This document is applicable, independently, to all employees of PIB Group Iberia Correduría de Seguros y Reaseguros S.A.U, hereinafter, indistinctly, “PIB Group Iberia” or “the Company”, which for these purposes includes, but is not limited to: permanent and temporary employees -full-time or part-time-; workers in training and apprenticeship periods; volunteers; interns; managers and other collaborators with labor or commercial relationship. Hereinafter, and for the sole purpose of this document, “employees”.
Ethical values are the essential and enduring principles of an organization. They are those inalienable and fundamental values that must guide all our actions and behaviors, and that form the identity of the organization.
The Company’s Management considers that Corporate Integrity, understood as the systematic observance of strict standards of ethical behavior in the company, constitutes a source of stable value creation and an indispensable requirement to preserve society’s trust in any institution, protecting the company’s reputation in all its areas.
In this sense, the Company’s Code of Ethics represents a mandatory guide for action and behavior, which develops the basic ethical principles so that the actions carried out in the performance of professional activities comply with the principles of legality, integrity and transparency.
This Code of Ethics and Conduct has been adapted to the new legal requirements and in particular to the Organic Law 5/2010, of June 22, 2010, by which the previous Spanish Criminal Code was reformed. In addition, international treaties on human rights, prevention of money laundering and financing of terrorism, anti-corruption and sustainability have been taken into account.
All this, with the aim of continuing to strengthen the awareness of each and every one of the professionals who are part of PIB Group Iberia, in relation to the duty of faithful compliance with the laws in force and the rules and ethical principles of our society.
This Code of Ethics and Conduct has been approved by the Company’s Board of Directors and compliance with it is required of both Management and all Company employees. All employees are obliged to respect the principles contained herein and to comply with the internal procedures for the best operation of the Company. Hereinafter, the Code will refer to all of them, indistinctly, as employees regardless of the position they hold or the place where they perform their activity.
Although, as is logical, responsibility increases as the hierarchical level increases, respect and compliance with the principles and rules established in this Code are, always and without exception, mandatory for all PIB Group Iberia employees.
Failure to comply with this can have serious consequences for the company, such as sanctions, reputational damage, loss of customers and market confidence, etc.
Serious breaches of this Code may result in disciplinary action, which may lead to dismissal and/or legal action.
The contents of the Code shall prevail over those internal rules that may contradict it, unless the latter establish more demanding requirements of conduct.
The application of the contents of the Code may in no case give rise to the violation of the applicable legal provisions.
If such a circumstance is found to exist, the contents of the Code must comply with the provisions of the aforementioned legal provisions.
This Code of Conduct is not intended to be an exhaustive manual covering each and every possible casuistry or situation in which an employee of PIB Group Iberia may be involved. It is a guide for action and behavior, whose main objective is to help make decisions based on the principles and rules expressed herein.
The main responsibility of the Company’s management is to ensure the sustainability of the entity. To this end, the first level of management of the Company and its entire management team shall be a model of reference in their behavior and compliance with the Code, and shall use all means at their disposal to disseminate the Company’s values and principles, enforcing compliance with the guidelines of conduct contained therein without exception.
Any doubts that may arise in relation to the interpretation of this Code of Conduct, as well as in its practical application, should be referred to the immediate superior or to the Chief Compliance Officer (CCO), who is responsible for monitoring and controlling its proper application.
All employees of PIB Group Iberia have the duty and obligation to comply with the values and ethical principles of this Code of Ethics and Conduct, as well as with all the rules derived from it.
The Code shall be made available to the personnel so that they may become familiar with it and raise any questions that its interpretation may raise.
This Code cannot cover all possible situations, so it is necessary to use good judgment and due diligence to differentiate the professional and correct conduct required in each situation.
PIB Group Iberia shall ensure that no punishment or retaliation is applied to any employee who, acting with integrity, loyalty and in good faith, has reported to the CCO any behavior contrary to the values and principles.
All business objectives and actions pursued must be consistent with the Company’s core values.
As the foundation of the Ethical Principles, the core values foster trust among all stakeholders to help meet or even exceed expectations.
The business and professional behavior of those who make up the Company, therefore, must adhere to the following principles that are key to the Company’s culture:
Specifically, and due to the special regulation of the sector in which the activity is carried out, Royal Decree-Law 3/2020, of February 4, on urgent measures incorporating into the Spanish legal system various European Union directives in the areas of public procurement in certain sectors; private insurance; pension plans and funds; taxation and tax litigation, must be complied with in an exhaustive manner.
The business and professional activities of the Company and its employees and collaborators are based on the value of integrity and are carried out in accordance with the principles of honesty, avoidance of all forms of corruption and respect for the particular circumstances and needs of all subjects involved. We treat everyone fairly and honestly. We comply with all applicable laws, regulations and internal policies.
With regard to our specific activity, it is not permitted to withhold information from a customer or prospective customer about the products that are offered to him/her or that he/she has contracted.
PIB Group Iberia’s professionals are subject to obligations and duties within our professional endeavors. Our actions and the way we act have a direct impact on the Company’s reputation in the markets and in society. Inappropriate behavior or a breach of the law by any of our employees can cause considerable or even irreparable damage to the image and reputation of our organization. It is the responsibility of each and every one of us to maintain appropriate behavior to promote the good image and reputation of the Company in all the communities and countries in which it operates.
The Company promotes the professional and personal development of all its employees and collaborators, ensuring equal opportunities through its performance policies.
No discrimination of any kind is permitted in the work or professional environment on the grounds of age, race, sex, religion, political opinion, social origin, sexual orientation or disability.
The Company supports, and is committed to continue implementing and developing policies aimed at integrating people with disabilities into the workplace and promoting employment opportunities for them.
The Company is committed to establishing an effective equal opportunity policy for its employees to develop their professional activity based on the principle of merit. Promotion decisions will be based on objective circumstances and assessments.
Likewise, the Company is committed to maintaining a policy of investment in the learning and personal and professional training of its employees and collaborators.
Employees shall respect and promote the equal opportunity policy in their professional environment, commit to their personal and continuous training, and support the personal and professional learning of their colleagues.
In general, the Company’s selection processes will be open, so that the greatest number of people with the appropriate qualifications to fill the job offered can access them, and will be carried out in accordance with objective assessment methods that take into consideration, in accordance with accredited merits and always under the principle of equal opportunities, the professional qualifications and capacity of the candidates.
New vacancies will be published internally in advance, to ensure that Company employees can apply on equal terms.
The persons directly or indirectly responsible for the selection and/or hiring of personnel shall guide their decisions and actions without admitting the influence of factors that could alter the objectivity of their judgment, in accordance with the criteria established in the Company’s selection and hiring procedures.
The Company’s employees will participate in the definition of its objectives and will be aware of the evaluations made of them.
The Company guarantees its employees an environment free of health risks in all its facilities. This objective is met through the adoption of standards and procedures inspired by international best practices in occupational health and safety and occupational risk prevention, adapted to the legal requirements applicable in each case.
All employees are responsible for observing strict compliance with health and safety standards, applying the corresponding rules and recommendations, with the aim of minimizing and preventing occupational hazards.
The Company considers that both the objective of preserving a healthy work environment and achieving highly productive professional environments are incompatible with the use of illegal psychotropic substances or alcohol abuse. The performance of work functions under their effects will be sanctioned in accordance with the applicable rules (among others, those included in the applicable collective bargaining agreement).
The Company will promptly and periodically inform its employees about the main lines of its strategic plan and the Company’s progress.
All Company employees must act in a spirit of collaboration, making available to other Company units and individuals the knowledge or resources that may facilitate the achievement of the Company’s objectives and interests.
Employees must work efficiently and responsibly during the workday, making the most of the time and resources that the company makes available to them, and trying to contribute maximum value in all the processes in which they participate.
Company personnel are obliged to respect the personal and family privacy of all persons, both employees of the entity and any other persons to whose data they have access as a result of their professional activity.
The use of the data must follow the general established channels, complying with the general principles of use and compliance with internal procedures.
Compliance with the procedures and manuals developed in compliance with data protection regulations is mandatory for the Company’s personnel affected by the same.
The Company undertakes to request and use only those data of employees and collaborators that are necessary or whose proof is required by the applicable regulations.
The Company will take all measures to preserve the confidentiality of the personal data in its possession.
Employees who, in the course of their professional activities, have access to information of other employees or collaborators shall respect and promote the confidentiality of this information and shall use it in a responsible and professional manner.
The Company respects the personal communications of its employees and professionals through the Internet and other means of communication in accordance with internal regulations regarding the use of computer media owned by the Company; however, employees undertake to make responsible use of the means of communication and, in general, of any other means made available to them.
In recognition of the importance of maintaining a healthy balance between the personal and professional responsibilities of our employees, the Company deeply values the benefits that this balance brings, both to the individual well-being of employees and to the success and sustainability of the organization as a whole. Therefore, the Company is committed to promoting measures that facilitate the work-life balance of our employees.
In addition, it promotes an organizational culture that recognizes and celebrates the importance of work-life balance, fostering a mindset of mutual respect and support among colleagues. In doing so, we aim to cultivate a work environment in which employees feel valued, motivated and able to achieve a satisfactory balance between their professional and personal responsibilities.
The behavior of Company personnel shall be governed by respect for other employees and third parties, and disrespect or a hostile attitude towards a third party within the scope of the professional relationship shall not be permitted or protected in any way.
In no way may the labor, professional or contractual relationships established by the Company’s employees among themselves or with other people be used to promote situations of harassment or intimidation or any other situation that violates their personal dignity or involves discrimination.
Any manifestation of violence, harassment, abuse of authority and any other behavior that generates intimidation or contempt towards people is rejected.
The dignity of people, as well as the absence of personal and professional discrimination, are two fundamental principles that must govern the behavior of all Company personnel.
The Company makes available to its employees the resources necessary for the performance of their professional activity and undertakes to provide the necessary means for the protection and safeguarding of the same.
Employees shall not use such resources for personal or extra-professional uses or for the performance of activities that are not directly related to the interest of the Entity, and shall be responsible for the protection of those resources entrusted to them in connection with their work, observing the utmost care in their custody.
All employees must use the Company’s resources responsibly, efficiently and appropriately in the context of their professional activities. Likewise, they shall avoid any action, especially superfluous activities and expenses, that may be detrimental to the Company.
The Company limits the possibility of acquisition of assets belonging to its corporate assets by employees to those cases in which the transaction is the result of a transparent bidding process, of an unrestricted nature and in which objective award criteria are applied.
The Company is the owner of the property and the rights of use and exploitation of the computer programs and systems, equipment, products, manuals, projects, studies, reports and other works and rights created, developed, improved or used by its employees, within the framework of their work activity.
Professionals shall respect the principle of confidentiality regarding the characteristics of the rights, licenses, data, programs, systems and technological knowledge, in general, whose ownership or exploitation or use rights correspond to the Company. In no case shall they make use of these for their own benefit, except for their work, nor shall they transfer them, with or without consideration, to third parties, even after termination of their employment relationship.
Employees shall not exploit, reproduce, replicate or transfer the Company’s computer systems and applications for purposes unrelated to the Company. Likewise, employees shall not install or use in the computer equipment provided by the Company programs or applications whose use is illegal or that may damage or harm the systems or damage the image or interests of the Company, customers or third parties.
When employees identify a problem or have a concern regarding a particular issue, they should raise it internally through the Department Heads, Human Resources, or the Company’s Management Committee.
Professionals, in addition to raising their doubts or submitting complaints through the usual channels, also have a confidential whistleblower channel that the Company makes available to them. Complaints submitted through this channel will be received by the Chief of Legal and Compliance Officer.
The Company will not tolerate any form of retaliation against employees who raise concerns and reports of wrongdoing in good faith. Employees who encourage whistleblowing and reporting will be treated with complete confidentiality.
Employees may not engage in outside activities, whether paid or unpaid, that could damage or conflict with the interests or image of the Company, and must therefore avoid situations that could give rise to a conflict between personal interests and those of the Company, and shall therefore refrain from representing the Company or intervening or influencing decision-making in any situation in which, directly or indirectly, they or a relative have a personal interest. In this way, they shall always act with absolute loyalty in the performance of their responsibilities.
Notwithstanding the foregoing, the involvement of employees in professional and business activities other than those they carry out in the Company is recognized and respected, provided they are legal and do not conflict with the responsibilities they have as employees. Therefore, the following shall be understood as permitted activities:
All these activities may not limit the availability or flexibility of time required for certain functions in the Company, nor may they reduce the efficiency in the performance of these functions.
Situations that could be considered a conflict of interest and are not defined above must be reported to the Chief of Legal and Compliance Officer for appropriate assessment.
No employee may grant, approve or influence the approval of financing or business between the Company, customers or suppliers with whom he/she has personal or family ties, or represent the Company in transactions or operations in which his/her personal or family interests may conflict with the interests of the Company.
At PIB Group Iberia, we defend honesty in commerce and transparency in the markets through fair competition, rejecting any corrupt practice. We compete based on the quality and innovation of our products and services; never offering third parties -clients, suppliers, consultants, competitors or authorities- benefits or advantages that are inappropriate and whose purpose is to obtain an advantageous or improper position in a commercial transaction or in the market, in general. PIB Group Iberia’s assets may not be used to try to influence the will of the recipient of such assets.
Consequently, PIB Group Iberia prohibits all its collaborators to offer, promise, guarantee, deliver or authorize the delivery of bribes, either through the delivery of money or any other type of benefit, advantage or favor, directly or indirectly -through consultants, agents, partners or intermediaries in general- to customers, suppliers, business partners, public officials or any other person or entity with which PIB Group Iberia maintains or may maintain relations of any kind.
Likewise, it is strictly forbidden for all employees of PIB Group Iberia to demand, request, accept, obtain or receive bribes or promises in the form of money or any other type of benefit, advantage or favor from any person or entity, which could in any way influence their objectivity and impartiality or influence their professional decisions. However, this does not apply in the case of occasional gifts or tokens of token value, as well as meals or events to which the employee is invited in the normal course of a business relationship, which are customary in accordance with local customs and are of reasonable value. For these purposes, gifts or presents are permitted if they meet the following conditions:
Any benefit, advantage, gift or present, or any other type of attention offered or received by Company employees that does not comply with the conditions set forth above must be refused or returned and, if there are clear indications that it is a bribe, it must be reported to the CCO.
Additionally, in cases where PIB Group Iberia works with consultants, agents, intermediaries or business partners, it is necessary that they know the values and ethical principles of the Company in relation to anti-corruption practices, as well as the rules, and submit to them. In addition, it is the responsibility of whoever is in charge of signing collaboration contracts to previously evaluate not only the professional suitability of such third parties, but also their reputation. In this sense, the inclusion of specific and appropriate clauses in the aforementioned contracts must be considered, in order to protect PIB Group Iberia.
In line with our core values of fairness and equality at work, the Company is committed to fully respect the freedom of association and collective bargaining of its employees. We recognize the right of employees to associate freely and to participate in union activities in the exercise of their labor rights.
PIB Group Iberia is committed to maintaining an open and collaborative attitude towards employee representation, recognizing its importance as an integral part of the work environment. We value constructive dialogue and good faith negotiation as fundamental tools to address the concerns and needs of our employees.
In addition, we are committed to fostering an inclusive and respectful work environment, where all voices are heard and considered when making decisions that affect employees. This involves establishing effective channels of communication and consultation with union representatives, as well as ensuring transparency in our labor processes and policies.
By maintaining this collaborative stance, we aim to promote harmonious and constructive labor relations, based on mutual respect and the search for joint solutions for the benefit of our entire labor community.
The Company’s employees, in the exercise of the competencies and activities attributed to them, shall maintain personal, commercial and professional conduct with integrity, respecting the commercial laws or others that regulate economic activity and business life, as well as the good practices of the insurance sector.
For these purposes, and taking into account that the regulations applicable to the insurance mediation sector -as well as those related to money laundering and financing of terrorism-, oblige brokerage firms to accredit the compliance of their employees and managers with this requirement, all the Company’s employees undertake to have no criminal record for the commission of crimes related to assets, socioeconomic order, the exercise of financial activities, against the Public Treasury, Social Security, and the Public Administration; And not to have been administratively sanctioned in insurance, banking, securities market, Public Treasury, Social Security, unfair competition or market abuse, movement of capital, economic transactions with foreign countries, money laundering and financing of terrorism and protection of consumers and users, for having incurred in infractions classified as very serious or serious.
The Company and its employees shall base their relations with customers, suppliers, competitors and partners, as well as with other market agents, on the principles of integrity, professionalism and transparency, on the ethical values contained in the Code and on the following guidelines for action:
The Company considers its customers as the center of its activity, in order to establish lasting relationships with them based on the reciprocal contribution of value and mutual trust.
The Company adds value through professional advice and innovation in the configuration and efficient provision of insurance products and services adapted to the needs of its customers at all times.
The principles that should always govern and be present in our relationship with our customers are:
The Company is unwaveringly committed to excellence in the quality of its products or services, as well as to the continuous improvement of its organizational processes to guarantee optimum attention and service to its customers.
In order to fulfill this commitment, the Company will devote all necessary resources to achieve excellence in all aspects of its operation. This involves a constant review of our processes and procedures, as well as the implementation of appropriate measures to ensure that our quality policy is integrated and practiced at all levels of the organization.
In this context, it is imperative that all employees and partners adhere to these quality principles. It is expected that any concerns, errors or omissions that may negatively affect the customer experience will be reported immediately to the relevant line managers. In addition, a designated channel will be established to report any actual or potential legal claims, as well as any errors, omissions or complaints received. The goal is to address these issues quickly and effectively, ensuring a satisfactory resolution for all parties involved and preserving the Company’s reputation and integrity.
The Company considers that one of the main elements on which the trust of its customers is based is the appropriate safeguarding of their information and the effective limitation of its use in accordance with the provisions of the applicable legal provisions in each case.
Non-public data held by the Company about customers, suppliers, employees or third parties are confidential and must be treated in compliance with the contractual confidentiality agreements to which they are subject, and in any case, in accordance with the applicable data protection regulations in force.
Personnel handling such data have a responsibility to provide appropriate custody and use of such data.
The non-public information that the Company has about its customers and their operations is confidential. The Company has adopted policies and procedures to:
Employees who, by reason of their position or professional activity, have or have access to customer information, are responsible for its custody and appropriate use.
The Company’s non-public information and documentation is considered a fundamental asset, and its appropriation by Company personnel is not permitted.
The duty of confidentiality in those who have had access to personal data and/or confidential information shall subsist even when the employment relationship has ended.
The Company is committed to providing its customers with timely, accurate and understandable information about its operations, as well as clear and truthful information about:
The Company’s employees must respect the principle of transparency, and is obliged to ensure that no action of theirs may be interpreted as deception to the detriment of customers, suppliers or third parties, informing anyone interested in taking out insurance of the conditions, coverage and other aspects of the contract that, in their opinion, should be subscribed.
Company personnel must refrain from entering into contracts on behalf of clients unless they have previously received the mandate and consent of the latter.
Any complaint from a customer, an insurer or a third party must be handled in accordance with the internal procedure, documented and answered in an appropriate manner and form by the person or body designated for this purpose. The purpose of these guidelines is to demonstrate that we put the interests of our clients before our own and act in a professional manner.
This commitment requires special diligence in the professional performance of all persons with responsibility for the maintenance of processes and information systems for customers, in the personal attention to their requests for information and in the resolution of their complaints.
Personnel who manage the presentation of bids in public or private tenders must refrain from any type of conduct that could be understood as price fixing, either with the bidder itself or with third party participants.
The Company applies corporately established criteria that regulate the acquisition of goods and services, as well as the selection of external collaborators in such a way that they are carried out in accordance with the following principles:
The selection processes for external collaborators, suppliers and providers shall be adapted to criteria of objectivity and impartiality, and any conflict of interest or favoritism in the selection of these shall be avoided.
The Company shall promote, whenever possible, the concurrence of a plurality of collaborators and suppliers of goods and services whose characteristics and conditions offered are adjusted, at all times, to the needs and requirements of the Company.
All employees who participate in supplier and external collaborator selection processes have the obligation to act impartially and objectively, applying quality and cost criteria, avoiding the collision of their personal interests with those of the Entity.
Prices, fees and information submitted by collaborators, suppliers and providers in a selection process will be treated confidentially and will not be disclosed to third parties, except with the consent of the interested parties and except in cases of legal obligation, or in compliance with judicial or administrative resolutions.
Notwithstanding the foregoing, when necessary in any negotiation process, only the reference prices would be disclosed to all bidders without identifying the incumbent supplier companies.
Employees who, due to their activity, have access to data related to suppliers and providers, must maintain the confidentiality of such data and comply with the provisions of the legislation on personal data protection, to the extent applicable.
The Company is committed to compete fairly in the markets in which it operates, promoting free competition and complying with the legal provisions in force, which benefits consumers and the efficiency and competitiveness of the companies.
Relations with competitors must be fair and governed by the principle of respect for the business activity of the third party. Company personnel are obliged to ensure the confidentiality of any kind of reserved or sensitive information of other companies, to which they have had access in a lawful manner and within the framework of negotiations or business relations.
Obtaining information from other competitors or any third party may only be done by strictly legal means, and insider information may not be used.
Employees shall refrain from carrying out or promoting any action that may be contrary to the regulations on this matter. Any action that raises any kind of doubt in this regard must be consulted with the Management Committee before being carried out.
No employee who joins the Company may use confidential or secret documentation that he/she may have obtained from previous employment. This unlawful use of documentation outside the Company is expressly prohibited.
The duties of confidentiality of the Company’s personnel shall survive indefinitely, even when the employment relationship has ended. Employees may not take any information or documentation of the Company, including that in computerized format, or provide or use such information in the interest of another company.
Personnel who manage the presentation of bids in public or private tenders must refrain from any type of conduct that could be understood as price fixing, either with the bidder itself or with third party participants.
In accordance with our internal policies and in strict observance of the laws in force, we wish to emphasize that the making of any type of donation to political parties, as well as to their foundations or federations, on behalf of our Company, is strictly prohibited. This mandate also includes the use of corporate funds to finance any political party, even indirectly.
We firmly believe in the importance of maintaining impartiality and transparency in our operations, and therefore reaffirm our commitment to political neutrality and rigorous compliance with established regulations to ensure integrity and ethics in all our business activities.”
Relations with authorities, regulatory bodies and administrations shall be subject to the principles of cooperation and transparency.
In order to be able to determine the existence of incompatibilities, the Chief of Legal and Compliance Officer shall be informed prior to accepting any public office.
Company employees shall not offer, promise or give any kind of gift or form of bribe or unjustified benefit to officials, authorities, or unjustified commission to third parties or insurance companies. Acts of bribery, which are expressly prohibited and punishable, include the offer or promise, direct or indirect, of any type of advantage or the use of any instrument for its concealment.
No gifts or hospitality shall be offered or given to persons or institutions with which the Company has a relationship and which may improperly influence their decision-making processes or the relationship itself. Only those gifts of social courtesy that are part of the internal policy established for this purpose shall be admissible, always in accordance with current legislation and the rules and procedures of the entity potentially receiving them.
Company employees who have a relationship with any authority or public official who may influence any aspect of the Company must avoid influencing, even indirectly, any decision that may affect the Company.
Compliance with tax obligations and social security payments to which the Company is obliged shall be carried out in a responsible, loyal and appropriate manner in accordance with current legislation.
Company personnel are obliged to respect the principles of clarity, transparency and truthfulness in their professional performance. The falsification, concealment or simulation of data, accounting entries, etc. with the purpose of avoiding payments or obtaining illicit benefits that cause damage to the Treasury, the Social Security or any creditor is strictly forbidden.
The Company’s economic-financial information must faithfully reflect its economic, financial and equity reality, in accordance with generally accepted accounting principles and applicable international financial reporting standards. For this purpose, no professional shall conceal or distort the information in the Company’s accounting records and reports.
The Company’s employees responsible for accounting and finance are obliged to comply exhaustively with the regulations affecting accounting, financial, economic, tax, or any other aspects that affect the Company’s tax declarations.
The Company, as an obliged subject in the prevention of money laundering and financing of terrorism, has the procedures and manuals referenced in the regulations for the prevention of money laundering. The Company establishes policies to prevent and avoid in the course of its operations the making of irregular payments or money laundering originating in illicit or criminal activities.
Company personnel, in order to avoid incurring the risk of money laundering, must act in accordance with the manuals, training and procedures approved for this purpose.
PIB Group Iberia does not facilitate money laundering or the financing of terrorist activities. For this reason, we collaborate with the competent authorities of each country in the fight against money laundering and the financing of terrorist activities, providing all the information they request from us in accordance with the legal rules and regulations in force on the matter, as well as reporting suspicious transactions.
The Company, following the recommendations of the Financial Action Task Force (FATF) and in accordance with the provisions of Law 10/2010 of April 28, 2010, has implemented a series of specific rules and procedures for the prevention and detection of money laundering and terrorist financing operations of PIB Group Iberia companies subject to money laundering. Among these procedures, we highlight:
The Company is committed to acting in a socially responsible manner, aimed at generating wealth for the society in which it operates, making this action compatible with the necessary business profit.
The Company’s managers are committed to ensuring the sustainability of the company, giving priority to this principle over short-term profit, as well as to pursuing the general interest above their own personal interests.
The Company’s commitment to society is materialized in the development of sponsorships, patronage and collaborations, which may be channeled through agreements and allocation of resources to social organizations and institutions, in a manner consistent with the Company’s strategy.
Likewise, through the Company and the voluntary collaboration of its employees, solidarity projects will be promoted and developed.
The Company recognizes the critical importance of preserving and protecting our environment in all our operations and business activities. As part of our commitment to sustainability and environmental responsibility, we are firmly committed to adopting business practices that seek the greatest possible respect for the environment and to minimize any negative impact our activities may have on it.
To achieve these objectives, the Company will provide its employees with the appropriate means and the necessary training to promote environmental awareness and the application of sustainable practices in all areas of our activity.
In addition, we are committed to strictly comply with all environmental legislation applicable to our operations, as well as to actively promote the adoption of good environmental practices among our employees and other stakeholders with whom we interact. This involves not only complying with existing regulations, but also constantly seeking opportunities to improve our environmental performance and reduce our ecological footprint.
In making this commitment, we seek not only to protect and preserve our natural environment for future generations, but also to contribute to the well-being of the communities in which we operate and to reinforce our reputation as a socially responsible company committed to sustainability.
As a consequence of the development of its business activities, the Company obtains from its customers, employees, collaborators, suppliers and administrators, or from other individuals with whom it relates, information of a personal nature, which it considers private to the individual.
In addition to the commitment to confidentiality reflected in various points of this Code, the Company has established a set of specific rules and procedures, set out in the Data Protection Policy, which have been adopted by the Company in order to protect and ensure the appropriate treatment of personal data.
These rules and procedures must comply with the legal requirements applicable in each case.
Regardless of the responsibilities specifically assigned to certain areas of the Company regarding information security and personal data protection, employees who, by reason of their position or professional activity, have or have access to this type of data, are responsible for its custody and appropriate use.
As part of our commitment to transparency and integrity in financial management, the Company has implemented specific procedures designed to ensure that our financial statements are prepared accurately and in strict compliance with applicable valuation principles and standards at all times.
Under no circumstances will any Company professional be allowed to conceal or distort the Company’s economic or financial information. We value transparency and honesty in the presentation of financial information, and we are committed to the highest ethical and professional standards in all our financial and accounting activities.
To ensure compliance with these principles, we foster an organizational culture that promotes accountability and responsibility at all levels of the company.
In line with our commitment to transparency and accountability to all our stakeholders, the Company is committed to providing truthful, relevant and useful information in all its communications, following the fundamental principle of transparency. We recognize the importance of keeping our stakeholders and the general public informed about our management, operations and results, ensuring that such information is accessible and understandable to all.
To fulfill this commitment, we pledge to disclose any information, both internal and external, in an honest and accurate manner, without seeking to confuse or mislead the recipient of the information. We value integrity and clarity in all our communications and strive to ensure that our actions and words reflect our core values and principles.
As for our relations with the media and financial analysts, we are committed to channeling them through our Presidential Secretariat. This centralization ensures coherence and consistency in our external communications, as well as the protection of confidential information and the proper management of relations with the media and analysts.
By adopting these practices, we reaffirm our commitment to transparency and integrity in all our operations and communications, thereby strengthening our company’s trust and credibility with all our stakeholders.
The Company recognizes and respects the intellectual property rights of third parties as a fundamental principle in its business ethics. Therefore, it is the responsibility of all Company personnel to ensure absolute respect for these rights in the performance of their professional duties.
In this regard, employees undertake not to use images, texts or drawings in Company advertising or official documents without the corresponding authorization from the legitimate owner. This implies performing due diligence to obtain the necessary permissions before using any content protected by copyright or intellectual property.
In addition, it is strictly forbidden to use trademarks or logos in the Company’s advertising or official documents without having previously obtained the corresponding authorization or without having registered these trademarks in the Company’s name. It is essential to verify the existence of prior industrial property rights registered in favor of third parties before using any trademark or logo in our communications.
We are also committed to ensuring that all advertising by the Company is truthful and does not contain misleading statements that may cause harm to potential customers. We value honesty and transparency in all our business communications and strive to maintain the trust and credibility of our brand with the public.
By adhering to these principles, we reaffirm our commitment to integrity and respect for intellectual property rights, thus ensuring ethical and responsible conduct in all our business and communication activities.
The Company recognizes the importance of establishing clear and consistent ethical and behavioral standards to guide the actions of all employees and collaborators. In this regard, it is essential that all members of the organization are fully informed and committed to the principles and standards established in our Code of Ethics and Conduct.
In order to ensure broad understanding and effective adherence to these principles, the Company is committed to actively communicate and disseminate the Code of Ethics and Conduct to all employees and collaborators. This includes availability in digital formats accessible through the Company’s internal communication channels.
In addition, we are committed to ensuring that all employees who join or become part of the Company receive a copy of the Code of Ethics and Conduct and expressly accept the values, principles and standards of action established therein. This explicit and formal acceptance ensures that all members of our organization are fully committed to the ethical standards and conduct that we promote as a company.
By communicating, disseminating and making the Code of Ethics and Conduct mandatory for all our employees and collaborators, we reaffirm our commitment to integrity, ethics and responsibility in all our operations and business relationships. This not only strengthens our corporate culture, but also contributes to maintaining our stakeholders’ trust and respect for the Company.
The monitoring and control of the application of the Code of Ethics and Conduct shall be the responsibility of the Company’s Management Committee, without prejudice to the functions attributed to other areas of the Company.
The Management Committee, as far as this Code is concerned, shall ensure that:
Any modification to the Code shall require the approval of the Company’s Management Committee. Likewise, suggestions and proposals made by employees and collaborators and the commitments acquired by the Company in matters of social responsibility and good governance will be taken into account.
Any doubts that may arise regarding the interpretation of the Code and its application should be referred to the immediate superior. If circumstances so require, the CCO may be consulted.
Any indication of irregularity or non-compliance with the rules of the Code must be reported to the immediate superior. The latter shall contact the company’s Management Committee, which shall take the measures it deems appropriate in this regard.
The confidentiality of the information provided, as well as the identity of the informant, shall be guaranteed. In any case, the Company undertakes not to take any direct or indirect retaliation against professionals who have reported an alleged irregularity.
When it is determined by the Management Committee that a Company professional has carried out activities that contravene the provisions of the Code of Ethics and Conduct, the appropriate disciplinary measures will be applied in accordance with the seriousness of the conduct infringed and in accordance with the applicable regulations.
Failure to comply with any rule by an employee may constitute sufficient reason for disciplinary action, up to and including termination of employment.
The Company has established formal channels so that all employees or collaborators can:
To ensure a culture of compliance and transparency, the Company recognizes the importance of establishing effective communication and reporting channels for employees and collaborators to raise queries and report possible breaches of the Code of Ethics and Conduct.
In this regard, employees or collaborators have the freedom and duty to make inquiries related to the interpretation or application of the Code of Ethics and Conduct to their direct manager. In the event that the inquiry requires specialized attention or a higher level of authority, they may also address the CCO, who is designated to oversee compliance with the company’s ethical and legal policies.
In addition, if an employee detects a possible breach of the Code of Ethics and Conduct, he/she is encouraged to report it immediately. This can be done directly to their line manager, to the CCO, or through the Company’s whistleblowing channel. This whistleblowing channel provides a confidential and secure way to report ethical irregularities or misconduct, ensuring the protection of the whistleblower and the appropriate investigation and response by the company.
By establishing these communication and reporting channels, the Company reaffirms its commitment to transparency, accountability and respect for all its employees and collaborators. These mechanisms not only allow us to quickly address potential ethical issues, but also foster a culture of trust and collaboration throughout the organization.
| Version No. | Date | Publisher | Approved by: | Description of change |
| 1.0 | 31/05/20204 | Legal & Compliance | Chief Legal & Compliance Officer | Initial version |
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