This document shall apply, independently, to all employees of PIB Group Iberia Correduría de Seguros y Reaseguros S.A.U., hereinafter, interchangeably, “PIB Group Iberia” or “the Company”, which for these purposes includes, by way of example but not limitation: permanent and temporary employees – full-time or part-time; trainees and apprentices; volunteers; interns; directors and other collaborators with an employment or commercial relationship. Henceforth, and for the sole purposes of this document, “employees”.
Ethical values are the essential and enduring principles of an organisation. They are those non-negotiable and fundamental values that must guide all our actions and behaviours, and that form the organisation's identity.
The Company's Management considers Corporate Integrity, understood as the systematic observance of strict standards of ethical behaviour within the company, to be a source of stable value creation and an indispensable requirement for preserving society's trust in any institution, protecting the company's reputation in all its aspects.
In this regard, the Company's Code of Ethics represents a compulsory guide for conduct and behaviour, which develops the basic ethical principles so that the actions taken 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, particularly Organic Law 5/2010 of 22 June, which reforms the previous Spanish Criminal Code. Furthermore, international treaties on human rights, prevention of money laundering and terrorist financing, anti-corruption, and sustainability have been taken into account.
All of this, with the objective 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 current laws and the ethical norms and principles of our society.
This Code of Ethics and Conduct has been approved by the Company's Board of Directors and its compliance is enforceable for both management and all employees who make up the Company. All are obligated to respect the principles set out herein and to comply with internal procedures for the better functioning of the Company. Henceforth, the Code shall refer to all of them, interchangeably, as employees, irrespective of the position they hold or the location where they carry out their activity.
Although, as is logical, responsibility increases with hierarchical level, adherence to and compliance with the principles and rules established in this Code are always and without exception mandatory for all employees of PIB Group Iberia.
Failure to comply with this can have serious consequences for the company, such as penalties, damage to reputation, loss of customers and market confidence, etc.
Serious breaches of this Code may lead to disciplinary measures, which could result in dismissal and/or legal action.
The content of the Code shall take precedence over that of any internal rules that may contradict it, unless such rules establish more stringent behavioural requirements.
The application of the content of the Code shall under no circumstances lead to a breach of applicable legal provisions.
If this circumstance is appreciated, the contents of the Code shall be adjusted to comply with the provisions of said legal dispositions.
This Code of Conduct is not intended to be an exhaustive manual covering every possible case or situation that an employee of PIB Group Iberia might find themselves in. It is a guide for action and behaviour, the fundamental objective of which 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 entity's sustainability. To this end, the Company's primary management layer and all its leadership team will serve as a role model in their behaviour and compliance with the Code, and will employ all available means to disseminate the Company's values and principles, ensuring the guidelines for conduct contained therein are enforced without exception.
Any doubt that may arise in relation to the interpretation of this Code of Conduct, as well as its practical application, should be consulted with the immediate hierarchical superior or with the Chief Compliance Officer (CCO), who is responsible for the monitoring and control of its proper application.
All employees of PIB Group Iberia have the duty and obligation to comply with the ethical values and principles of this Code of Ethics and Conduct, as well as with all the rules derived from it.
The Code will be made available to staff so that they can familiarise themselves with it and raise any questions that its interpretation might give rise to.
This Code cannot cover all possible situations, so it is necessary to exercise good judgement and due diligence to differentiate the professional and correct conduct required by each situation.
PIB Group Iberia will ensure that no form of punishment or reprisal is applied to any collaborator who, acting with integrity, loyalty and good faith, has reported any behaviour contrary to the values and principles to the CCO.
All business objectives and actions pursued must be consistent with the Company's core values.
As the foundation of Ethical Principles, core values foster trust among all stakeholders, to help meet or even exceed expectations.
The business and professional conduct of those who make up the Company must therefore adhere to the following principles, which are key to its culture:
Specifically, and due to the special regulation of the sector in which the activity is carried out, Royal Decree-Law 3/2020, of 4 February, on urgent measures incorporating various European Union directives into Spanish law in the field of public procurement in certain sectors; private insurance; pension plans and funds; the tax field and tax litigation, must be complied with exhaustively.
The Company's and its employees' and collaborators' business and professional activities are based on the value of integrity and are carried out in accordance with the principles of honesty, the avoidance of all forms of corruption, and respect for the particular circumstances and needs of all individuals involved in them. We treat all people fairly and honestly. We comply with all applicable laws, regulations, and internal policies.
Regarding our specific activity, it is not permitted to conceal information from a client or potential client about the products that are offered to them or that they have contracted.
The professionals who make up PIB Group Iberia are subject to obligations and duties within our professional undertaking. Our actions and the way we behave directly impact the Company's reputation in the markets and society. Inappropriate behaviour or breaches of the law by any of our colleagues can cause considerable or even irreparable damage to our organisation's image and reputation. It is the responsibility of each and every one of us to maintain appropriate behaviour to promote the good image and reputation of the Company in all the communities and countries where it is present.
The Company promotes the professional and personal development of all its employees and collaborators, ensuring equal opportunities through its policies.
No discrimination of any kind is permitted in the workplace or professional sphere on the grounds of age, race, sex, religion, political opinion, social origin, sexual orientation, or disability.
The Company supports, and is committed to continuing to implement and develop, policies aimed at the employment integration and promotion of employment opportunities for people with disabilities.
The Company undertakes to establish an effective equal opportunities policy so that its employees can pursue their professional activities on the basis of merit. Promotion decisions will be based on objective circumstances and assessments.
The Company also commits to maintaining an investment policy for the personal and professional learning and development of its employees and collaborators.
Employees shall respect and promote the equal opportunities policy in their professional sphere, commit to their personal and continuous training, and support the personal and professional development of their colleagues.
In general, the Company's selection processes will be open, allowing the largest possible number of individuals with the appropriate qualifications to fill the advertised position. These processes will be conducted according to objective assessment methods that take into account, based on proven merit and always under the principle of equal opportunities, the professional qualifications and capabilities of the candidates.
The new offers will be published internally first, to ensure that Company employees can apply on equal terms.
Those persons who are directly or indirectly responsible for the selection and/or hiring of personnel shall base their decisions and actions on the criteria established in the Company's selection and hiring procedures, without admitting the influence of factors that may alter the objectivity of their judgement.
Company employees will participate in the definition of their objectives and will be informed of the evaluations they receive.
The Company guarantees its employees a health risk-free environment in all its facilities. This objective is met through the adoption of standards and procedures inspired by best international practices in occupational health and safety, adapted to the legal requirements that apply in each case.
All employees are responsible for rigorously observing health and safety regulations, applying the corresponding rules and recommendations, with the aim of minimising and preventing workplace risks.
The Company considers that both the objective of preserving a healthy working environment and the achievement of highly productive professional settings are incompatible with the consumption of illegal psychotropic substances or alcohol abuse. Performing work duties under the influence of these will be subject to sanction in accordance with applicable regulations (including, but not limited to, those included in the relevant collective bargaining agreement).
The Company will inform its employees promptly and regularly about the main points of its Strategic Plan and the Company's progress.
All employees of the Company must act in a spirit of collaboration, making available to other units and individuals within the Company the knowledge or resources that may facilitate the achievement of the Company's objectives and interests.
Employees must work efficiently and responsibly during working hours, making the most of the time and resources the company makes available to them, and striving to add maximum value to all processes in which they participate.
Company staff are obliged to respect the personal and family privacy of all individuals, both the entity's employees and any other individuals whose data they access due to their professional activities.
The use of data must follow the general guidelines established, adhering to the general principles of use and compliance with internal procedures.
Compliance with the procedures and manuals developed in accordance with data protection regulations is mandatory for Company personnel subject to them.
The Company undertakes to request and use exclusively those data of employees and collaborators that are necessary or whose record is required by applicable legislation.
The Company will take all measures to preserve the confidentiality of the personal data it holds.
Employees who, through the performance of their professional activity, have access to information of other employees or collaborators will respect and promote the confidentiality of this information and will make responsible and professional use of it.
The Company respects the personal communications of its employees and professionals via the internet and other means of communication in accordance with its internal regulations on the use of Company-owned IT equipment. Nevertheless, employees undertake to make responsible use of communication facilities and, in general, of any other means made available to them.
In recognition of the importance of maintaining a healthy balance between our employees' personal and professional responsibilities, the Company deeply values the benefits this balance brings, both to the individual well-being of our staff and to the success and sustainability of the organisation as a whole. Therefore, the Company is committed to fostering measures that facilitate the reconciliation of our employees' work and personal lives.
Furthermore, an organisational culture is promoted that recognises and celebrates the importance of work-life balance, fostering a mindset of mutual respect and support among colleagues. In doing so, the aim is to cultivate a working environment where employees feel valued, motivated, and capable of achieving a satisfying balance between their professional and personal responsibilities.
The Company's staff behaviour will be governed by respect for other employees and third parties, with disrespect or hostile attitudes towards a third party within the professional relationship being neither permitted nor condoned in any way.
Under no circumstances may the employment, professional, or contractual relationships established by the Company's employees among themselves, or with other persons, be used to foster situations of harassment or intimidation or any other that is an attack on their personal dignity or constitutes discrimination.
Any display of violence, harassment, abuse of authority, or any other behaviour that generates intimidation or contempt towards people is rejected.
The dignity of individuals, as well as the absence of personal and professional discrimination, are established as two fundamental principles that must govern the behaviour of all Company staff.
The Company makes available to its employees the necessary resources for the performance of their professional activity and undertakes to provide the necessary means for their protection and safeguarding.
Employees shall not use such resources for personal or non-professional purposes, or for the performance of activities not directly related to the interests of the Entity. They shall also be responsible for the protection of any resources entrusted to them in connection with their work, exercising the utmost care in their safekeeping.
All employees must use the Company's resources responsibly, efficiently, and appropriately within the scope of their professional activities. Likewise, they shall avoid any action, particularly superfluous activities and expenses, that may harm the Entity.
The Company restricts the possibility of employees acquiring assets belonging to its business patrimony to those cases where the transaction results from a transparent, non-restricted bidding process and where objective award criteria are applied.
The Company owns the property and rights of use and exploitation of computer programs and systems, equipment, products, manuals, projects, studies, reports, and other works and rights created, developed, improved, or used by its employees as part of their employment.
Professionals shall respect the principle of confidentiality with regard to the characteristics of the rights, licences, data, programmes, systems and technological knowledge, in general, belonging to the Company or of which the Company holds exploitation or usage rights. Under no circumstances shall they make use of these for their own benefit, except for their work, nor shall they assign them, with or without consideration, to third parties, even after their employment relationship has ended.
Employees shall not exploit, reproduce, replicate or assign the Company's IT systems and applications for purposes unrelated to the Company. Likewise, employees shall not install or use on the IT equipment provided by the Entity programmes or applications that are used illegally or that may harm or damage the systems or prejudice the image or interests of the Company, its clients or third parties.
When employees detect a problem or have a concern relating to a particular matter, they should raise it internally through their Department Managers, Human Resources, or the Company's Management Committee.
In addition to raising their concerns or making complaints through the usual channels, professionals also have a confidential reporting channel made available to them by the Company. Complaints submitted through this channel will be received by the Chief Legal and Compliance Officer.
The Company will not tolerate any form of reprisal against employees who raise concerns and report illicit conduct in good faith. Employees who promote reporting and whistleblowing will enjoy complete confidentiality.
Employees shall not undertake external activities, whether paid or unpaid, that could harm or conflict with the Company's interests or image. Therefore, they must avoid situations that could lead to a conflict between personal interests and those of the Company, and shall refrain from representing the Entity or intervening or influencing decision-making in any situation where they themselves or a relative directly or indirectly has a personal interest. In this way, they must always act in the fulfilment of their responsibilities with absolute loyalty.
Notwithstanding the above, the involvement of employees in professional and business activities outside of those they undertake for the Company is recognised and respected, provided that they are legal and do not conflict with their responsibilities as employees. Therefore, the following will be considered permitted activities:
None of these activities may limit the availability or flexibility of working hours required for certain roles within the Company, nor may they diminish the efficiency with which these roles are performed.
Situations liable to be considered as conflicts of interest and not previously defined shall be reported for timely assessment to the Chief Legal and Compliance Officer.
No employee may grant, approve, or exert influence for the approval of financing or business relationships between the Company and clients or suppliers with whom they are personally or familially linked, nor may they represent the Company in transactions or operations where their personal or familial interests may conflict with the Company's interests.
From PIB Group Iberia, we champion honest commerce and market transparency through fair competition, rejecting any corrupt practices. We compete based on the quality and innovation of our products and services; never offering third parties – clients, suppliers, consultants, competitors, or authorities – inappropriate benefits or advantages aimed at obtaining an advantageous or undue position in a commercial transaction or the market, in general. PIB Group Iberia's assets cannot be used to attempt to influence the will of their recipient.
Consequently, PIB Group Iberia prohibits all its collaborators from offering, promising, guaranteeing, delivering, or authorising the delivery of bribes, whether through the delivery of money or any other type of benefit, advantage, or favour, directly or indirectly – via consultants, agents, partners, or intermediaries in general – to clients, suppliers, business partners, public officials, or any other person or entity with whom PIB Group Iberia maintains or may maintain relations of any kind.
Likewise, all employees of PIB Group Iberia are strictly prohibited from demanding, soliciting, accepting, obtaining, or receiving bribes, or promises thereof, in the form of money or any other benefit, advantage, or favour from any person or entity, which could in any way influence their objectivity and impartiality, or influence their professional decisions. However, this shall not apply to occasional gifts or tokens whose value is symbolic, as well as meals or events to which the employee is invited in the normal course of a business relationship, which are customary according to local practices and have a reasonable value. For these purposes, gifts or tokens are permitted if they meet the following conditions:
Any benefit, advantage, gift, or other form of gratuity, or any other type of attention offered to or received by the Company's employees, that does not comply with the conditions set out above, must be refused or returned and, in the case of clear indications of bribery, must be reported to the CCO.
Furthermore, in cases where PIB Group Iberia works with consultants, agents, intermediaries, or business partners, it is necessary for them to be aware of the Company's values and ethical principles regarding anti-corruption practices, as well as its rules, and to comply with them. Additionally, it is the responsibility of whoever is in charge of signing collaboration agreements to previously assess not only the professional suitability of said third parties but also their reputation. In this regard, the inclusion of specific and appropriate clauses in the aforementioned contracts should be considered, with the aim of protecting PIB Group Iberia.
In line with our core values of fairness and equal opportunity, the Company is committed to fully respecting the freedom of association and collective bargaining rights of our employees. We recognise employees' right to associate freely and engage in trade union activities in the exercise of their labour rights.
PIB Group Iberia is committed to maintaining an open and collaborative attitude towards the representation of workers, recognising their importance as an integral part of the workplace. We value constructive dialogue and good-faith negotiation as fundamental tools for addressing the concerns and needs of our employees.
Furthermore, we are committed to fostering an inclusive and respectful working environment, where all voices are heard and considered in decision-making processes that affect employees. This involves establishing effective channels of communication and consultation with trade union representatives, as well as guaranteeing transparency in our processes and labour policies.
By maintaining this collaborative stance, we aim to foster harmonious and constructive working relationships, based on mutual respect and the pursuit of joint solutions for the benefit of our entire working community.
Employees of the Company, in the exercise of the powers and activities assigned to them, shall maintain personal, commercial and professional integrity, respecting 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 relating to money laundering and terrorist financing – oblige brokerages to verify that their employees and directors meet this requirement, all Company employees undertake to have no criminal record for the commission of offences relating to property, the socio-economic order, the exercise of financial activities, against public finance, social security, and public administration; and not to have been administratively sanctioned in matters of insurance, banking, the securities market, public finance, social security, unfair competition or market abuse, capital movements, foreign economic transactions, money laundering and terrorist financing, and consumer and user protection, for having incurred in very serious or serious infringements.
The Company and its employees will base their relationships with their clients, suppliers, competitors, and partners, as well as with other market participants, 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 clients to be at the centre of its activities, with the aim of establishing long-lasting relationships based on the reciprocal contribution of value and mutual trust.
The Company provides value through professionalised advice and innovation in the efficient design and delivery of insurance products and services tailored to the needs it perceives from its clients at any given moment.
The principles that should govern and always be present in our relationship with clients are:
The Company is unyieldingly committed to excellence in the quality of its products or services, as well as to the continuous improvement of its organisational processes to guarantee optimal customer care and service.
To fulfil this commitment, the Company will dedicate 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 practised at all levels of the organisation.
In this context, it is imperative that all employees and collaborators adhere to these quality principles. Any concern, error, or omission that may negatively affect the client experience is expected to be communicated immediately to the relevant line managers. Furthermore, a designated channel will be established to report any actual or potential legal claims, as well as any errors, omissions, or complaints received. The objective 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 its clients' trust is based is the appropriate safeguarding of their information and the effective limitation of its use in accordance with the legal provisions that, in each case, are applicable.
Non-public data held by the Company concerning customers, suppliers, employees or third parties is confidential and must be treated in compliance with any contractual confidentiality agreements to which they are subject, and in all cases, in accordance with applicable data protection regulations.
Staff handling this type of data have a responsibility to ensure its appropriate custody and use.
The non-public information which the Company holds about its clients and their operations is confidential. The Company has adopted rules and procedures to:
Employees who, by reason of their position or professional activity, hold or have access to client information, are responsible for its safekeeping and appropriate use.
The Company's information and documentation that is not public is considered a fundamental asset, and its appropriation by the personnel of this Company is not permitted.
The duty of confidentiality for anyone who has had access to personal data and/or confidential information shall remain even when the employment relationship has ended.
The Company undertakes to provide its clients with timely, accurate, and understandable information about its operations, as well as clear and truthful information regarding:
The Company's employees must uphold the principle of transparency and are obliged to ensure that none of their actions can be interpreted as deception to the detriment of clients, suppliers, or third parties, by informing anyone interested in taking out insurance of the conditions, coverage, and other aspects of the contract that they deem appropriate to subscribe to.
Company staff must refrain from entering into contracts on behalf of clients unless they have previously received a mandate and consent from them.
Any claim from a customer, insurer, or third party must be processed according to internal procedure, documented, and responded to in an appropriate manner and form by the designated person or body. The objective of these guidelines is to demonstrate that we prioritise our customers' interests over our own and that we act with complete professionalism.
This commitment requires particular diligence in the professional conduct of all individuals with responsibility for maintaining information systems and processes for clientele, in providing personal attention to their information requests, and in resolving their complaints.
Staff managing the submission of bids in public or private tenders must refrain from any type of conduct that could be construed as price-fixing, either with the bidder themselves or with third-party participants.
The Company applies corporately established criteria that regulate the procurement of goods and services, as well as the selection of external collaborators, so that these are carried out in accordance with the following principles:
The selection processes for external collaborators, suppliers, and providers will be adapted to criteria of objectivity and impartiality, and any conflict of interest or favouritism in their selection will be avoided.
The Company shall, whenever possible, promote the participation of a plurality of collaborators and suppliers of goods and services whose characteristics and offered conditions, at any given time, align with the Company's needs and requirements.
All employees participating in selection processes for external suppliers and collaborators are obliged to act with impartiality and objectivity, applying quality and cost criteria, and avoiding any conflict between their personal interests and those of the Entity.
The prices, fees, and information presented by collaborators, suppliers, and vendors during 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 compliance with judicial or administrative resolutions.
However, the above notwithstanding, when necessary in any negotiation process, reference prices would only be disclosed to all bidders without identification of the owning supplier companies.
Employees who, by virtue of their activity, access data relating to suppliers and contractors must maintain the confidentiality of such data and comply with data protection legislation, to the extent that it applies.
The Company undertakes to compete fairly in the markets in which it operates, promoting free competition and complying with current legal provisions, which redounds to the benefit of consumers and to the efficiency and competitiveness of businesses.
Relations with competitor companies must be fair and guided by the principle of respect for the business activities of others. Company personnel are obliged to ensure the confidentiality of any kind of reserved or sensitive information belonging to other companies, which they have lawfully accessed within the framework of negotiations or business relationships.
Information obtained from other competitors or any third party may only be done by strictly legal means, and privileged information may not be used.
Employees shall refrain from undertaking or promoting any action that may be contrary to the regulation on this matter. Any action that raises any doubt in this regard must be consulted with the Management Committee before being carried out.
No employee joining the Company shall use any confidential or secret documentation they may have obtained from their previous employment. This illicit use of documentation not belonging to the Company is expressly prohibited.
The Company's staff confidentiality obligations will remain in force indefinitely, even after the employment relationship has ended. Employees will not be permitted to take any type of Company information or documentation, including that stored on computer media, nor to contribute or use such information in the interest of another company.
Staff managing tender submissions in public or private tenders must refrain from any conduct that could be construed as price-fixing, either with the bidder themselves or with third parties participating.
In accordance with our internal policies and in strict observance of prevailing laws, we wish to emphasise that making any form of donation to political parties, or to their foundations or federations, in the name of our Company, is strictly prohibited. This directive 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, we reaffirm our commitment to political neutrality and strict adherence to established regulations to guarantee integrity and ethics in all our business activities.»
Our relationships with authorities, regulatory bodies and administrations will be governed by the principles of cooperation and transparency.
In order to determine the existence of incompatibilities, you will be informed Chief Legal and Compliance Officer prior to accepting any public office.
Company employees must not offer, promise, or give any kind of gift, bribe, or unjustified benefit to officials, authorities, or unjustified commission to third parties or insurance companies. Acts of bribery, which are expressly prohibited and penalised, include the direct or indirect offering or promise of any kind of advantage or the use of any instrument for its concealment.
No gifts or favours will be offered or provided to individuals or institutions with whom the Company has a relationship, and which could improperly influence their decision-making processes or the relationship itself. Only those tokens of social courtesy that are part of the established internal policy for this purpose, in accordance with current legislation and the rules and procedures of the potentially recipient entity, will be admissible.
Employees of the Company who have dealings with any public authority or official that could influence any aspect of society must refrain from influencing, even indirectly, any decision-making that affects the Company.
The Company shall meet its tax obligations and social security payments in a responsible, loyal, and lawful manner, in accordance with current legislation.
Company personnel are obliged to adhere to the principles of clarity, transparency and truthfulness in their professional conduct. The falsification, concealment or simulation of data, accounting entries, etc., with the objective of evading payments or obtaining illicit benefits that cause harm to the Public Treasury, Social Security or any creditor, is strictly prohibited.
The Company's economic and financial information must faithfully reflect its economic, financial, and asset reality, in accordance with generally accepted accounting principles and applicable International Financial Reporting Standards. For these purposes, no professional shall conceal or distort information in the Company's accounting records and reports.
Employees of the Company responsible for accounting and finance are required to fully comply with regulations affecting the Company's accounting, financial, economic, tax, or any other aspects relating to tax declarations.
The Company, as a subject obliged to prevent money laundering and terrorist financing, has the procedures and manuals referenced in the money laundering prevention regulations. The Company establishes policies to prevent and avoid, in the course of its operations, the making of irregular payments or money laundering originating from illicit or criminal activities.
Company personnel, for the purpose of avoiding the risk of money laundering, must act in accordance with the approved manuals, training and procedures.
From PIB Group Iberia, we do 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 in accordance with current legal standards and regulations 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 Law 10/2010 of 28 April, has implemented a series of specific rules and procedures for the prevention and detection of money laundering and terrorist financing operations by PIB Group Iberia companies subject to money laundering regulations. Among these procedures, we highlight:
The Company is committed to socially responsible performance, aimed at generating wealth for the society in which it operates, balancing this performance with the necessary business profit.
The Company's directors undertake to ensure the sustainability of the company, prioritising this principle over short-term profit, and to pursue the general interest above their personal interests.
The Company's commitment to society is realised through the development of sponsorships, patronage, and collaborations, which may be channelled through agreements and the allocation of resources to social organisations and institutions, in a manner consistent with the Entity's strategy.
Likewise, through the Company and the voluntary collaboration of its employees, projects of a charitable nature will be promoted and developed.
The Company recognises the critical importance of preserving and protecting our environment across 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 minimise any negative impact our activities may have on it.
To achieve these objectives, the Company will provide its employees with the appropriate means and necessary training to promote environmental awareness and the implementation of sustainable practices in all areas of our business.
Furthermore, we are committed to strictly adhering to all environmental legislation applicable to our operations, as well as actively promoting 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.
By undertaking this commitment, we aim 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 developing its business activities, the Company obtains personal information from its clients, employees, collaborators, suppliers, administrators, or other individuals with whom it interacts, which it considers private to the individual.
In addition to the commitment to confidentiality reflected in various points of this Code, the Company is establishing a set of specific rules and procedures, laid out in the Data Protection Policy, which have been adopted by the Company with the aim of protecting and ensuring the appropriate processing of personal data.
Such rules and procedures shall comply with the legal requirements applicable in each case.
Regardless of the responsibilities specifically assigned to certain areas of the Company concerning information security and personal data protection, employees who, by reason of their position or professional activity, possess or have access to this type of data are responsible for its safekeeping 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 the valuation principles and standards applicable at any given time.
Under no circumstances will any Company professional be permitted to conceal or misrepresent the economic or financial information of the Company. We value transparency and honesty in the presentation of financial information, and we are committed to adhering to the highest ethical and professional standards in all our financial and accounting activities.
To ensure adherence to these principles, we foster an organisational 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 pledges to provide truthful, relevant, and useful information in all its communications, adhering to the fundamental principle of transparency. We recognise 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 fulfil this commitment, we pledge to disclose any information, both internal and external, honestly and accurately, without any intention to confuse or mislead the recipient. We value integrity and clarity in all our communications and endeavour to ensure our actions and words reflect our core values and principles.
Concerning our relationships with the media and financial analysts, we are committed to channelling them through our Presidency Secretariat. This centralisation ensures coherence and consistency in our external communications, as well as the protection of confidential information and the proper management of relationships 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 the trust and credibility of our company with all our stakeholders.
The Company recognises and respects the intellectual property rights of third parties as a fundamental principle of 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 the Company's advertising or official documents without the corresponding authorisation from the legitimate owner. This implies carrying out due diligence to obtain the necessary permits before using any content protected by copyright or intellectual property rights.
Furthermore, it is strictly prohibited to use trademarks or logos in advertising or official company documents without prior authorisation or without registering these trademarks in the Company's name. It is essential to verify the existence of prior industrial property rights registered in favour of third parties before using any trademark or logo in our communications.
Furthermore, we undertake to ensure that all advertising carried out by the Company is truthful and does not contain misleading claims that could cause harm to potential customers. We value honesty and transparency in all our commercial communications, and we strive to maintain our brand's trust and credibility with the public.
By adhering to these principles, we reaffirm our commitment to integrity and respect for intellectual property rights, thereby ensuring ethical and responsible conduct in all our commercial and communication activities.
The Company recognises the importance of establishing clear and consistent ethical and conduct standards to guide the actions of all its employees and collaborators. In this regard, it is fundamental that all members of the organisation are fully informed and committed to the principles and norms established in our Code of Ethics and Conduct.
To ensure broad understanding and effective adherence to these principles, the Company commits to actively communicate and disseminate the Code of Ethics and Conduct among all its employees and collaborators. This includes its availability in digital formats accessible through the Company's internal communication channels.
Furthermore, we undertake to ensure 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 behaviour established within it. This explicit and formal acceptance guarantees that all members of our organisation are fully committed to the ethical and conduct standards 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 the trust and respect of our stakeholders towards 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 assigned to other areas of the Company.
The Management Committee, in relation to this Code, shall ensure:
Any modification of the Code will require the approval of the Company's Steering Committee. Likewise, suggestions and proposals made by employees and collaborators, as well as the commitments undertaken by the Company regarding social responsibility and good governance, will be taken into account.
Any doubts that may arise regarding the interpretation and application of the Code should be consulted with your immediate superior. If circumstances require, you may refer to the CCO.
Any indication of irregularity or non-compliance with the Code's rules must be reported to the immediate superior. The latter must then contact the Company's Steering Committee, which will take the appropriate measures.
The confidentiality of the information provided, as well as the identity of the person providing it, will be guaranteed. In any case, the Company undertakes not to take any direct or indirect reprisals against professionals who have reported an alleged irregularity.
When the Steering Committee determines that a Company professional has engaged in activities that contravene the Code of Ethics and Conduct, appropriate disciplinary measures will be applied in accordance with the severity of the misconduct and relevant 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 recognises the importance of establishing effective communication and whistleblowing channels so that employees and collaborators can raise queries and report potential breaches of the Code of Ethics and Conduct.
In this regard, employees or collaborators have the freedom and the duty to make enquiries related to the interpretation or application of the Code of Ethics and Conduct to their line manager. In the event that the enquiry requires specialist 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.
Furthermore, if an employee identifies a potential breach of the Code of Ethics and Conduct, they are 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 inappropriate conduct, ensuring the protection of the whistleblower and an adequate investigation and response by the company.
By establishing these channels for communication and reporting, the Company reaffirms its commitment to transparency, accountability, and respect for all its employees and collaborators. These mechanisms not only allow for the swift address of potential ethical issues but also foster a culture of trust and collaboration throughout the organisation.
| Version No. | Date | Editor | Approved by: | Change description |
| 1.0 | 31/05/20204 | Legal & Compliance | Chief Legal & Compliance Officer | Initial version |
