Code of Ethics

A company’s identity and image are the result, not only of its financial and economic performance, but also of a series of principles, values, behaviors and choices. Above all, the ethics of a company are the result of the combined ethics of its employees, who must follow a number of rules, or principles of behavior.

BySide, Lead Activation, S.A (BySide), owner of the Bytalk brand and project, expects its employees’ behavior to follow ethical concerns, without forgetting the impact that their decisions, actions and behaviors have on partners, customers, suppliers and the general public.

Ethical concerns are even more important in these times of new challenges, opportunities and threats, as a result of an increasingly strong global economy and the growing importance of info-communication. Thus, and taking into consideration the importance of this issue, BySide explains and formalizes the company’s ethical principles.

These are the main objectives that this document is intended to achieve:

– To clearly explain the behaviors that are compatible with the principles and values that BySide wishes to be recognized by its customers, partners and suppliers.
– Encourage all employees to share the values and principles, and adopt the aforementioned behavior.
– To promote relationships based on trust among all BySide employees, partners, customers and suppliers.


This code of ethics applies to all BySide employees, regardless of their employment status, or hierarchical position. All employees include: all members of management, directors, office staff and other employees.

Violation of the rules

Any violation of the rules of conduct, defined in this policy, by any employee will be duly reviewed by management.

Monitoring and omitted cases

BySide management is responsible for the implementation and monitoring of this policy, as well as for the interpretation of this code, clarification of doubts or omitted cases.

Final Considerations

This Code of Ethics may be subject to updates and corrections, in order to adapt to the future evolution of BySide and external contexts, or new legal rules that may be adopted.

Employees undertake to guide their behavior by this Code of Ethics, which defines the following values and rules of behavior.

Rules of action

BySide’s actions must be governed by principles of honesty, integrity, dignity, correctness, professionalism and impartiality. Especially in relationship to customers, suppliers, partners, employees, authorities, the press and the general public. This conduct must be fulfilled through the individual behavior of each BySide employee.

Duty of loyalty

Employees must be loyal to BySide and work to defend its prestige, credibility and good image in all situations. Employees must be impartial and objective in their analysis of all business decisions made on behalf of the company.

Compliance with the law

All BySide employees must abide by and enforce the laws applicable to the company’s activity, especially those on the confidentiality of communications and information passed by users. Employees must not take any action on behalf of the company, which may violate the general law and the rules applicable to their activities.

Rules of conduct


All employees must act within the limits of their responsibility, especially the risk limits defined by BySide, and by the company’s budget targets. Employees must use the power given to them in a non-abusive manner, with the sole aim of achieving the company’s goals, and not for their own benefit.

Interpersonal relations

All employees should contribute to the creation and maintenance of a good working environment through collaboration and mutual cooperation. They should therefore cooperate with each other, without taking personal advantage when implementing their superiors’ decisions in accordance with the company’s rules or when supporting their subordinates in their application.

Professional growth and merit

BySide employees should continuously try to improve and update their knowledge in order to improve professional skills and service. BySide shall evaluate performance based on merit.

Confidentiality and professional secrecy

All employees are required to maintain professional secrecy, especially on topics that due to their importance, or due to the law, should not be public knowledge. They must be reserved and discreet about facts and information that concern rules under information confidentiality.

Conflict of Interest

When employees are called upon to take part in any decision, which directly or indirectly, involves companies and organizations for which they work, or have worked, or people to whom they are connected by family or affinity ties, they must immediately communicate the conflict of interest to their superiors. BySide employees must reject any outside employment where such activities could threaten their performance, or where in organizations that could interfere with BySide’s objectives, business and customers.

Illegal Activities

BySide, or its employees, should NEVER receive, or make, any payments or favors to customers or suppliers. They must not, in this way, attempt to gain a competitive advantage over their competitors and must refuse to obtain business information through illegal or dubious means. Additionally, all employees must refuse gifts to, or from, third parties. Gifts may never be made in a personal capacity and, if any, must follow the rules established by BySide. Receiving offers, including gifts, or participation in public events with offers with a value of more than 100 (one hundred) euros, must be explained in writing to management, and must be refused, if there is no clear intention on the part of the giver.

Private arrangements made by employees

BySide employees must not participate in, enter into any contracts or business dealings with companies working with BySide if they offer more favorable terms than would be expected, especially in the negotiation of loans, discounts, payment deadlines, or sale of goods and services.

Use of company resources

BySide resources must be used efficiently, with the aim of achieving the company’s objectives and not for personal benefit. Employees must protect and look after the proper preservation of the company’s assets.

Relationship with customers

Employees must show a high degree of professionalism, respect and sensitivity in their dealings with customers. They must offer customers quality, efficiency and support, making available all the information that may be needed about products, services, or prices.

Commercial conditions

Commercial conditions must be well defined, in a non-ambiguous way, according to the principle of honesty. The company, and all employees, must ensure strict compliance with the agreed-upon conditions for product or service quality.

Communication with the press and advertising

Information passed to the media, or through advertising, must be clear and true, respecting ethical, cultural, and environmental principles and of human dignity. These should also contribute to dignify BySide.

Relationship with suppliers

BySide must honor commitments with suppliers of products and services, and validate that its suppliers fulfill their contracts. Contracts must be written clearly, without ambiguities, or omissions, and must comply with company rules on the subject matter. In selecting suppliers of products or services, BySide must consider not only the commercial terms and quality of the products, or services, but also the ethical behavior of the suppliers. BySide shall also make its suppliers of products or services aware of their compliance with the ethical principles and values of the company, especially with regard to confidential information about BySide, and any potencial conflicts of interest with which may also work with BySide’s competitors.

Relationship with competitors

BySide shall respect market rules and refuse any unfair competition, when signing agreements, or fixing prices, and when respecting material or intellectual property rights.

Relationship with partners

BySide employees must always behave in such a way as to protect the interests of partners.

Relations with official bodies

BySide shall cooperate, with supervision and control, with authorities and official bodies and answer all questions they may raise.

Conduct on Social Networks

Social media plays an important role in how we interact with market leaders, potential clients and customers. BySide encourages employees, interns and contract staff to participate in social media, and in online communities, but requires everyone to follow ethical rules and guidelines, regardless of their position.

Key digital platforms covered by this Policy include, but are not limited to, blogs, microblogs (e.g., Twitter), online messaging (e.g., WhastApp, Facebook Messenger, Skype, iMessage), social networks (e.g., Facebook, Instagram, Pinterest, Tumblr), video sharing websites (e.g., YouTube), photo sharing websites, and podcasts.

Employees, interns, and other contracted personnel are required NOT to participate in social media in the following ways:

– NOT to share confidential, or private information. This includes confidential company data, whether financial or service data, or private information, shared with BySide by third parties, lines of information, unannounced customers, acquisitions, or potential or pending investments, and any and all information not yet available in the public domain.
– NOT impersonate any third party, or as an employee of another company, and NOT ask others to do so. Ensure that the content you create and the marks you leave are truthful and honest. Do not hide relevant information about your identity, connection to the business, or any other pertinent information. Also, never ask others, including customers and partners, to present themselves with false identities, or to be untruthful in their relationship with BySide
– DO NOT lie. Statements and online messages about the business, and its products/services, should reflect honest opinions, values, recommendations and/or experiences. In addition, you must not omit material information that could change the meaning of the communication. Under no circumstances will unsubstantiated, misleading, or unfounded claims about the company or a competitor be allowed.
– DO NOT make personal attacks, or speak negatively about BySide’s employees, interns, contract personnel, customers, potential customers, or competitors. Incomplete, inaccurate, inappropriate, threatening, harassing, or poorly worded posts may be harmful to other employees, interns, and contractors, damage relationships, or undermine BySide’s efforts to encourage teamwork. Personal insults and offenses, obscenities, rumors, lies and other offensive language are expressly prohibited.
– DO NOT use the company name in any social media identity (e.g., username, “handle” or “screen name”), or speak as an official representative of the company. Only official social media accounts managed by the company’s Marketing team may interact as official company representatives.

Employees, interns and contract staff are asked to participate in social media in the following ways:

– DISCLOSE that you are a BySide employee, or that you work for BySide, especially if you are creating content related to our field of activity, and verify that other social media participants disclose their actual connection to BySide. BySide values honesty and transparency. Use the information in your bio to disclose your affiliation with BySide. When commenting (for example, on a blog post, or in a forum), disclose your relationship with BySide. In addition, customers, partners, and other social media participants must disclose their “real connections” to BySide when working with us on marketing activities. Such “real connections” include, but are not limited to: benefits or incentives, such as monetary compensation, product loans, free services, gifts in kind, or special access privileges provided by BySide. All disclosures must be clear and relevant, easy to understand, and in non-ambiguous language.
– DISCLOSE if you are acting as a representative of the company. When posting your own opinions, comments, or content about BySide and/or its products or services, you should make it clear that your views do not necessarily represent those of the Company.
– THINK before you post. Think about the information being posted, the channel in which it is being presented, and how it will be received. Remember that information posted on social media “lives forever” and can be used out of context.
– INFORM the Marketing team ( about possible problems, questions, wrong or negative information, and even compliments you may find about BySide. If you find anything of concern, or otherwise notable, you should inform the Marketing team, so that they can respond in their official capacity, if that be the case. You should also direct any press requests to the respective Marketing contacts.
– DO ask questions if you are unsure. If you have any questions about what is acceptable and what is not, contact the Marketing team.
– This policy is part of BySide’s Code of Ethics and Conduct. As such, employees are required to know and comply with this policy; failure to do so will result in corrective action that may include termination of employment with BySide.

If you have any questions about this social media policy or any other point in this code of ethics, please contact