Code of Ethics & Conduct. Grupo Antolin

Transcription

1 Grupo Antolin

2 Index 1. - Letter from the President 2. - Introduction to the Code 3. - Enforcement and Application of the Code 4.- Commitment A) of Grupo Antolin B) of the employees 5. - Management of Ethics Violations A) Whistleblowing (Grupo Ethics Link) B) Ethics Committee

3 1.- Letter from the President Since the beginning, Grupo Antolin has had the firm intention of doing what is right. And in the world today, in constant change, the intention to act responsibly has now become more important than ever. We understand Responsible Conduct is the only way to carry out the actions and decisions of our commercial activity. This conduct is, furthermore, independent from the location of the activity and particularly important in developing countries. The values of Grupo Antolin are the foundation of our corporate culture, and are strengthened by our creativity, leadership, customer focused and sustainability. Our job is to contribute to the professional and personal growth of each and every person who is an integral part of Grupo Antolin, through the creation of an environment of mutual respect, free from any form of harassment or discrimination of any kind. We want to be an innovative company, integrated within the communities in which we operate. And in this sentiment, the Code of Ethics and Conduct strives to orient all employees of the company to this way of acting. In the corporate strategy of Grupo Antolin, we have integrated the Ten Principles of conduct and action from the World Pact of the United Nations on Human Rights, work, environment and the fight against corruption. Responsibility is the axis around which our corporate identity revolves. José Antolin Toledano

4 2. - Introduction to the Code The Code of Ethics and Conduct of Grupo Antolin (hereafter referred to as the Code) is a living document in which the principal objective is to guarantee responsible conduct in the development of our activities. With this document, Grupo Antolin publicly declares its commitment to the Universal Declaration of Human Rights, the principles of the Global Compact of the United Nations (of which, Grupo Antolinhas been a founding member of since 2003), and the Organization for Economic Cooperation and Development (OECD). The present document reflects these values and should serve as a guide for the conduct of the company and those who make up the company. It should instill honesty, ethics and professionalism in our relationships with our clients, stockholders, employees, suppliers and with society in general. The Code is not a rule of internal regimen, nor is it a substitute for the collective bargaining agreements or of the national, international or local legislations. Nevertheless, the company gives a prioritized level of importance to the compliance with this Code, of which all employees of Grupo Antolin should commit to respecting the content and spirit of the document. Ultimately, we should always appeal to our sense of responsibility and good judgment, and seek counsel if ever there is doubt regarding appropriate corporate behavior.

5 3. - Enforcement and Application of the Code This Code of Ethics and Conduct goes into effect on the same day Grupo Antolin makes its commitment public. This Code is subject to revisions and updates as the Company fulfills its obligations of Corporate Responsibility, as well as from suggestions and proposals made by the employees and the Ethics and Conduct Committee of Grupo Antolin. Grupo Antolin s commitment to this Code extends to all of the facilities in which Grupo Antolin is a major partner or has management control, as well as to the supply chain. Similarly, this Code applies to all employees associated with Grupo Antolin, independent from contracts that have been negotiated in labor relations, the position that is held in the organization or the territory where employed. Anyone who violates the Code, Policies or Procedures of Grupo Antolin is subject to disciplinary actions, up to and including dismissal. Disciplinary actions are also applicable to anyone who requests or approves infractions, or has any knowledge of them but does not act immediately to seek resolution.

6 4.- Commitment A) of Grupo Antolin Grupo Antolin continuously strives for a sustainable future, working to decrease the impact our activities generate on the environment and on the people in the surrounding communities. For this reason, we are committed to the specific universal values that govern Grupo Antolin s behavior in all activities. Human Rights: Grupo Antolin supports the fundamentals of human rights, and avoids and denounces participation in any commercial activities that abuse those rights. Labor Standards: Grupo Antolin defends the freedom of association and effectively acknowledges the rights of collective bargaining. Supports the elimination of all forms of forced labor or work which is carried out under coercion. Respects the laws enforced in each country with regard to work hours. Implements policies in accordance with local compensation laws, including minimum wage and employment benefits. Opposes illegal child labor practices. Favors the elimination of discriminatory hiring and employment practices. And guarantees a management system with safe and healthy work standards.

7 Environment: Grupo Antolin aspires to minimize the detrimental impact on the environment from its commercial operations. Fosters initiatives that promote enhanced environmental responsibility. And promotes the development and diffusion of processes and technologies that are respectful of the environment. Anti-Corruption: Grupo Antolin is committed to supporting international and local efforts to eliminate corruption and financial crime. Relationships with Competitors: Grupo Antolin is committed to competing vigorously and competitively in the marketplace, but in full compliance with all laws regarding competition in its different commercial territories. B) of the employees To be honest and trustworthy, basing our competitiveness on the quality of our products and services, avoiding situations that confuse professional responsibilities and ethics, ensuring that any payment, distribution or gift, for or in the name of the company, is legal and for legitimate reasons. To act in an educated manner that is respectful and fair to co-workers and professionals of Grupo Antolin, as well as with our clients and service providers, applying the company policies in the areas of diversity and tolerance, without discrimination for reasons of age, race, color, sex, language, religion, beliefs, origin, or any other condition or circumstance, personal and/or social.

8 To maintain the necessary level of confidentiality, within the framework of professional ethics in all work-related aspects of those areas, to guard all professional secrets whenever needed, both internally and externally, with suppliers, clients and competitors. To protect our own independence without letting others influence our professional judgment, and avoid involvement in any situation where a possible conflict of interest or circumstance could affect our own impartial critical judgment and objectivity. To achieve a healthy and secure atmosphere fulfilling and ensuring the necessary security measures and cleanliness, as well as making responsible use of the resources and facilities of Grupo Antolin, when and where work is performed, never working under the influence of alcohol or drugs or any other illegal substance that might cause questionable professional behavior and/or threaten the security of others. To prohibit violent behavior, threats, coercion or any form of intimidation or harassment from co-workers, management, clients or any other agent of the company. To preserve company knowledge by facilitating the dissemination of information to other Grupo employees and willingly making available the management systems of knowledge that enable information to be more effectively distributed to others within the company. To utilize with diligence the proper technical resources and materials provided by the Company to avoid damage from misuse, and being responsible for the possession, proper care of them and their use in compliance with the rules and enforced internal guidelines.

9 To enforce a belief in creating an agreeable and respectful work environment, using the tools provided for all employees by the Company to express the level of satisfaction with the policies and processes of Grupo Antolin. To contribute to the continued improvement of our environmental behavior, integrating the environmental policies of Grupo Antolin into our company s conduct and daily activities. To represent Grupo Antolin responsibly in its development of our professional activities, always and everywhere, being conscious that whatever proceedings, omissions or decisions that are made on behalf of Grupo, directly or indirectly, affect the reputation of the company. To be committed to achieving the maximum quality, individually, as a part of a team and cooperatively, always seeking the best continuity. To denounce any situation that violates the principles and fundamental Rights of the people and of the environment of each of the companies in which the presented code applies. To experience the right to express our concerns and points of view across the established inquiry channels established to guarantee the freedom of expression.

10 5. Management of Ethics Violations A) Whistleblowing (Grupo Ethics Link) Available to all Grupo Antolin employees is the Whistleblowing (Grupo Ethics Link) as a way to submit any complaints and/or incident reports to be considered in a timely manner. This communication can be made through the Company s Intranet, for those who have access to a computer, and also via the following mail address: Grupo Antolin P.O. Box 2069 Burgos, Spain E The complaints should be identified with all of the necessary information provided, and with the specific details of the incident. Anonymous claims will not be accepted. This information will be received solely by the corporate office Human Resources Department. Periodically, the received documentation will be presented to the Ethics Committee. If it is determined that a complaint is valid and can be supported, two evaluators will be designated to carry out any interviews and to compile all of the necessary information. The resolution, representing the position of the company regarding the specific conflict, will be communicated solely to the interested parties, and will be taken under advisement.

11 It is the responsibility of each of us to apply the contents of this Code of Ethics & Conduct in an appropriate manor, and to in turn, help others to do the same. From here forward, we would like to encourage everyone to express their concerns and to inform us, in good faith and with impartiality and respect, of any conduct or situation that is contrary to the commitments stated in this document. In consideration of Grupo Antolin, as a whole and in its global position, when faced with situations concerning corporate conduct in its International efforts, the established policies of the company of destination and of the origin should be available to adequately make any decisions. If there is any doubt, however, each professional should use their best judgment to determine the best way to respond to the situation, seeking assistance from coworkers, from those who are responsible, and if necessary, from the company by submitting their concerns to the Ethics Committee for consideration. B) Ethics Committee Grupo Antolin has created an Ethics Committee with the charge to watch over the development, revision and the fulfillment of the Code of Ethics and Conduct. And has the authority to resolve the ethics-related conflicts that occur within the company. The Committee consists of a cabinet of internal professionals, as well as of external experts in the areas of Corporate Responsibility, labor and legal matters. The objectives of the Ethics Committee are: 1. - To evaluate the level of symmetry between the values of the company and the actual social and cultural environment of the company To develop and update the values and the present Code, based on the internal needs of the company.

12 3. - To oversee the complete adaptation to the ethics principles and values within Grupo Antolin To guide and support the professionals of the company To identify, analyze and give responses to unresolved issues. The Ethics Committee is, furthermore, committed to periodically providing updates on the direction of Grupo Antolin with respect to the number and the severity of discovered incidents, the number of interventions by the committee and the number of corrective actions brought to resolution, as well as an extension of knowledge of the Code of Ethics and Conduct on behalf of the professionals of de Grupo Antolin. I have read, understand and am committed to respecting the spirit and the language of the Code of Ethics and Conduct of Grupo Antolin