Ethical code

01 | Estudio Lamela Profile

The Firm, as an entity, was born in 1954, when Antonio Lamela, my father, received the title of Senior Architect and began the activity of the liberal profession. In the Spain of that time – the mid-fifties – there were only two schools of Architecture – Madrid and Barcelona – and about forty or fifty architects graduated a year.

The first important Studio was the one established in 1958 in the building at O’Donnell 33. It was an office of about 140 m2, which, compared to what was usual at the time, turned out to be one of the best and most modern in Spain, with the team of that time making up about thirty people.

In 1962 it was decided to take an important step – after four years of life at O’Donnell 33 – and to design a new studio. As my father did not want to move away from his family residence for operational reasons, he promoted a building located on the opposite sidewalk and in the next block O’Donnell 34, which was inaugurated on April 1, 1966.

This building was surprisingly new for the time and represented a before and after in the interior design of offices in Madrid and even, for the staff themselves, a great advance, white coats were incorporated for all the staff, as a symbol of order and cleanliness. Working on Saturday was dispensed with and the working day was set from Monday to Friday with forty hours a week.

I obtained the title of Architect in 1981, and after doing my military service and doing a postgraduate degree in Italy, I joined the Studio in 1984.

The economic crisis of the seventies had lasted longer than necessary, and the staff of the Studio went from the fifty people it had at the time to practically a dozen. This great change took place in 1987 and took place gradually.

In October 1997, the Firm won the tender for the New Terminal of the Madrid-Barajas Airport, together with lnitec, TPS and Richard Rogers Partnership. This event marked a before and after in Estudio Lamela, and the Estudio reached seventy collaborators.

The 21st century brought important changes in the philosophy and strategy of the company, with a special boost to the internationalization of our services. Thus, from September 2001 we became part of the largest European association of Architectural Firms, with associated offices in London, Paris, Milan, Brussels, Frankfurt, Warsaw and Madrid, including HOK, one of the world’s leading firms in Europe.

In 2000, together with Ferrovial-Budimex, we won the first prize for the expansion of Warsaw Airport, the most ambitious and important infrastructure project in Poland, and in 2004 we opened an office in Warsaw to develop new projects.

Since 2006 we have had an office in Mexico City, where the construction of a Banco Santander Contac Center in Querétaro has been completed, and also since 2007, we have been developing projects for countries of the Persian Gulf (G.C.C.J.), especially in the United Arab Emirates, Qatar, Bahrain and Oman, as well as Equatorial Guinea, Panama, Brazil and the European Union -Belgium,  Great Britain, Italy, France-.

Today, from our new headquarters in Madrid, in a unique building of our own design, just as my father Antonio Lamela did more than four decades ago, we continue to look to the future with optimism and with the intention of continuing to grow, improving the quality of our service and developing projects in new specialties and geographical areas.

 

02 | Introduction

PURPOSE

The purpose of this Code of Ethics is to establish the guidelines, principles and values that must be followed by the members of Estudio Lamela and the collaborators who work for or on our behalf, in order to carry out our activities under ethical, sustainable, socially responsible criteria and in compliance with current legislation, both Spanish and that of the countries where Estudio Lamela operates. Although this Code of Ethics does not compile all the situations that may occur, the objective is to establish a general guide. If we are unsure of certain conduct or legal requirements or the application of the Code of Ethics, we must consult with our superior or Management. The purpose of this Code of Ethics is to establish the guidelines, principles and values that must be followed by the members of Estudio Lamela and the collaborators who work for or on our behalf.  to carry out our activities under ethical, sustainable, socially responsible criteria and in compliance with current legislation, both Spanish and that of the countries where Estudio Lamela operates. Although this Code of Ethics does not compile all the situations that may occur, the objective is to establish a general guide. If you are unsure of certain conduct or legal requirements or the application of the Code of Ethics, you should consult your superior or Management.

SCOPE OF APPLICATION

The Code of Ethics is applicable to all members of Estudio Lamela, regardless of their hierarchical level, geographical or functional location and existing contractual relationship, and they are obliged to know the Code of Ethics, accept its content in its entirety and act in accordance with the principles and values contained therein. There is a clear commitment from the Management to provide adequate resources to facilitate compliance with it.

LEGAL REQUIREMENTS

Our values, policy and corporate culture are based, mainly on the following regulations:

  1. Human rights2. Business ethics and legal compliance3. Health and Safety4. Environment and climate change5. Sustainable Development Goals (SDGs)

 

COMPLIANCE AND DISSEMINATION

Estudio Lamela is committed to disseminating the Code of Ethics among all the members of Estudio Lamela. The Code of Ethics will be communicated in electronic format and will be available to stakeholders on our website, wwww.lamela.com

 

03 | Our Principles of Behavior

All actions developed by Estudio Lamela are based on an attitude of respect, ethics, professionalism, honesty and integrity.

The Management of Estudio Lamela is committed to complying with the following corporate values:

The management of our activities must comply with the following corporate values:

CORPORATE IMAGE OF ESTUDIO LAMELA

Estudio Lamela considers that among its most important assets are its corporate image and corporate reputation.

UPRIGHT PROFESSIONAL CONDUCT IN BUSINESS AND RELATIONS WITH THIRD PARTIES

Estudio Lamela establishes a corporate policy and culture to carry out business practices in compliance with the national and international legislation that applies to us. Our professionals at Estudio Lamela will carry out their activity in accordance with the principles of professionalism and integrity in their actions and decisions:

The professionals of Estudio Lamela will strictly comply with the legislation in force in the place where they carry out their activity.

Our professionals may not, regardless of their position or function, request, order or execute actions or behavior contrary to the provisions of our Code of Ethics and legal requirements. No professional must comply with requests or orders contrary to our Code of Ethics and legal requirements, nor may they rely on them, as a justification for illegal behavior. Failure to comply with our Code of Ethics may result in disciplinary sanctions.

Commitment and Anti-Fraud Policy.

Estudio Lamela is committed to preventing, detecting and reporting fraud and cooperating with all stakeholders, to reduce any opportunity for fraud.

Estudio Lamela has a firm commitment to integrity, legality and transparency in all activities and zero tolerance for any form of corruption, fraud, bribery or illicit conduct, both in the public and private spheres.

This commitment extends to all workers, managers, suppliers and collaborators, who must act in accordance with our corporate values and current legislation.

Express prohibition of illegal practices:

Estudio Lamela will manage the risk of fraud through the following aspects:

RELATIONSHIP WITH STAKEHOLDERS

Estudio Lamela promotes transparency and free trade in its regular activities with stakeholders (customers, collaborators, suppliers or third parties, etc.) with whom we maintain a contractual or professional relationship. Estudio Lamela is committed to complying with the legal, contractual requirements and/or expectations of stakeholders and establishing long-term professional relationships based on integrity, transparency, ethics and compliance with current legislation.

LIST OF SUPPLIERS AND COLLABORATORS

Estudio Lamela’s professional relations with suppliers and collaborators must be based on the quality of products and services and compliance with our Code of Ethics, current legislation and the Global Compact.

SUSTAINABILITY AND ENVIRONMENT

Estudio Lamela is committed to sustainability and ethical and social management, and we work to reduce the carbon footprint of our projects, moving towards a more conscious, circular and low-emission architecture.

We generate value in society through the development of sustainable projects, involving collaborators and stakeholders, within a global strategy.

Our commitment is based on the following principles:

Our global strategy is aligned with the Sustainable Development Goals (SDGs) and we take on the challenge of promoting the 2030 Agenda. Our activities and strategy are aligned with the 17 goals; however, the following SDGs are priorities for Estudio Lamela: 3, 6, 7, 9, 11, 12, 13 and 15.

LABOR RIGHTS

Estudio Lamela is committed to promoting and respecting the labor rights of all workers, such as:

Consequently, professionals undertake to fulfill their basic duties as professionals, such as:

HEALTH AND SAFETY

Estudio Lamela is committed to promoting and maintaining a safe and healthy work environment, communicating and disseminating the identified occupational risks and will take appropriate measures to prevent accidents and/or injuries caused during or associated with work activity, by limiting, as far as is reasonable, the causes of risk inherent to said work environment.

RESPECT FOR PEOPLE

Estudio Lamela believes that respect for others should be a basic element of the conduct of its professionals and social and ethical responsibility. These principles favor the well-being, safety, equal opportunities, diversity and professional development of the people who are part of Estudio Lamela, promoting a respectful, inclusive and collaborative work environment.

PRINCIPLES OF NON-DISCRIMINATION AND EQUAL OPPORTUNITIES

Estudio Lamela is committed to promoting an appropriate work environment so that no discrimination of any kind occurs, based on the attributes of race, sex, ideology, religion, sexual orientation, age, nationality, disability or any other personal, physical or social condition, and in which diversity is respected and valued. Estudio Lamela rejects any manifestation of violence, physical, sexual, psychological, moral or other harassment, abuse of authority at work and any other conduct that generates an intimidating or offensive environment for the personal rights of its professionals.

Estudio Lamela establishes the following principles of Equality, based on the Universal Declaration of Human Rights and other applicable international requirements:

SELECTION AND TRAINING

Estudio Lamela maintains a selection program that caters exclusively to the academic and professional merits of the candidates and to the specific needs of Estudio Lamela. Our selection programmed respects the principle of equal opportunities for all candidates.

We promote the training of professionals according to their role and responsibility. The training programs promote equal opportunities and the development of a professional career that contributes to the achievement of personal objectives and of Estudio Lamela. Professionals are committed to permanently updating their technical and managerial knowledge and to taking advantage of Estudio Lamela’s training programs.

Estudio Lamela evaluates its professionals according to criteria of objectivity and according to their individual and collective professional performance.

WORK-LIFE BALANCE

Estudio Lamela considers that professional development and work-life balance is the basis of social and ethical responsibility. Estudio Lamela establishes different measures aimed at achieving a balance between family, personal and professional responsibilities.

The conciliation measures are based on the following criteria:

CONFLICT OF INTEREST

A conflict of interest will be considered to exist in those situations in which the personal interest of the professional and the interest of Estudio Lamela collide, directly or indirectly.

There will be personal interest among the workers, when the matter affects the person directly, or a related person.

Description of related person:

By way of example, but not limited to, the following situations can be considered to generate a conflict of interest with Estudio Lamela:

Workers must avoid all situations that could give rise to a conflict of interest. They must refrain from influencing or intervening in decision-making in those situations in which they directly or indirectly have a personal interest, favoring other related people, themselves or external companies, which may harm the interests of Estudio Lamela.

Workers are obliged to immediately inform their hierarchical superior and/or Management of any possible situation of potential conflict of interest. A situation of conflict of interest does not necessarily constitute a breach of our Code of Ethics but not communicating it is.

FIGHT AGAINST CORRUPTION AND BRIBERY AND FINANCIAL CRIMES

Estudio Lamela bases the development of its activities on the principle of respect for the Law, as well as on the fight against corruption and financial crimes, in all its forms, financing of terrorism, etc.

It is absolutely forbidden to pay and/or accept bribes, as well as to participate in acts of corruption of any kind. Bribery is not only limited to cash payments, but also includes, but is not limited to gifts or gifts, invitation to all kinds of entertainment and travel events, loans or credits, all kinds of personal favors, etc.

Corrupt activities not only constitute a breach of our Code of Ethics but may also involve a breach of current legislation. These prohibitions apply to all countries where Estudio Lamela operates, regardless of what is provided for in local legislation. Notwithstanding the above, those that meet the following requirements will be considered gifts or hospitality allowed:

DATA PROTECTION AND THE RIGHT TO PRIVACY

Estudio Lamela respects the right to privacy of its professionals, in all its manifestations, and especially regarding personal, medical and economic data. That is why it will always comply with current legislation on the protection of personal data provided by both its professionals and stakeholders.

Workers undertake to make responsible use of the computer systems and means of communication that Estudio Lamela makes available to them. Such means are not provided for personal use and are therefore not suitable for private communication. They do not therefore generate an expectation of privacy if they must be supervised by Estudio Lamela in the proportionate performance of their management and control duties.

Estudio Lamela undertakes not to disclose stored personal data of its professionals to third parties, except with the explicit consent of the interested parties and except in cases of legal obligation or compliance with judicial or administrative resolutions. Under no circumstances may personal data stored be processed for purposes other than those legally or contractually provided.

Workers who may have access to personal and confidential data undertake to maintain total confidentiality.

CONFIDENTIAL INFORMATION

The information about Estudio Lamela is the property of the organization and is essential for the development of its activities.

The employees of Estudio Lamela undertake to maintain the total confidentiality of the information with which we work, including the intellectual and industrial property and other intangible assets owned by Estudio Lamela or any of the stakeholders with which we interact.

DISCIPLINARY MEASURES

Infringement of the corporate principles and values of this Code of Ethics may constitute a violation of the worker’s contractual and legal obligations or a breach punishable by disciplinary action (as established in the current Collective Agreement or applicable labour legislation), with all applicable legal consequences, and may entail compensation for damages.

The Management of Estudio Lamela will ensure compliance with this Code of Ethics and will also act as an exemplary model for the entire organization.

WHISTLEBLOWING CHANNEL

Estudio Lamela has a whistleblowing channel for workers or interest groups, to promote compliance with the law and the rules of conduct established in our Code of Ethics.

Workers who have knowledge or reasonable indications of conduct contrary to the law or to this Code of Ethics must report it immediately through the established Complaints Channel and/or directly to their superior or to the Management for management.

The identity of the complainant will always be confidential. Without prejudice to the foregoing, the data of the persons who make the communication may be provided both to the administrative or judicial authorities, to the extent that they are required by such authorities as a result of any procedure derived from the subject matter of the complaint, and to the persons involved in any subsequent investigation or judicial proceedings initiated as a result of the investigation. Such transfer of data to the administrative or judicial authorities will always be carried out in compliance with current legislation on the Protection of Personal Data.

Estudio Lamela may not adopt any disciplinary action, direct or indirect, against the complainant, for making use of the Whistleblowing Channel. In other words, complaints that are intentionally fraudulent and/or in bad faith are not allowed, giving rise to the appropriate sanctions according to our Disciplinary Regime.

A communication channel is available for workers and stakeholders via email, canaldenuncias@lamela.com

Madrid, October 17, 2025

Carlos Lamela
Executive President

 

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