduct

4.1. With our team

Everyone on our teams—including employees and external collaborators—is committed to upholding and respecting the following principles:

To ensure equal opportunities and non-discriminatory treatment on the basis of origin, race, color, gender, religion, disability, sexual orientation, gender identity, political opinion, union membership, or any other status, while promoting diversity and inclusion.
Respect people’s dignity, integrity, and personal lives, and do not tolerate any form of intimidation, offense, abuse of power, or harassment.
To foster active dialogue and the participation of our people in everything that improves our day-to-day relationships.
Work as a team, supporting others and prioritizing collective success.
To provide the training necessary for individuals’ professional development.
Ensure a safe and healthy work environment by safeguarding the safety and health of the teams.
To help employees balance their professional and personal lives.
Recognize people’s achievements using merit-based criteria.
Use the Company’s resources responsibly, taking care of its assets and information.

HLM has an Equality Plan and a protocol for preventing and addressing sexual harassment and gender-based harassment, and is committed to equal pay for women and men.

4.2. With our customers

Those who interact with our customers agree to:

To develop long-term relationships based on trust, mutual respect, transparency, and confidentiality.
Strive for excellence by offering the best possible service and clear, precise proposals.
To provide honest, professional, and transparent advice, based on accurate information and technical criteria.
Respect competitors by refraining from criticizing, defaming, or disparaging them.
To ensure the quality, diversity, innovation, and value of the products and services we offer.
Resolve disputes by prioritizing dialogue, and refrain from using any illegal, corrupt, or unethical means to attract customers or provide services.

4.3. With our suppliers and business partners

The quality of what we offer depends largely on our suppliers, so the selection process must be transparent and meticulous. HLM promotes among its suppliers and subcontractors the same standards of ethics, integrity, and quality that it applies to its employees and customers. As a distributor, HLM works with numerous suppliers; it will ensure that its distribution and supply agreements incorporate this Code or its implications, and expects its suppliers to adhere to the following principles:

Promote respect for human rights throughout the entire value chain, including its subcontractors.
Strictly comply with applicable regulations and laws.
Treat the information they receive from HLM confidentially and responsibly.
Provide products and services that meet the specifications, and promptly report any problems that are detected.
Ensure equal opportunities and reject all discriminatory practices.
Protect its employees from any form of harassment or abuse, and ensure their safety and health.
Respect the Fundamental Rights of the International Labor Organization: no child labor or forced labor; wages and working hours in accordance with the law; freedom of association and collective bargaining; and safe working conditions.
Respect the environment by complying, at a minimum, with the applicable laws in each country.b
Refrain from any illegal or corrupt activity, particularly that intended to influence HLM’s decisions in a non-transparent manner.

Fairness and impartiality must guide our relationships with suppliers, within a framework of impeccable ethics and compliance with competition laws.

4.4. Integrity in Business

HLM competes and operates with integrity. Everyone in the organization is committed to:

Prevention of corruption and bribery: Do not offer or accept payments, gifts, or benefits that could unduly influence a decision, in accordance with the Integrity and Independence Policy (Appendix I).
Gifts and hospitality: Accept or offer only reasonable courtesies that are customary in business practice and always transparent, within the limits set forth in Annex I.
Conflicts of interest: Avoid situations in which personal interests might interfere with those of HLM, and report them when they arise.
Fair competition: Comply with antitrust laws and regulations, and refrain from any agreements or practices that restrict competition.
Prevention of money laundering: Reject any transaction with a suspicious origin or purpose and comply with applicable regulations.
Accuracy of information: to ensure that transactions are recorded completely, accurately, and in a timely manner in the Company’s records and financial statements.

4.5. Protection of Information and Assets

HLM’s information and assets, as well as those of third parties, deserve special protection. We are committed to:

Confidentiality: Protect HLM’s confidential information, as well as that of clients and suppliers, and use it only for authorized purposes.
Personal Data Protection: Process personal data in accordance with applicable regulations and HLM’s Privacy Policy.
Intellectual and industrial property: Respect your own rights and those of third parties regarding trademarks, content, and software.
Responsible use of systems and assets: Use the Company’s resources, equipment, and systems diligently and for professional purposes.
Social Media and Communication: Act responsibly in public communication and on social media, without compromising HLM’s image or information.

4.6. Sustainability and the Environment

HLM feels a responsibility to contribute to the long-term sustainability of society and the planet, not only by respecting the environment but also through active policies aimed at improving it.

With society and its institutions

To contribute to the economic development and well-being of the society in which we operate, with a focus on groups at risk of exclusion.
To participate in the market while complying with competition laws and prioritizing dialogue over conflict.
To provide accurate and transparent information on the Group’s economic, social, and environmental performance.

Through music and our community

To sell high-quality products that perform as expected.
To promote access to music and support the community of musicians, both professionals and amateurs.
Promote responsible listening and the protection of hearing health by providing information on the proper use of equipment.

With the environment

Comply with current environmental regulations and promote respect for the environment among our teams and at our facilities.
Reduce the direct impact of our operations (waste, emissions, energy and water consumption, and packaging) and minimize the use of raw materials.
Favorecer la recogida selectiva y el reciclaje, y reducir el impacto indirecto de nuestra actividad.

5. Governance of the Code

HLM develops, communicates, and implements the policies and procedures necessary to enforce this Code. Compliance with this Code is mandatory, and all actions must be conducted in an ethical and lawful manner at all times.

The Ethics and Compliance Committee ensures the dissemination of and compliance with the Code, resolves questions regarding its interpretation, and oversees the Internal Reporting System. Failure to comply with the Code may result in the disciplinary measures provided for and, in the case of third parties, in the termination of the relationship.

Given its importance, the Policy on Integrity and Independence (Appendix I) is included in this document.

6. Internal Reporting System (Whistleblower Channel)

HLM has an Internal Reporting System that allows employees to confidentially report any conduct that violates the law, this Code, or internal policies, in accordance with Law 2/2023 and Directive (EU) 2019/1937.

Anyone, whether an employee or an external party, can report incidents via email at [email protected]. The system allows for both identified and anonymous reports, and guarantees the confidentiality of the reporter’s identity and that of the individuals involved in all cases.

HLM guarantees that there will be no retaliation against anyone who reports in good faith. Reports made knowingly with false information are not covered by this protection.

The System Manager will acknowledge receipt of the report within seven calendar days and will conduct an investigation within a maximum of three months, which may be extended for justified reasons. The System Manager will review each case and, when appropriate, refer it to the Ethics and Compliance Committee, which will decide on the measures to be taken.

APPENDIX I. Policy on Integrity and Independence

To avoid conflicts of interest, the HLM team will comply with all anti-corruption and anti-bribery regulations. It is prohibited to offer or accept gifts or payments intended to influence a decision regarding the HLM Group. As a general rule:

No compensation, gift, or gratuity from clients, suppliers, or third parties that affects or could affect the responsible performance of professional duties will be accepted.
No compensation, gift, or gratuity will be offered to customers, suppliers, or third parties for that purpose.

Any gift received by an HLM employee with an estimated value exceeding €150 must be reported to their direct supervisor and the Human Resources Department. In such cases, the Human Resources Department may manage the gift and allocate it to internal initiatives aimed at improving the work environment.

Invitations to meals related to a business event and unsolicited promotional gifts (pens, calendars, and similar items) bearing a supplier’s logo are considered standard practice. Any travel, meal, or gift not included in the Company’s promotional programs will require prior authorization from General Management and must comply with the law.

Cash payments and receipts must, in all cases, comply with the limits established by current legislation. In transactions in which one of the parties is a business or a professional, the law does not permit cash payments equal to or greater than €1,000. In transactions with individuals, any cash payment exceeding €2,500 may only be made after notifying the appropriate department in advance.