This document defines the values and principles of conduct significant for N3XT Sports Europe, S.L (hereinafter also referred to as – “N3XT Sports”) for the purpose of good functioning and decision making, of the reliability and compliance to laws and regulations as well as the reputation of N3XT Sports as a sports agency propelling the Sports industry. It describes the standards of ethical and business conduct expected of N3XT Sports employees, collaborators and, in general, everyone who operates in the name of and for N3XT Sports (hereinafter also jointly referred to as – “Addressees to the Code”).

All Employees may be required to attest annually to their awareness and acceptance of this code and to affirm their compliance with its provisions. All Collaborators and, in general, everyone who operates in the name of and for N3XT Sports may be also required to affirm their compliance with its provisions.

This Code provides guidelines for ethical and professional conduct. Addressees to the Code must exercise sound judgment and common sense in interpreting and applying these standards in any given situation. In case of doubt, they should consult with the company’s top management or a Director.

The Company assures the privacy of the data it owns using them in compliance with the existing juridical regulations.

N3XT Sports employees, collaborators and, in general, everyone who operates in the name of and for N3XT Sports are required not to use confidential information for purposes other than those connected to the performance of their activity.

In carrying out any activity, the employees, collaborators and, in general, everyone who operates in the name of and for N3XT Sports have to avoid situations that can result in a conflict of interest which can influence the impartial and ethical conduct of the subjects. The subjects that find themselves in a situation of conflict of interest, even if only potential, have to promptly inform their top management or Directors of N3XT Sports that will evaluate the action to be taken.

During the development of relationships, the Addressees to the Code have to give complete, transparent, comprehensible and accurate information, in order to enable the interested parties to make autonomous and conscious decisions aware of the involved interests, the alternatives and relevant consequences.

In particular, during the formulation of any kind of agreement, N3XT Sports will ensure to specify to the contractor, in a clear and comprehensible way, the conduct to adopt during the established relationship.

It is not allowed for the Addressees to the Code to offer or receive to/from anyone, any gift that could be barely interpreted as exceeding the normal commercial or courtesy practices, or else being intended as to acquire special treatments in carrying out any activity that can be linked to the Company.

In particular, it is prohibited to make any kind of gift to Public Officials – being national or foreigners – or to their parents or relatives. In Countries where it is usual to offer gifts to clients or other subjects as an act of courtesy, these gifts have to be of appropriate nature and value, not contrasting with the Juridical and Regulatory dispositions therein in force and not being in any case construable as compensation during the request of favors and/or facilitations.

In the event that the Addressee to the Code receives offers and/or requests of presents or benefits – except for commercial uses or of small value – he is obliged to inform the company top management or a Director.

The Company’s activities have to be managed in full respect of the legislation in force in the field of prevention and protection. At N3XT Sports, we recognize the importance of reducing our environmental impact and promoting sustainable practices in the sports industry.

With regards to Corporate Citizenship, we take into consideration the following measures in our working space and travel commitments in order to reduce our carbon footprint:

1. Use of energy-efficient equipment and appliances in our office

2. Reduction of paper usage by digitizing documentation and communication wherever possible.

3. Central office location to encourage the adoption of eco-friendly transportation options, such as biking or public transportation.
4. Traveling out of the country with as few staff as possible, and wherever possible traveling by public transportation.

As we continue our commitment to leveraging N3XT Sports, we have created a rich network of partnerships with higher education institutions in order to contribute to the professional development of young professionals.

Since 2018, N3XT Sports has invested time and resources in sharing its expertise and deep knowledge in the field of Digital transformation, Sports Business, and Technology; and shall put the best effort to follow the same practices in the future.

N3XT Sports promotes the health and safety culture at work, confirming with its highest commitment to guarantee this culture in its own structure. The company is dedicated to achieving and sustaining the safety of the working stations and environment for every employee.

Management of safety at work is focused on prevention. The Company supplies to its employees a yearly medical check up training, general and specific information and every other support that allows working in healthy and safe working conditions, in accordance with the requirements provided under the legislation of Country of establishment of N3XT Sports. N3XT Sports is ready to make the evaluation of risks to be implemented, and make adequate corrective measures to be adopted in order to avoid health, human safety and business risks.

In that spirit, we note that our office in Valencia is accessible for anyone using mobility devices.

The evaluation of the personnel to be employed is carried out on the basis of the matching of the candidates’ profiles with the ones expected and with the business needs, in accordance with the equal opportunities for all interested parties. The requested information is strictly connected to the audit matters provided for the professional profile, in compliance with the privacy and the opinions of the applicant. Within the limits of available information, the company’s operations adopt appropriate measures to avoid favoritism, nepotism or other forms of cronyism during the phases of selection and recruitment.

Employees are employed with a regular working contract. With the creation of the working relationship, each employee has to receive accurate information about:

• Characteristics of the working functions, role responsibility and job description;

• Normative and remuneration elements, as regulated by the collective National labor agreement;

• Norms and procedures to adopt in order to avoid behaviors against statutory rules and company policies.

This information shall be presented to the employee through the employee handbook such that a proper understanding can be at the base of the job taking.

Each department is in charge of valorizing the working time of the employees requesting services that are coherent with the performance of their duties and with the organization of the working schemes.

It is an abuse of the authority position to request, as an act owed to the hierarchic superior, performances, which do not fall under the respective employment contract, personal favors or any behavior that represents a violation of the present Code.

The involvement of the employees in the working performances is ensured, including also moments of participation to discussions and decisions instrumental to the realization of the business objectives. The employee has to participate in these moments with cooperative spirit and independence of judgment.

Each Department as well as the company top management have to make the best use of and valorize fully each professional present in the organization through activating the levers available to favor the development and growth of its employees. N3XT Sports shall provide to all employees information and training tools with the objective to valorize the specific competences and implement the occupational values of the personnel. During certain moments of the professional life of the employee an institutional training might be performed (for example, for the new entrants, training about safety at work, about the corresponding risk prevention, and an introduction to the Company and its business), while for the operational staff recurrent trainings might be organized.

The collaborator’s privacy is protected by the adoption of standards that specify the information that the company requires from the collaborator and the ways to store and handle them. Investigations about ideas, preferences, personal tastes and, in general, the collaborators’ private life is excluded. Furthermore, without prejudice to the hypothesis provided for by law, these standards include the prohibition to communicate/disclose personal information without having the consent of the data subject and establish the rules for the control of the norms of the privacy protection by each collaborator.

The relations with clients have to be characterized by fairness, courtesy and helpfulness. The Company undertakes to supply, with efficiency and courtesy, within the limits of the contracts, products of high quality that satisfy or exceed the reasonable expectations of the client. Moreover, it is committed to supply accurate and exhaustive information about the work undertaken and deliverables such that the client can make conscious decisions. Every contractual relation activity with the clients may be documented and traceable. The customers’ satisfaction is a primary resource. That’s why the Company implements measures and procedures to verify and assess whether the clients are satisfied with the deliverables so as to continuously improve the level of the commercial offer and to remedy possible cases of dissatisfaction in a rapid way.

The Code is communicated both to the internal and external interested parties of the Company, through appropriate communication and diffusion activities on the intranet and Internet networks. The Code is distributed to all employees during the recruitment phase and to every third party that enters in business relationship with N3XT Sports. Internally, training and informational programs ensure the adequate knowledge and understanding of the Code.

It is the right of any employee to suggest potential needs of revision of the Code of ethics.