Code of Conduct
1. Purpose and Scope
This Code of Conduct defines the ethical principles and standards of behavior expected of all individuals associated with Alioth Capital, including partners, employees, contractors, and advisors. It reflects our commitment to integrity, independence, discretion, and excellence in all aspects of our work.
2. Integrity and Professionalism
We conduct our business with the highest standards of honesty and ethical behavior.
Our work is grounded in facts, sound analysis, and independent judgment.
We maintain a high level of professionalism in every interaction, whether with clients, partners, or colleagues.
3. Confidentiality
We respect and protect all confidential and proprietary information entrusted to us by clients, partners, and stakeholders.
Confidentiality is preserved during and after any engagement.
We never use confidential information for personal benefit or disclose it without proper authorization.

4. Independence and Objectivity
We provide advice based solely on professional judgment, free from external pressure or bias.
We act independently, even in complex or high-stakes situations, and always prioritize the client’s long-term interests.
5. Compliance with Laws and Professional Standards
We comply with all applicable laws, regulations, and industry standards in the jurisdictions where we operate.
We uphold anti-corruption, anti-bribery, anti-money laundering, and anti-fraud regulations at all times.
6. Avoidance of Conflicts of Interest
We proactively identify, disclose, and appropriately manage any actual or potential conflicts of interest.
If a conflict cannot be mitigated satisfactorily, we will decline or withdraw from the engagement.
7. Diversity, Equity, and Inclusion
Alioth Capital is committed to fostering a working environment — both internally and in our client engagements — that respects and embraces diversity in all its forms.
We do not tolerate any form of discrimination or harassment based on race, ethnicity, gender, gender identity or expression, sexual orientation, age, religion, disability, socioeconomic background, or any other protected characteristic.
We treat all individuals with dignity, fairness, and respect, and actively promote inclusive practices in our work and interactions.
We recognize that diverse perspectives enhance decision-making, creativity, and long-term value creation.
8. Commitment to Excellence
We take pride in the rigor, clarity, and reliability of our work.
We are committed to continuous improvement, seeking feedback, learning from experience, and adapting to change.
9. Reporting Concerns
We encourage all individuals to report any concerns related to unethical behavior, misconduct, or violations of this Code.
Reports will be handled seriously, professionally, and — where appropriate — confidentially.
Retaliation against individuals who raise concerns in good faith will not be tolerated.
10. Accountability
Everyone associated with Alioth Capital is expected to uphold this Code and contribute to the firm's ethical culture.
Breaches may lead to appropriate consequences, including reassignment, termination of engagement, or legal action where necessary.
Version 1.0 – April 2025

For questions about this Code or to report a concern, please contact: info@aliothcapital.es
