Ind

Code of Conduct and Responsible
Practices
Inditex Group
July 2012
2
Index
1. Definition and goals of the Code of Conduct and Responsible Practices……………..3
2. Scope of application …………………………………………………………………………………….3
3. General principles………………………………………………………………………………………..4
4. Conduct and responsible practices commitments …………………………………………….5
4.1. Compliance with applicable laws and internal regulations…………………………5
4.2. Enforcement of agreements and conventions …………………………………………6
4.3. Relationship with employees ………………………………………………………………..6
4.4. Relationship with customers …………………………………………………………………6
4.5. Market practice …………………………………………………………………………………..7
4.6. Relationship with suppliers …………………………………………………………………..8
4.7. Relationship with public authorities and servants …………………………………….8
4.8 Conflicts of interest ………………………………………………………………………………9
4.9 Exercise of other activities…………………………………………………………………..10
4.10 Use of goods and services of the company………………………………………….10
4.11 Confidentiality of information and personal data protection…………………….11
4.12 Protection of intellectual and industrial property ……………………………………12
4.13 Record of transactions………………………………………………………………………12
4.14 Social and environmental commitment………………………………………………..13
5. Code Compliance and Committee of Ethics…………………………………………………..13
5.1. Committee of Ethics…………………………………………………………………………..13
6. Publicity of the Code…………………………………………………………………………………..14
Schedule I: Codes and global commitments willingly undertaken by Inditex…………..15
Schedule II: Definitions…………………………………………………………………………………..16
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1. Definition and goals of the Code of Conduct and Responsible Practices
Inditex’s “Code of Conduct and Responsible Practices” (hereinafter, the “Code”) is the
updated and consolidated version in a single document of two codes: the “Internal Code of
Conduct” and the “Internal Guidelines for Responsible Practices”, which were approved by
the Board of Directors of Inditex, S.A. in 2001 and 2006, respectively.
The Code provides the action lines which must be followed by the Inditex Group (hereinafter,
“Inditex” or the “Company”) and its employees in the performance of their professional duties.
The goal of this Code consists of exacting an ethical and responsible professional conduct
from Inditex and its entire workforce in the conduct of their business anywhere in the world,
as a gist of its corporate culture upon which the training and the personal and professional
career of its employees is based. For such purposes, the principles and values which shall
govern the relationship between Inditex and its stakeholders (employees, customers,
shareholders, business partners, suppliers and the societies where its business model is
implemented) are defined.
Therefore, the Code:
 Allows gaining awareness and enforcing Inditex’ s business culture, deeply rooted
in respecting human and labour rights and in the effective inclusion within the
company of the whole group of employees, respecting their diversity.
 Lays down the principle of due diligence regarding the prevention, detection and
removal of irregular conducts, regardless of their nature, including, among others,
risks review, definition of liabilities, training of employees and, where appropriate,
of third parties linked to the company, and procedures standardization, namely to
give notice and to immediately remove irregular conducts.
 The Code takes into account the principle of criminal liability of legal persons,
addressed in the legal system of different jurisdictions where Inditex operates, and
prevents and forbids the existence of any behaviour which may entail that the
company is deemed to be liable, from its legal representatives, directors, employees
or any other party under the authority of any staff member.
2. Scope of application
The Code applies to all the companies which form Inditex and it is binding for their whole staff,
regardless of the office they hold and the duties they perform.
The enforcement of the Code, in full or in part, may extend to any physical and/or natural
person linked to Inditex, where this is expedient to achieve its goal and possible, given the
nature of the relationship.
Notice of this Code shall be given in person to all the Directors, Officers and any other person
representing Inditex, where the type of relationship with the company so requires, and they
shall undertake in writing to abide by it. Likewise, this obligation to enforce the Code shall be
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expressly provided in the employment agreements entered into with the employees, who will
receive a copy of the Code upon joining the company.
The exemption from the obligation for specific cases duly evidenced may be authorized by the
Committee of Ethics exclusively, which shall report such fact, as soon as possible, to the Audit
and Control Committee.
3. General principles
The Code of Conduct is defined as an ethical commitment that includes basic principles and
standards for the proper development of the relations between INDITEX and its principle
stakeholders wherever it carries out its business activities.
The Code is based upon the following principles:
 All the operations of the Inditex Group shall be developed under an ethical and
responsible perspective.
 Compliance with laws and regulations of each country.
 The conduct of Inditex’s employees shall follow in letter and spirit the provisions of this
Code of Conduct and Responsible Practices.
 All persons, whether natural or legal, who maintain, directly or indirectly, any kind of
professional, economic, social or industrial relationships with Inditex shall be treated in
a fair and honourable manner.
 All the activities of Inditex shall be carried out in the manner that most respects the
environment, promoting biodiversity preservation and sustainable management of
natural resources.
Employees
The Inditex Group does not employ anyone who has not reached the age of 16.
No one who is employed at Inditex shall be discriminated against because of their race,
physical disability, illness, religion, sexual orientation, political views, age, nationality or
gender.
Inditex forbids any manner of physical, sexual, psychological or verbal harassment or abuse
to its employees, as well as any other behavior which may create an intimidating, offensive or
hostile environment
The employees of Inditex have their right recognised to associate or organise themselves or
to bargain collectively.
Working hours and overtime shall not exceed the statutory limit set forth in the laws and
regulations of each country. Overtime shall always be voluntary and paid according to law.
Inditex’s employees are paid wages in accordance with the duties performed, always
respecting the agreements of each sector in each country.
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All Inditex’s employees perform their work in safe and healthy workplaces.
Customers
Inditex undertakes to offer to all its customers a high standard of excellence, quality and safety
in all its products, and to have a smooth and transparent communication with them. Such
products shall be manufactured in an ethical and responsible manner.
Shareholders
Inditex will perform its activity pursuant to the social interest, it being understood as the
feasibility and maximization of the company’s value in the long run in the common interest of
all the shareholders.
Business partners
Inditex´s business partners are bound to comply with the contents of this Code.
Suppliers
Manufacturers which produce the goods sold by Inditex are bound to comply with the Code of
Conduct for Manufacturers and Suppliers and with this Code, as applicable. The remaining
suppliers of goods and services for Inditex shall comply with both Codes, as applicable to
them.
Likewise, they shall allow any monitoring by Inditex or any authorised third parties, to verify
such compliance.
Society
Inditex undertakes to collaborate with the local, national and international communities where
it operates.
4. Conduct and responsible practices commitments
4.1. Compliance with applicable laws and internal regulations
Regulatory compliance is a prerequisite of this Code. Inditex’s workforce must comply with
all applicable laws and regulations in each and every country where Inditex manufactures,
distributes and sells its products. Enforcement of this Code shall in no event entail infringing
any of the prevailing legal provisions in force in any country where Inditex operates.
Inditex’s workforce shall comply with the internal regulations and procedures of the
company, and follow the directions which may be given in the implementation thereof.
Any existing local Codes of Conduct shall be aligned with and meet the standards
hereunder provided and this Code shall prevail over any other internal regulation, unless
this latter is more exacting. Such local Codes and any implementing instruments need to
be approved first by the Audit and Control Committee.
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For the sake of due internal control, decisions of Inditex’ employees shall be traceable from
the perspective of regulatory compliance; therefore, where such decisions are reviewed by
any authorised third party or by the company itself, their adjustment to internal and external
regulations need to be evidenced and verified.
Inditex undertakes to provide all required means for its employees to be aware of and to
understand the internal and external regulations required for the performance of their
duties.
In the event of any breach of this Code, the Company relies on a procedure to make
enquiries and to give notices which allows anyone involved with the company to report in a
confidential manner any irregularity which may entail an infringement of the Code.
4.2. Enforcement of agreements and conventions
Inditex makes its own, as part of its internal regulations, the contents of any national and
international agreements and conventions to which it has adhered, and undertakes to
promote and enforce them.
A list of the main agreements and conventions to which Inditex has adhered is attached
hereto as Schedule 1, which shall be updated at all times.
4.3. Relationship with employees
Inditex considers individuals to be a key business factor, it upholds and promotes
observance of human and labour rights and undertakes to enforce the regulations and best
practices in the field of employment conditions and health and safety at work.
The workforce shall contribute to the strict observance of applicable employment standards
and to the prevention, detection and removal of any irregularity with this respect. All
employees shall be bound to interact with other employees, pursuant to criteria of respect,
dignity and justice, taking into account the different cultural background of each individual,
without allowing any manner of violence, harassment or abuse in the work place, or any
manner of discrimination on account of race, religion, age, nationality, gender or any other
personal or social condition beyond qualifications and capacity, especially considering
attention and assimilation into working life of disabled or handicapped people.
All employees shall be responsible for strictly meeting any health and safety at work
standards and for ensuring their own security and that of the individuals affected by their
activities.
The use of any substance which may have a negative effect on the due performance of
professional obligations is expressly forbidden.
4.4. Relationship with customers
All employees shall be bound to act, in their relationship with customers, pursuant to criteria
of respect, dignity and justice, taking into account the different cultural background of each
individual, without allowing any manner of discrimination on account of race, religion, age,
nationality, gender or any other personal or social condition beyond qualifications and
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capacity, especially considering attention and assimilation into working life of disabled or
handicapped people.
Inditex protects its customers by setting forth and enforcing mandatory standards on all its
suppliers in the field of health and safety of the product, and ensures that all goods it sells
are not hazardous for their health and or safety. Inditex’s employees shall make sure that
the above referred standards are duly met, as well as any other standardised regulations
and procedures, regarding labeling, quality and features of garments.
In the course of their business activities, Inditex’s employees shall promote goods of the
company based upon objective standards, without distorting their description or features.
The company shall carry out promotional activities in a honest manner so as not to provide
false or deceptive information which may mislead its customers or third parties. Likewise,
contents shown in every promotional and advertising support shall present or promote the
image of a healthy individual, preventing presenting cut off from reality stereotypes.
Inditex’s workforce shall ensure the security of any and all means of payment used at the
company’s stores, whether physical or online stores, to ensure the appropriate working and
traceability of invoicing and collection procedures, data protection regarding its customers
and fraud prevention.
4.5. Market practice
Inditex is a loyal competitor within the market and it does not admit any misleading,
dishonest or malicious conduct whatsoever.
Inditex’s employees shall carry out any search for commercial or market information without
infringing any regulations protecting it. Employees shall reject any information about any
competitor improperly gathered or gathered in breach of the confidentiality kept by the
lawful owners of such information. Namely, especial attention shall be drawn to not
breaching any secret of the company where professionals from other competing companies
of the sector would join Inditex.
Workforce shall likewise refrain from disclosing any malicious or false information about the
competitors of the company.
Other than regarding the selling at stores activity, regarding their relationship with third
parties, Inditex’s employees shall avoid, as a rule of thumb, any cash payment, and
payments in currencies other than the agreed one. Anyway, payments shall adjust to the
policies defined by the Financial Management Department. Likewise, employees shall
exercise special control on any unscheduled payments to or by any third parties not
previously mentioned in the relevant agreements, on payments made to any bank account
other than the usual one used in the transactions with any given organization or individual;
payments made to or by any individual, company, organization or to any account opened
anywhere that is deemed to be a tax haven and those payments made to organizations
whose shareholder, owner or ultimate beneficiary cannot be identified.
Employees shall require compliance with all regulations regarding processes of new
registrations or declaration of origin of goods, supervising compliance with the standards
and procedures laid down by the company in this field.
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4.6. Relationship with suppliers
Inditex’s employees shall maintain a lawful, ethical and respectful relationship with its
suppliers.
The choice of suppliers shall be governed by principles of objectivity and transparency,
combining the interest of the company in achieving the best conditions, with that of
maintaining stable relations with ethical and responsible suppliers.
Any and all suppliers working with Inditex shall undertake to observe human and labour
rights of all employees recruited and to involve its business partners and convey these
principles to them. Under no circumstance shall Inditex accept the violation of any of these
principles.
Any activity within the scope of purchases and procurement will be carried out in full
compliance with the prevailing corporate regulations and procedures in force. All decisions
made within this scope shall be evidenced, that is they shall be supported and checked in
the event of a review by any third parties or by the control-exerting bodies within Inditex.
Inditex’s personnel are bound to protect any commercially sensitive information regarding
the terms and conditions set forth by the company regarding its procurement chain.
Inditex’s employees shall not demand or accept from suppliers any information regarding
the terms agreed with any of Inditex’s competitors.
No Inditex’s employee may offer, grant, apply for or accept, either directly or indirectly, any
gifts, handouts, favours or compensations, whether in cash or in kind, regardless of the
nature thereof, that might have an impact in the decision-taking process in connection with
the performance of the duties pertaining to their office.
Any gifts or handouts received in breach of the provisions of this Code shall be forthwith
returned and this fact must be reported to the Committee of Ethics. Should this return not
be reasonably likely, these gifts or handouts shall be delivered to the Corporate Social
Responsibility Department, which, further to the issuance of the pertaining receipt, shall
contribute them to a charity.
Specifically, no Inditex’s employee may offer, grant, apply for, or accept any gifts or
handouts from any individuals or body corporate with whom Inditex has any manner of
relationship whatsoever for an amount whether on its own or added up within one year
which exceeds Euro 100 or the equivalent amount thereof in local currency. Cash gifts are
expressly forbidden.
4.7. Relationship with public authorities and servants
Inditex’s employees shall maintain lawful, ethical and respectful relationships with the
authorities and public institutions in such countries where they conduct their business, in
line with international provisions on anti-corruption and anti-bribery policies. Such
employees involved in any relationship with representatives of public authorities shall have
the prior express authorization of the company for such relationship.
Any staff members involved with public administrations shall formally document all
decisions made and evidence compliance with internal and external regulations, in order
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to help any third parties and control bodies within the company to review regulatory
compliance in this field.
As a rule of thumb, no employee of Inditex may offer, grant, demand or accept, whether
directly or indirectly, any gifts or donations, favours or compensations, regardless of their
nature, to or from any public authorities or servants.
The foregoing does not apply, however, to such gifts and tokens of scarce economic value,
equitable and reasonable according to local practice, and transparent, and which are given
on account of lawful, socially accepted interests, and which are occasional to avoid that
their contents or recurrence might lead any independent third party to question the good
faith of the employee or the company. Cash gifts are expressly forbidden.
It is incumbent on each employee to be duly informed and to appropriately assess local
practices, taking into account the interest and good name of the company. In case of any
doubts, they shall be addressed to the Committee of Ethics.
Anyway, usual practices about gifts and tokens shall be duly monitored, assessed and
registered by the company.
Inditex’s employees shall refrain from making any facilitating or expediting payments,
consisting of giving out money or any other valuables, regardless of their amount, in order
to ensuring or speeding up any bureaucratic proceeding, regardless of its nature, vis-à-vis
any court, public administration or official agency.
Employees shall avoid getting any undue tax benefit for Inditex and shall make sure that
the information reported in this field to the tax authorities is true and accurate and fairly
presents the real status of the company. They shall also make sure that aid demanded or
received from public authorities is duly allocated and that the application for such aid is
transparent, without resorting to tampering the application so as to be granted such aid, or
allocating it to any use other than the one for which it was granted.
In such countries where there are requirements and restrictions regarding international
trade, Inditex’s employees shall strictly comply with the prevailing regulations in force and
shall provide the required information on their activities to any authority which may have
requested it.
4.8 Conflicts of interest
Inditex’s employees shall avoid any situation which might entail any conflict between their
personal interests and those of the company. They shall also refrain from representing the
company and from taking part or having a say in any decision making wherein they may
have, either directly or indirectly, either themselves or through any related party thereto,
any personal interest. They may not avail themselves of their position in the company to
obtain any economic or personal benefit, or any business opportunity for them.
No employee of Inditex may render services as consultant, director, officer, employee or
advisor to any of Inditex’s competitors, except for such services which may be rendered at
the request of Inditex or with the authorization of the Committee of Ethics.
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Inditex respects the private life of its employees and therefore the private sphere of their
decisions. In the framework of this policy of respect, employees are urged to report to the
Committee of Ethics any personal conflicts of interest or any conflicts of interest involving
their relatives, that might jeopardize the necessary objectivity or professionalism of their
duties within Inditex, so that, in the respect of the confidentiality and privacy of individuals,
the relevant measures might be taken for the mutual benefit of the company and of the
affected individuals.
Namely, the cases below shall be considered as potential situations of conflict of interest
and they shall be reported to the Committee of Ethics:
 The conduct by any employee or by any person related to him/her, either directly or
indirectly, by themselves or through any company or institution, of any business which
is the same, similar or supplementary to the business conducted by Inditex.
 The conduct by any employee or by any person related to him/her, either directly or
indirectly, by themselves or through any company or institution, of any business which
involves an exchange of goods and/or services, regardless of the remuneration system
agreed.
4.9 Exercise of other activities
Inditex’s employees shall only be able to develop any working or professional activities
other than those carried out for Inditex, where same shall not diminish the efficiency
required in the performance of their duties.
Any occupation or professional activity alien to Inditex that might affect the working hours
for the company shall be previously authorised by the Committee of Ethics.
Inditex develops its business model without having any political interference in those
communities where it carries out its manufacture, distribution and/or commercialisation
activities.
Any relationship that the Inditex Group may have with any governments, authorities,
institutions and political parties shall be based upon the principles of legality and neutrality.
Contributions, whether in cash and/or in kind that might be made by the company, where
applicable, to any political parties, institutions and public authorities, shall always be made
in accordance with the current legislation in force and ensuring the transparency thereof;
for such purposes, a previous report of the Legal Department evidencing that any such
contributions are lawful, shall be required.
The right of the employees to take part in lawful political activities is hereby acknowledged,
provided that said activities would not interfere with the appropriate performance of their
work for the company and that they would take place during non working hours and outside
any of Inditex´s facilities so that these activities may not be attributed to the company.
4.10 Use of goods and services of the company
The employees of Inditex shall secure an efficient use of the goods and services of the
company and shall not use any goods for their own profit.
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With this respect, the employees of Inditex shall never use any equipment made available
to them by the company to install or download any software, application or contents whose
use is illegal, which infringe the regulations of the company or which may damage its
reputation. They shall not use either any monies or cards of the company to pay for any
proceedings not inherent in their professional activity.
Employees shall be aware that documents and data included in IT systems and equipment
of Inditex may be subject to review by relevant units within the company or any third parties
appointed by the company itself, where necessary and whenever prevailing regulations in
force so permit.
4.11 Confidentiality of information and personal data protection
Inditex’s workforce shall protect the information and know-how generated within the
organization, the property of Inditex or under its custody.
Employees shall abstain from using for their own benefit any data, information or document
obtained in the course of their professional activities. Likewise, they shall not disclose any
information to any third parties, except where this is required by the applicable laws, nor
the internal regulations of the company or where they are expressly authorized to do so.
Additionally, they shall not use any confidential data, information or document originating
in any third company without its express authorization in writing.
Inditex’s staff undertakes to keep confidential, and to use them pursuant to the internal
regulations in this field, any data, information or documents obtained in the performance of
their duties within the company. As a rule of thumb, and unless otherwise stated, any
information available to them shall be deemed confidential, and shall be used exclusively
for the purposes for which it was obtained.
Likewise, employees shall not copy, reproduce or use the information for any purposes
other than what is required for the performance of their duties, and they shall not store it in
any IT systems other than those the property of Inditex, unless where expressly authorised.
The confidentiality obligation shall remain even after termination of work with Inditex and it
shall include the obligation to return any material connected with the company that the
employee has in his/her hands when upon termination of his/her relationship with the
company.
Inditex´s employees shall respect the personal privacy and the privacy of the family of any
individual, whether employee or otherwise, whose personal data are made available to
such employees. The authorization to use any data shall be granted in connection with
specific and duly supported applications. Inditex’s employees shall strictly comply with any
regulations, whether internal or external, set forth to ensure the due processing of
information and data provided to the company by any third parties.
Regarding the gathering of personal data of customers, employees, suppliers or any
individual or company involved in any contractual relationship or otherwise with Inditex,
Inditex employees shall obtain the required mandatory consents, and they undertake to
use such data for the purposes expressly consented. Likewise, Inditex’s personnel shall be
familiar with and observe all internal procedures implemented regarding storage, custody
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and access to data, aimed to ensure the different levels of security required pursuant to the
nature thereof.
Employees shall report to the relevant department or area any incidence they might detect
concerning confidentiality of information or personal data protection.
4.12 Protection of intellectual and industrial property
Inditex is committed toward protecting intellectual and industrial property, whether of its
own, or of others. This covers, among others, copyrights, patents, trademarks, domain
names, reproduction rights, design rights, database extraction rights and rights on technical
expertise.
Inditex shall be accountable for the originality of its own design and shall make sure that its
suppliers ensure that the designs they provide the company with are original.
It is expressly forbidden to any staff member to use any works, creations or distinctive signs
of intellectual or industrial property of third parties, without the prior evidence that the
company relies on the relevant rights and/or licenses.
Inditex’s employees shall take all necessary steps to protect the intellectual and industrial
property rights, and they shall procure that all processes and decisions within this field are
traceable, in that they should be documented and duly supported and subject to verification,
especially, through the titles to the works, creations or distinctive signs and the enforcement
of such clauses which ensure originality and peaceful use of industrial and intellectual
property rights of third parties.
Such intellectual and industrial property rights resulting from the work of employees while
they work for the company and connected with current and future business of Inditex shall
remain the property of the company.
Only such trademarks, images and texts duly authorized by the IP Department, the
Department of Communication and Institutional Relations and the Corporate Social
Responsibility Department may be used for marketing and advertising purposes.
4.13 Record of transactions
Any and all transactions carried out by Inditex which may have an economic impact shall
be clearly and accurately shown on the appropriate records of accounts, as a true
representation of the transactions carried out, and they shall be made available to the
internal and external auditors.
Inditex’s employees shall enter the financial information on the company’s systems in a full,
clear and accurate manner, so that they would show, as at the relevant date, their rights
and obligations in accordance with the applicable regulations. Additionally, the accuracy
and integrity of the financial information which, under the prevailing regulations in force
shall be disclosed to the market shall be ensured.
Inditex undertakes to implement and maintain an appropriate internal control system on
financial reporting, ensuring the regular supervision of the effectiveness of such system.
Accounting records shall be at all times made available to the internal and external auditors.
For such purposes, Inditex undertakes to provide its employees with the necessary training
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for them to understand and comply with the commitments undertaken by the company
regarding the internal control on financial information.
4.14 Social and environmental commitment
At Inditex, Corporate Social Responsibility understood as a social and environmental
commitment in the conduct of its business, beneficial for all its stakeholders, is an integral
part of its business mode.
Inditex’s social commitment materializes in the performance of sponsorship, patronage and
social action activities, carried out by the organization itself or channeled with the help of
non-profit organizations or charities.
Likewise, Inditex shall encourage and advocate the collaboration of its employees with nonprofit organizations or charities wherever it operates through corporate volunteering
schemes, among others.
Under Inditex’s internal regulations, the Committee of Patronage and Sponsorship, is the
organ entitled to approve any contributions made towards sponsorship, patronage or social
investment schemes.
Inditex undertakes to minimize the environmental impact throughout the life-cycle of its
products, from the purchase of commodities, or from the generation thereof based upon
natural resources, through the final disposal thereof, implementing in every stage of the
design, manufacture, distribution, retail sale, and end of use processes, measures to
reduce and set off such impact.
In the performance of their work, Inditex’s employees shall encourage the social and
environmental sustainability of the company as a way of creating value for all its
stakeholders in a responsible manner.
5. Code Compliance and Committee of Ethics
5.1. Committee of Ethics
In order to ensure compliance with this Code, a Committee of Ethics exists within the
organization, composed of:
 The General Counsel and Code Compliance Officer
 The Internal Audit Director
 The Corporate Social Responsibility Director
 The Human Resources Director
The Committee of Ethics may act of its own motion or at the behest of any employee of
Inditex, manufacturer, supplier or any third party with a direct relationship and a lawful
business or professional interest, further to a report made in good faith.
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For such purposes, notices given under this Code, whether reporting any breach of the
Code, or including any enquiries regarding the construction or implementation thereof, may
be addressed to the Company by any of the following means:
 Ordinary post addressed to: Avenida de la Diputación, Edificio Inditex, 15142
Arteixo, A Coruña (Spain), for the attention of the Committee of Ethics.
 E-mail addressed to: comitedeetica@inditex.com
 Fax sent to: +34 981 18 62 11.
The Committee of Ethics reports to the Board of Directors through the Audit and Control
Committee and has the following duties:
a) To supervise compliance with the Code and the internal circulation thereof to
Inditex’s personnel.
b) To receive any manner of written instruments with regard to the enforcement of
this code and to send them, where appropriate, to the relevant body or
Department which may be responsible for dealing with and settling such
instrument.
c) To monitor and supervise the management and settlement of any file.
d) To solve any doubts which may arise, regarding the enforcement of the Code.
e) To propose to the Board of Directors, after report from the Audit and Control
Committee, any explanation or implementation rule which the enforcement of the
Code may require, and at least, an annual report to review its enforcement.
f) To supervise the Whistle Blowing Channel and compliance with the Procedure.
In the performance of its duties, the Committee of Ethics shall ensure:
a) The confidentiality of all the information and background and of the acts and
deeds performed, unless the disclosure of information is required by law or
judicial order.
b) The thorough review of any information or document that originated its action.
c) The commencement of such proceedings that adjust to the circumstances,
where it shall always act with independence and full respect of the right of the
affected person to be heard as well as of the presumption of innocence.
d) Non-retaliation against any complainant as a result of bringing complaints in
good faith to the Committee.
The Committee of Ethics shall have all required means to ensure the enforcement of this
Code.
Decisions of the Committee of Ethics shall be binding for any company which forms
Inditex and for the employees.
6. Publicity of the Code
The Code shall be made available to the employees in their own language, and remain posted
on all web sites of Inditex, and shall be subject to the appropriate disclosure, training and
awareness-raising actions to be properly understood and implemented within the whole
organization.
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Schedule I: Codes and global commitments willingly undertaken by Inditex
 UNI GLOBAL UNION (www.uniglobalunion.org). It encourages respect for and
promotion of fundamental rights and decent work within the retail and distribution
network.
 The United Nations Global Compact (www.globalcompact.org). A United Nations
initiative to encourage social dialogue between companies and the civil society.
 Ethical Trading Initiative (ETI) (www.ethicaltrade.org). This is a dialogue Platform to
improve working conditions of workers in developing countries. It is an alliance between
companies, international trade unions, and non-governmental organizations.
 International framework agreement and protocol with the International Textile,
Garment and Leather Workers Federation (ITGLWF) (www.itglwf.org). To promote
essential human and social rights within Inditex’s supply chain, including the definition
of mechanisms of joint action within the supply chain to implement the Code of Conduct
for Manufacturers and Suppliers.
 ILO’s Better Work Programme (www.betterwork.org). This is a platform to improve
compliance with labour regulations and competitiveness of global supply chains.
 The CEO Water Mandate (www.ceowatermandate.org). A United Nations initiative to
support companies in the development, implementation and disclosure of their waterrelated strategies and policies.
 Sustainable Apparel Coalition (www.apparelcoalition.org). An initiative of the textile
sector to set in train a joint sustainable index to assess the environmental performance
of their suppliers during the production process.
 Textile Exchange (www.textileexchange.org). Plataform to promote the growing of
organic cotton, and global sustainability within the textile sector.
 Better Cotton Initiative (www.bettercotton.org). Initiative to develop and promote best
practices in the traditional growing of cotton to benefit the farmers and the environment,
and to ensure the future of the sector.
 Code of Tax best practices. It encourages a mutually cooperative relationship between
the Tax Agency and the companies.
 Collaboration agreement between the Ministry of Health and Consumption and the
fashion sector in Spain. It seeks to defend and promote the rights of Spanish consumers
within the fashion world, namely regarding training, and the promotion of a healthylooking appearance.
16
Schedule II: Definitions
For the purposes hereof, the following terms shall have the following meanings:
Inditex.- All companies that are part of the Inditex’s corporate Group worldwide. Unless
otherwise provided herein, the word “company” shall be deemed to apply to each and every
company within the Inditex Group.
Inditex, S.A.- Industria de Diseño Textil, S.A., a company listed on the Stock Exchanges of
Madrid, Barcelona, Bilbao and Valencia and on the Exchange Electronic Trading System
(SIBE, Spanish acronym) (Continuous Market) with registered address at Avda. de la Diputación,
Edificio Inditex, 15142 Arteixo, A Coruña (Spain), registered with the Companies Register of
the province of A Coruña, on Volume 964 of the File, General Section, Folio 17, Page no. C3342 and VAT Number (ES- C.I.F) A15075062.
Staff or employees.- All directors, officers and other employees of Inditex, regardless of their
employment agreement, when they act in such capacity, that is, for and on behalf of Inditex,
both if they do so directly and indirectly in person or through any third party, company or
controlled entity of any kind.
Related person.- Any person who is linked to any employee of Inditex as:
• Their spouses or any other person with similar relation of affectivity.
• Their ascendant, descendant or brother or sister.
• The ascendant, descendant, or brother or sister of the spouse or of any other person
with similar relation of affectivity.
Suppliers.- Manufacturers of the Inditex Group and any other supplier of goods and services
which are engaged in any direct business relationship with Inditex.
Business partners.- Any company engaged in a business relationship with Inditex through
the setting of any manner of joint ventures or franchises.