1. Introduction
At HLM Group, we believe that sustainable business success can only be achieved through integrity, respect, responsibility, and compliance with the law. Our commitment extends beyond delivering high-quality products and services; we strive to conduct our business ethically, transparently, and responsibly, building long-term trust with our customers, suppliers, employees, business partners, and the communities in which we operate.
This Code of Ethics establishes the principles and standards of conduct that guide all activities carried out by HLM Group. It serves as a reference for decision-making at every level of the organization.
Integrity is a fundamental part of our corporate identity. Accordingly, HLM maintains a zero-tolerance policy towards unlawful, fraudulent, or unethical behaviour.
2. Purpose, Scope and Applicability
This Code of Ethics applies to all companies within HLM Group, including HOL MUSIC DRAL, S.L., HOL MUSIC ITALY, S.R.L., as well as any current or future subsidiaries or affiliated companies.
Compliance with this Code is mandatory for:
Everyone covered by this Code is expected to understand, respect and comply with its principles.
The Board of Directors and Executive Management are committed to leading by example and promoting a strong ethical culture throughout the organization.
This Code will be reviewed periodically to ensure its compliance with applicable legislation and internationally recognized best practices in corporate governance.
3. Our Core Values
Our business activities are guided by five fundamental values.
Integrity
We act honestly, independently and responsibly in every decision we make.
Respect
We treat every individual with dignity, fairness and respect, fostering an inclusive workplace free from discrimination.
Excellence
We pursue continuous improvement, innovation and the highest standards of quality in our products and services.
Transparency
We communicate openly, honestly and responsibly with all our stakeholders.
Sustainability
We conduct our business with a long-term perspective, creating positive value for society while minimizing our environmental impact.
4. Compliance with Laws and Regulations
HLM Group conducts its business in full compliance with all applicable laws and regulations in every country where it operates.
Every individual is responsible for understanding the legal requirements relevant to their role and for acting accordingly.
Whenever uncertainty exists regarding legal or ethical obligations, guidance should be sought before making a decision.
Lack of knowledge does not exempt anyone from compliance.
5. Our Commitments
5.1 Our People
People are our most valuable asset.
We are committed to:
HLM Group maintains an Equality Plan and a Protocol for the Prevention of Sexual Harassment and Harassment Based on Sex, while actively promoting equal pay for equal work.
5.2 Human Rights
HLM Group respects and promotes internationally recognised Human Rights.
We reject any form of:
We expect the same commitment from our suppliers, contractors and business partners.
5.3 Our Customers
Our relationships with customers are built on trust.
We are committed to:
5.4 Suppliers and Business Partners
We select suppliers based on objective criteria such as quality, capability, sustainability and integrity.
We expect them to uphold the same ethical standards that guide our own business.
They are expected to:
All commercial relationships shall be governed by fairness, objectivity and free competition.
5.5 Business Integrity
HLM Group conducts all business activities honestly and ethically.
Everyone within the organization must:
5.6 Conflicts of Interest
Business decisions must always be made in the best interests of HLM Group.
Examples of conflicts of interest include:
Any actual or potential conflict of interest must be reported immediately to Management.
5.7 Information and Asset Protection
Information is one of HLM Group’s most valuable assets.
Everyone is expected to:
Cybersecurity
Employees and collaborators shall protect passwords and credentials, prevent unauthorized access, follow cybersecurity best practices and immediately report any security incident.
Responsible Use of Artificial Intelligence
Artificial Intelligence tools shall be used responsibly and exclusively for legitimate business purposes, respecting confidentiality, personal data protection regulations, intellectual property rights and the internal policies of HLM Group.
5.8 Sustainability
Sustainability is an integral part of our long-term business strategy.
Society
We are committed to:
The Music Community
We strive to:
Environment
HLM Group works continuously to reduce its environmental impact by:
6. Governance
HLM Group will implement the policies, procedures and controls necessary to ensure compliance with this Code of Ethics.
The Ethics and Compliance Committee is responsible for:
Failure to comply with this Code may result in disciplinary measures or, where applicable, termination of the business relationship.
7. Internal Reporting System (Whistleblowing Channel)
HLM Group operates an Internal Reporting System that allows employees and third parties to report, confidentially and, where legally permitted, anonymously, any conduct that may violate applicable laws, this Code of Ethics or internal company policies.
Reports may be submitted via:
HLM Group guarantees:
The System Manager will acknowledge receipt of the report within seven calendar days and investigate the matter in accordance with Spanish Law 2/2023 and Directive (EU) 2019/1937.
ANNEX I – Integrity and Independence Policy
HLM Group maintains a zero-tolerance policy towards bribery, corruption and conflicts of interest.
As a general rule:
Everyone representing HLM Group is expected to act with independence, objectivity, honesty and integrity in every professional relationship.
