Code of Ethics

Code of Conduct and Ethics of Rosmiman Software Corporation


Integrity and ethics have always been a significant part of the way we do business in Rosmiman Software Corporation. Acting with a strong sense of integrity is crucial to maintain the confidence and credibility of our customers, partners, employees, shareholders and other stakeholders.
Create an environment of transparency in conducting business represents a high priority for us all. Our Code of Conduct and Ethics in the Company is our promise to act with truth, fairness, goodwill, honesty and integrity in our professional activities. We hope our company does business in accordance with the principles set in this Code and that all members of the company are responsible to meet such standards.

Our Code of Conduct and Ethics in the Company contains regulations regarding individual responsibilities and between members of the same category as well as responsibilities to our employees, customers, suppliers, shareholders and other stakeholders and includes:

  • Compliance with laws, rules and regulations.
  • Protection of confidential information, from our company as well as from our customers and suppliers.
  • Protection and proper use of company goods.
  • Treatment with respect to the employees of Rosmiman Software Corporation.
  • Resolution of conflicts of interest.
  • Encourage the provision of reports on any illegal or unethical behavior.


Each of us must assume the task of reviewing and following this Code and complying with all applicable laws and policies and guidelines of the company. The failure to fulfill may result in civil and criminal responsibility and may result in disciplinary actions including the employment termination.

We establish additional responsibilities in our directors and managers, who should, through their actions, demonstrate the importance the fulfillment.

The directors and managers must ensure this Code is implemented through appropriate disciplinary actions. Unethical conduct will not be ignored.


All employees have the duty to report any conduct they may believe in good faith, it is a violation of the law or the Code of Conduct and Ethics of the Company to their immediate superior or the direction of the company in accordance with procedures established locally.

Violations of the laws or this Code and, in particular, related to accounting, internal accounting controls, auditing issues or any deceptive financial practices must also be notified in accordance with the established procedure.

In situations involving issues of workers’ rights and working conditions, employees should report the issue to their immediate superior. If their immediate superior is involved in the situation they want to report or is not able to or has not solved adequately their concerns, the employee should report directly to the management. Rosmiman Software Corporation will not admit any discrimination or retaliation against employees for reporting in good faith, about real or suspected infractions.


In Rosmiman Software Corporation we take business, strategic, economic and organizational decisions based on the best interests of the company and not on personal considerations or relationships. A conflict of interest arises when something interferes with or influences on the exercise of independent opinion of an employee in the best interests of the company. We must avoid situations where our personal interests may conflict or even seem to conflict with the interests of the company.

Special awareness must be taken in the following example situations:

Business Opportunities – You shall not have business opportunities for yourself that are related to the activities or obligations with Rosmiman Software Corporation if this would be contrary to the interests of Rosmiman Software Corporation. You shall not use in any way, property, information or the position of Rosmiman Software Corporation for personal profit.

Other employment or activity – Any employment outside Rosmiman Software Corporation, with or without compensation, must not impair the performance of the work in Rosmiman Software Corporation. You may not engage in commercial and economic interests that divert time and attention of the responsibilities in Rosmiman Software Corporation or require work during the time spent in Rosmiman Software Corporation. You must avoid any conflict of interest by not accepting third party jobs or development of particular activities for your own benefit.

Political Activities – Rosmiman Software Corporation or any of its employees on behalf or representing the company shall not make contributions or payments in any way, directly or indirectly to political parties or committees or individual politicians.

Gifts, benefits, refunds and representation activities – An employee of Rosmiman Software Corporation shall not offer or accept gifts, benefits, refund or compensation in representation activities to or from, third parties that would constitute a law violation or that may affect, or seem to affect, the professional opinion in the execution of their work or in the fulfillment of their obligations to Rosmiman Software Corporation or third parties.


Rosmiman Software Corporation has a wide variety of assets including physical assets, proprietary information and intellectual property. It is responsible for protecting the properties entrusted to and for helping and protecting the assets of Rosmiman Software Corporation in general. In order to do this the workers must be knowledgeable and understand the guidelines on safety and use of goods of Rosmiman Software Corporation.

Here are some instructions for treating internal and external information, communication systems and intellectual property.

Intellectual Property – Intellectual property includes a wide range of properties, such as software, manuals and technical documentation etc. Some intellectual property is or may be subject to special protection by copyright, patent rights, trademark rights, etc. Intellectual property is a wealth of maximum value for Rosmiman Software Corporation and should be treated with proper care. Each employee must follow, and if in doubt, look for instructions on how to act in order to protect this valuable asset. The intellectual property created by each employee, derived from their professional performance, is transferred and assigned to Rosmiman Software Corporation by law and / or its employment contract or other agreements, with the exceptions stipulated in the collective or personal agreements with Rosmiman Software Corporation.

Use of the communications systems of Rosmiman Software Corporation – The communications systems of Rosmiman Software Corporation, including Internet connections should be used for the business of Rosmiman Software Corporation. Each employee should always make sure to follow the instructions regarding the treatment of passwords. Unacceptable use of the communications systems of Rosmiman Software Corporation includes to process, send, retrieve, access, view, store, print or in any way disseminate material and information that is confidential, fraudulent, harassing, threatening, illegal, racial, sexist, obscene, defamatory or in any way incompatible with a professional conduct.

When leaving the working at Rosmiman Software Corporation – Each employee must return all property of Rosmiman Software Corporation, including documentation, manuals, software, work tools as operating systems, databases, software and software development tools, and any media containing proprietary information of Rosmiman Software Corporation. The employee will remain obligated by the restrictions on use and disclosure of proprietary information of Rosmiman Software Corporation.


Rosmiman Software Corporation employees have access to the information Rosmiman Software Corporation has available and sometimes also to third-party proprietary information. Such information may be financial information, business plans, technical information, information about employees and customers and other information. Unauthorized access, use and disclosure may cause damages to third parties or Rosmiman Software Corporation and therefore, it is not allowed to access, use or disclose the information unless it has been properly authorized. When in doubt of your authorization, you must find the appropriate instructions or consult your immediate superior or the management of the company.

These are some rules to help protect the information of Rosmiman Software Corporation:

  1. Do not disclose to others information that has not been released by Rosmiman Software Corporation except for (i) persons working for Rosmiman Software Corporation who have access in their work to the kind of information available and have well-grounded reasons to have the information, (ii) any other person authorized by Rosmiman Software Corporation as the recipient of such information or (iii) persons who, according to their work, have to provide such information.
  2. Do not access, duplicate, reproduce or use, directly or indirectly, own information that is not within the duties and responsibilities of your job as an employee of Rosmiman Software Corporation.
  3. The knowledge of any treatment or misuse of confidential information shall be notified promptly, to the immediate superior or the management of the company, and the employee shall cooperate fully with Rosmiman Software Corporation to protect such information.
  4. Do not keep private information about Rosmiman Software Corporation on private computers or other means not provided by the company.
  5. If you need to take information out of the facilities of Rosmiman Software Corporation for work purposes, you must return the information when you complete the tasks performed outside the premises of Rosmiman Software Corporation. No information may be stored at home or elsewhere.

Note: Code of conduct and ethics of Rosmiman Software Corporation as “Corporate Defense” of Corporate Criminal Liability (Organic Law 5 / 2010) of the Government of Spain.