Code of conduct
Code of conduct
The purpose of the Code of Conduct of SOLTEC GROUP (hereinafter the Group) is to establish the guidelines and lines of action of all its directors, executives and employees for their daily operations, regarding their relationship with all its stakeholders, with a transparent, effective and efficient management of resources, being honest with clients, suppliers, institutions and being socially and environmentally responsible.
This Code of Conduct is part of and the basis for the Corporate Compliance Program implemented within the Group in order to prevent, avoid and detect the perpetration of criminal offences in the corporate environment, in compliance with the Spanish Criminal Code and the Tax Compliance Program.
The Code of Conduct of the Group is based on the definition of the Mission, Vision, Values and Principles of the Group, and constitutes the action guidelines that guarantee the employees’ appropriate performance of professional duties. It adapts and adjusts to the current legislation in the country where the Group operates and to the Internal Policies and Protocols.
1.2. Scope The Code of Conduct of the Group contains a series of mandatory values, principles, ethical rules and guidelines for behavior aimed at the directors, executives and in general at all the staff of the Group (hereinafter “employees”) in the performance of their duties, regardless of the type of contract establishing the employment relationship, the position they hold, or the place where they work.
Besides this Code of Conduct, the employees shall also observe the regulations established in certain mandatory protocols and specific instructions.
In the event of breach or noncompliance with this Code or any of the procedures and protocols on Corporate Compliance and Tax Compliance, the corresponding penalties shall be imposed as established by Labor Law and the applicable Collective Bargaining Agreement or, in serious instances, dismissal or termination of employment for the infringing person.
Moreover, the Group shall promote and encourage the implementation of guidelines for behavior established in this Code of Conduct among its suppliers and collaborating companies.
The Group undertakes to disseminate this Code of Conduct, to keep it duly updated, and to provide the necessary tools for its effective implementation and development. Persons who join the Company in the future shall expressly accept the full content of this Code, which shall be annexed to the Employment Contract.
1.3. Mission At the Group, we are convinced that our task is to fulfil our commitments as a socially responsible company to people, technological innovation and the environment.
Through the development of our activities we want to contribute to making our planet cleaner, more sustainable and fairer through the efficient production of photovoltaic energy.
To this end, the Group's Mission Statement refers to the objectives we set ourselves, and is the expression of what the Group seeks to achieve in its work and in its relationship with all its stakeholders, and in particular:
- To encourage and cooperate in favour of the maximum implementation of renewable energies worldwide. - To promote excellence and quality for our customers and to satisfy all their needs in the renewable energy sector. - Fulfil our ethical commitment. - To provide a suitable and integration-friendly working environment for our employees.
We support technological innovation and continuous research as a way to develop more efficient products and services and improve environmental protection. In our view, this is the only way to offer quality, competitive and unique products for the demanding renewable energy market.
1.4. Vision The Group's vision expresses its aspiration and firm commitment to consolidate its position as a leader in the solar photovoltaic market through the recognition of its efficiency, innovation, transparency, dedication to the customer, business ethics and its permanent commitment to the community through the development of the most competitive products of the highest technical quality equipped with cutting-edge technology.
2. Principles and values guiding the Group's behaviour towards its employees
The activities of all Group employees must always be related to the reality of the needs of the stakeholders with whom they interact (shareholders, suppliers, customers, government entities and the community), guided by this Code of Conduct and the following values:
2.1. Teamwork. We work in an environment of mutual collaboration and continuous learning and we guarantee the professionalism of all our actions. In this sense, the Group's goal is to optimise our capacity to generate ideas that can be materialised through the integration of different points of view and teamwork. 2.2. Customer focus. Our work is focused on guaranteeing efficient results, anticipating situations and responding proactively to the changes that a globalised and dynamic environment such as ours presents us with on a daily basis. 2.3. Non-conformity. The Group works and develops its actions with a clear vocation for continuous improvement, the only premise that makes it possible to offer our customers an optimal product to meet the demanding needs of our society. 2.4. Respect. Our premise is to achieve our objectives while being aware of how our actions and decisions have an impact on people and the environment. Likewise, the Group participates and contributes to the development of the communities in which it operates, attending to local needs, in search of a more sustainable world. 2.5. Trust Trust as a value of the Group is twofold; in oneself and in the team, so that it permeates all the professional actions in which we are involved, only in this way can we create a reputation to be proud of. 2.6. Proactivity Proactivity as a Group value expresses the way in which the functions entrusted to us must be assumed, as it is a symptom of constancy, discipline and problem prevention. Compliance Body The Group has assigned a body to perform the duties of Compliance Officer (also called Compliance Body), which will be: (i) responsible for resolving any specific doubts that may arise regarding the day-to-day application of this Code and the other protocols and procedures that make up the Corporate Compliance and Tax Compliance Programme; (ii) responsible for carrying out certain random checks to ensure compliance; and (iii) responsible for receiving and managing complaints or reports of alleged non-compliance.
All Group professionals and other Addressees are hereby informed that, should they become aware of conduct contrary to this Code, specific protocols/instructions and the law applicable to the Group, primarily in the area of possible offences, they must inform the Compliance Unit, which will receive and process the reports that are communicated, as a general rule, through the e-mail account specifically created for this purpose firstname.lastname@example.org.
The Group or its Compliance Officer will provide information on the other requirements or characteristics of this whistleblowing channel. In addition to these employee-related values, the Group's corporate values are customer focus, solvency, transparency, innovation as a switch for positive change and equality (social justice) and care for our employees (our Energy, our People).
3. Group responsibilities and relationships
3.1. Stakeholder relations
The Group's stakeholders are its own employees, customers, suppliers and external partners, shareholders, public and private institutions and society in general.
Group employees act with integrity at all times. To this end, it is necessary to be aware of our responsibilities under this Code:
- Read, know and understand the Code, the policies, principles and procedures contained therein in order to ensure adherence to all the requirements of the Code.
- Comply with each of the points set out in the code.
- Ensure that other employees or groups affected by this handbook comply with and commit to the code.
- Demonstrate on a daily basis your commitment to our principles and set an example to other employees.
- Avoid any situation that could lead to illegal practices.
- Cooperate with audits by providing the requested information and being faithful to reality.
- Ask for help when in doubt about how to act.
- Report any knowledge or suspicion of non-compliance with this code to the line manager through the mechanisms in place to safeguard the code.
3.2.1. Recruitment We believe that the best way to increase competitiveness in the market is to recruit workers with the skills and attitudes necessary to meet the expectations and objectives that are closest in time. To this end, we develop selection processes using tools that meet the requirements of technical and ethical reliability, respecting the principle of non-discrimination and promoting equal opportunities.
3.2.2. Establishment of the employment relationship We ensure that all our employees are hired under a legal employment contract and reject any practice that deviates from this principle.
We have protocols and procedures in place to prevent and respond to any signs of discrimination, harassment or intimidation of workers.
We facilitate the personal and professional growth of our entire team through development/evaluation processes.
We encourage training among our employees through the establishment of tailor-made plans according to the specific needs of the organisation from a fair and objective perspective.
We promote a collaborative methodology among our employees, creating an ideal environment where people can express their ideas and make their own decisions that help the organisation to achieve its global objectives.
3.3. Relations with the administration and public institutions. 188.8.131.52. Respect for laws and human rights As a responsible company, the Group is committed to respecting and complying with numerous laws, regulations and other legally binding rules applicable to it.
In this way, the Group's employees undertake to respect the laws in force in the countries where they carry out their activities, and to refrain from any action that could be detrimental to the interests of the company.
The Group may be held legally liable for violations of laws and other legally binding regulations, as well as for any other unlawful activities of its employees, and therefore the Group expects all its employees to act lawfully, ethically and professionally in the performance of their duties. The commitment to comply with the law in all areas in each of the places where the Group operates is an inexcusable premise and of essential relevance to maintain and improve trust with citizens and society.
In all professional conduct, Group employees will strive to do not only what is legal, but what is right and will maintain strict respect for the Human Rights and Civil Liberties enshrined in the Universal Declaration of Human Rights.
184.108.40.206. Money laundering and terrorist financing The Group is committed to firmly combating money laundering in order to prevent the financing of terrorism, loyally following the recommendations of the Financial Action Task Force (FATF). To this end, the Group will not enter into business relationships with persons or entities that do not comply with the money laundering and terrorist financing obligations of each country or that do not provide adequate information regarding compliance therewith.
220.127.116.11. Corruption and bribery Employees of the Group may not make or offer, directly or indirectly, any payment in cash, in kind or any other benefit, to any public official, with the intention of unlawfully obtaining or retaining business or other advantages.
Likewise, employees of the Group may not, under any circumstances, accept gifts, donations, attentions or any other kind of favour from any person or private entity in the course of their work, unless they are symbolic and insignificant or as a sign of courtesy.
The Group requires its employees to comply strictly with all applicable anti-corruption regulations, and in this respect they may not offer, directly or indirectly, any benefit or service to customers, partners or any other person or entity, which has or may have relations with the company, with a view to unlawfully influencing such relations, provided that this is not justified by an economic transaction.
18.104.22.168. Gift regulations. Generally in accordance with the Group's Anti-Corruption Policy:
- The Group's professionals may not offer, promise or deliver gifts, donations, personal benefits, financial compensation or any other unjustified liberality or advantage to any third party outside the cases provided for in the Anti-Corruption Protocol, and in accordance with the authorisation and control procedures and requirements established therein.
However, gifts would be considered acceptable if they (i) are of a token nature and of an insignificant amount; (ii) are in accordance with customary business practices and customs; and (iii) are not intended to improperly influence the award or procurement of a good or service.
In this regard, the Group sets a quantitative limit of €1,500 for commercial promotion work, so that any expenses exceeding that amount must be authorized in writing by the Group’s Sales Department and justification must be provided. Despite having established this limit for express approval, the Group audits all expenses incurred in relation to this section, for the purpose of clarifying or taking action on alleged noncompliance.
Any doubtful assumption must be consulted with the Compliance Committee, with the knowledge of the Governing Body, which shall determine whether or not such offer, promise or delivery is appropriate. In this regard, emphasis shall be placed on training the persons who carry out commercial prospecting on the direct means of communication they have with the Compliance Committee through the email email@example.com to determine the Group's position with respect to these cases.
- The Group's professionals may not accept, in general, any gift, gift, liberality, personal benefit, financial compensation or unjustified advantage from any customer, supplier, competitor or natural or legal person in general who seeks to acquire any of these conditions with respect to the Group. On the other hand, the acceptance by Senior Management and the Governing Body of items of a symbolic nature shall be admissible, applying in this respect the limit of €1,500 set in relation to the giving of gifts.
Other members of the Group may only accept such gifts and donations if they are immediately linked to a business transaction (e.g. receiving an invitation to lunch from a supplier as part of a routine visit or for obtaining approval, accepting promotional gifts from the supplier, such as notebooks, pens, key rings, etc.
It should be borne in mind, however, that the international scope of the Group means that it has suppliers and customers from many different countries and that this may mean that, given the different cultural sensitivities, the rejection of a gift may be interpreted negatively, so that in these cases it is accepted and immediately reported to the member of Senior Management to whom they report organically. The same applies in those cases where the supplier or customer sends a gift to the Group's premises without prior notice. In both cases and in others that could be considered similar, these gifts shall be allocated to the Group's WellBeing Programme, of which the sender of the gift shall be informed.
However, any member of the Group who receives a gift valued at more than 1,500 euros must inform the Compliance Committee for the purpose of its due inventory, although any doubtful case, regardless of the amount involved, must be consulted with the Compliance Committee, with the knowledge of the Governing Body, which will determine whether or not such offer, promise or delivery is appropriate.
If, for any reason, a gift of a value in excess of 1,500 euros is received, it must be handed over to the Compliance Officer, who, if possible, will donate it within 3 months to a Non-Governmental Organisation and file the receipt issued by that Organisation. If this is not possible, these gifts shall also be donated to the Group's WellBeing Programme.
In any case, it is expressly forbidden to provide suppliers with a personal address or any other address other than that of the Group’s facilities for the receipt of gifts.
Invitations to social events, seminars or any other type of event may also be accepted provided that the value of accessing such events is less than €200 per person and provided that attendance at such events does not entail a financial consideration for the employee or for the Group. If assistance is remunerated, it will require prior authorization from the Compliance Body.
22.214.171.124. Prohibition of contributions to political parties. The use of Company funds or property, either directly or indirectly, for the benefit of or as a contribution to political campaigns, candidates or political parties is prohibited. An employee must contact the Company's Legal Department before using Company money or property for any purpose related to a campaign, candidate or political party.
It is not the Company's policy to discourage or prohibit its employees, at their absolute discretion, from making political contributions at their personal level, or participating in political life on their own time and at their own expense, or expressing their political views or engaging in any other legitimate political activity that is consistent with local law.
However, employees are prohibited from using their position with the Company, or the Company's assets, to seek to influence the personal decisions of others to support, or not to support, a particular candidate or political party.
126.96.36.199. Unfair competition The Group prohibits any action involving the exercise of illegal unfair competition practices and undertakes to ensure compliance with the competition laws applicable in the countries in which it operates.
In this regard, the Group undertakes to base its actions on the principles of loyalty and respect, exercising the good business practices that it has developed throughout its history, and thus avoiding any prohibited business practice.
The Company and its employees must comply with the antitrust laws of all countries in which it operates.
Such laws vary from country to country and can be complex. If an employee performs a function that may be affected by antitrust law, he or she is obliged to be aware of the applicable law and should refer questions concerning compliance with that law to the Company's Legal Department.
Antitrust law prohibits any attempt to monopolise or limit competition, including, but not limited to, selling products below cost, collusion in bidding procedures, group boycotts, price discrimination, price or product cost fixing, or sharing customers or geographic territories with competitors. Also prohibited are certain types of tying arrangements that require a customer who wishes to purchase one product to purchase other products or services, as well as agreements with distributors or retailers on the price at which they must sell the Company's products to the public, and other restrictive agreements.
Violation of antitrust law can lead to both civil and criminal penalties.
Likewise, the Company must carry out its activity in compliance with all legislation, regulations and standards in force that affect the manufacture and distribution of the Company's services.
The Company also complies with all laws, both domestic and foreign, governing advertising. Such laws generally prohibit, in the promotion and sale of the Company's products, any false, misleading or deceptive advertising.
All advertising or marketing claims that the Company makes about its products must be truthful and substantiated.
188.8.131.52. Relationship of Collaboration with Public Authorities The Group undertakes to collaborate with any public administrative and/or judicial body or entity, providing the necessary information to enable it to carry out its work as easily as possible, within a framework of collaboration, respect and cordiality, without prejudice to maintaining confidentiality in those cases in which it is manifestly necessary. Likewise, the Group guarantees not to hinder requests for information from public officials or the performance of any other function performed by them in the legitimate exercise of their powers, provided that they are protected by and comply with the law.
4. Commitments 4.1. Loyalty to the company and conflicts of interest Group employees faithfully assume the obligation to promote the interests of the company, as well as the prohibition to personally benefit from opportunities arising through the use of Group information or to benefit third parties with this information. Likewise, Group employees undertake not to put personal interests before those of our customers or the interests of the Group under any circumstances.
A conflict of interest arises when an employee has an interest or relationship, or is engaged in an activity, which is, or appears to be, incompatible with the interests of the Company, or which may affect, or gives the appearance that it may affect, the employee's objectivity in the performance of his or her work.
It also means that an employee may not use any information or business opportunity obtained in the course of the Company's business to obtain a financial benefit for himself or herself, an immediate family member, a close friend or a co-worker.
4.1.2. Personal financial interests If the employee, or an immediate family member of the employee, has a substantial financial interest in a company that supplies, purchases from or competes with the Company, there is a conflict of interest with the Company.
Such financial interests are prohibited unless they have received prior express written approval from the Company's Legal Department. Prohibited financial interests include, but are not limited to:
o Ownership of shares or other securities, call options or debt securities. o Receipt of fees, loans or other payments. o Holding an office, membership of the Board of Directors or participation in the management of an external entity. o The acquisition of any rights to real estate, equipment, materials or any other movable property if the opportunity to invest therein is available to the employee, or to an immediate family member of the employee, solely or primarily by virtue of the employee's position with the Company, or if the employee, or an immediate family member of the employee, can obtain a financial benefit from the employee's position with the Company.
In case of doubt about the acceptability of a particular investment in an external entity, or about the aforementioned ownership, or about a business opportunity, the Company's Legal Department and the Compliance Officer should be consulted.
4.1.3. Customers and suppliers The Group will always maintain a relationship with its customers and suppliers based on reciprocal transparency.
The Group's employees shall act with integrity towards the company's customers, with the aim of further enhancing the quality of its services, and the long-term development of relationships based on trust and mutual respect.
With regard to the approval, registration and variation of supplier data (with special attention to the accounts to which payments are to be made to them), the provisions of the protocols known as Procedure for the Approval of Suppliers, Procedure for the Management of Purchases on Site, Standard for the registration and modification of supplier data and Protocol for the prevention of punishable insolvencies and the processing of official notices, notifications and seizures shall apply.
4.1.4. Management of subsidies Out of loyalty to the administrations and institutions, as well as out of responsibility for the use of public funds, we must be particularly diligent, efficient, honest and transparent in the area of subsidies.
Therefore, in addition to full compliance with the regulations on subsidies, as well as with the bases, clauses or specific provisions contemplated in each subsidy or aid for which it is applied for, it shall be the responsibility of the Group's staff:
o Ensure the integrity and veracity of the documentation presented to the administrations or institutions. o Maintain full collaboration between the technical staff, the Programmes staff of the Administrations and the administration area, in order to compete solidly and efficiently for bids or tenders for subsidies. o Diligently manage the funds received, ensuring and documenting the traceability from the time the funds are obtained to their application in expenditure. o Maintain the greatest collaboration with the administrations and institutions (as well as with external auditors), and provide them with the corresponding justifications on request.
As a consequence of the above, the proper archiving and document management of the subsidy received shall be developed and maintained in order to comply with the provisions of the previous section.
Likewise, in order to avoid the risk of committing or collaborating in the crimes of subsidy fraud, fraud against the Public Treasury and/or Social Security, and to accredit to the Administrations and public entities an effective control of the working hours incurred -and to improve efficiency-, all the Group's professionals (mainly those involved in subsidised projects), must be extremely rigorous in allocating the hours of effective dedication to the different projects and do so without delay.
4.2. Confidentiality commitment The Group guarantees to respect the confidentiality and privacy of third party data in its possession and undertakes to have the necessary means to safeguard the privacy of employees by collecting and processing data in accordance with applicable laws and professional obligations.
Group employees undertake not to disclose any confidential and personal information they may obtain in the course of their work, notwithstanding any legal, administrative or judicial provisions requiring them to be disclosed to entities or persons or to be made public, and shall refrain from any improper use of such information.
4.2.1. Computers and other electronic devices. Use of electronic mail
The Company may provide computers and other electronic devices to employees to assist them in the performance of their work. The Company must have full access to all such physical equipment, which shall at all times remain the property of the Company.
Consequently, if an employee uses a Company computer at home or away from work, he/she must take the necessary precautions to prevent its theft or damage.
To the extent permitted by applicable law, the Company reserves the right to monitor, for any reason whatsoever, the use of its property, including accessing, inspecting and removing computers, hard drives, electronic files, voice mail, e-mail and Internet access.
In particular, employees should be aware that e-mails and other electronic communications are considered Company documents and property of the Company. Such materials may be: (i) the subject of subpoenas and requests for information from law enforcement agencies, (ii) relevant to internal investigations conducted by the Company, or (iii) provided in litigation to which the Company is a party.
The purpose of e-mail is to facilitate the transmission of Company-related information. It is important to remember that e-mails, like any other writing, should only be written when necessary, and should be accurate, complete, thorough and professionally written. Employees should not use their computer to display, receive or send any material that colleagues may find offensive or unprofessional.
4.2.2. Social networking The Company understands that some employees may choose to post personal information on the Internet through personal websites, Facebook, Twitter, Instagram, blogs, forums, newsgroups or chat rooms, uploading content, or commenting on other websites or blogs.
For the sake of simplicity, this policy refers to these platforms collectively as "social networks".
Employees should remember that this policy applies to any new device, platform or technology that is brought to market, whether or not such devices or websites are expressly mentioned in this policy.
The Company recognises that employees may conduct such self-expression activities on their own time and on their own devices and systems, and not on Company time or on Company devices or systems.
Those using social media should keep in mind a few simple guidelines:
o The Internet can be eternal. Everything that is written on the Internet can be traced back to its author, in one way or another. Information is frequently and repeatedly backed up, and posts published in one forum are usually replicated in other forums through backlinks and mentions or reproductions of those posts.
o Protect confidentiality. Employees must always comply with their confidentiality obligations by refraining from publishing and commenting on private or confidential information belonging to the Company or its customers.
o Everyone is responsible for what they publish. Any person who publishes a post on the Internet is responsible for what he or she writes or shows on the Internet, both personally and professionally. The Company reserves the right to reprimand employees, to the extent permitted by applicable law, for any comments, content or images in personal or work-related posts that are vulgar, obscene, threatening, intimidating, violent, pornographic, unethical, harassing or in violation of Company policies.
o Always comply with Company policies. There should be no personal use of social media during working hours. Limited use of social media is acceptable, provided that such activities do not otherwise violate the Group's policies on computers, internet access or other devices. When using social media for personal matters, employees must use their personal email address, not the Group's email address.
o It is possible to separate friends and professional relationships on social networks. It is not necessary for our personal activity on Facebook, Instagram, Twitter or similar social networks to include our clients or colleagues. We should be able to freely say "no" to requests received from colleagues, professional relations or customers. Employees should be aware of and use the levels of privacy controls offered by personal social media accounts.
4.3. Commitment to technical excellence and innovation We have a team of professionals that stands out for its great capacity for innovation and development of projects of the highest technology. Thanks to this team, we are pioneers in the manufacture of state-of-the-art solar trackers.
We establish a Quality System that ensures that the activities carried out throughout the process are in accordance with the specifications, controls, standards and requirements. We have quality protocols and procedures that guarantee the fulfilment of quality objectives, as well as the regulations, aiming at all times to increase customer satisfaction.
In the course of its business, the Group does not accept unspecified goods or products that do not meet the administrative and internal requirements of the company.
4.4. Commitment to quality, environment and health and safety At the Group, we ensure that services comply with applicable specifications, standards and codes, as well as applicable legislation and regulations in terms of Quality, Environment and Occupational Safety.
We establish actions and programmes aimed at continuous improvement, pollution prevention and the prevention of damage and deterioration of health, both in the quality of services, as well as in the respect, protection of the environment and people's safety.
We maintain permanent contact with all the members of the supply chain, in order to be able to collaborate jointly in the improvement of our services, both in technical aspects, as well as in quality, prevention of occupational and environmental risks.
4.5. Prohibition of the consumption of alcoholic beverages, drugs and narcotic substances.
The Company will not tolerate the use of alcoholic beverages, drugs or other illegal substances. The presence of drugs or other illegal substances on Company premises is a violation of this Code.
The Company is committed to maintaining a working environment free of illegal drug and alcohol use and may initiate disciplinary proceedings (including dismissal), to the extent permitted by applicable law, in response to any breach of this Code.
4.6. The Company treats its employees equally, regardless of race, colour, creed, religion, gender, country of origin, nationality, sexual orientation, age, disability and other characteristics covered by protection policies.
We do not tolerate any form of harassment, whether of co-workers, customers or suppliers, including harassment based on gender, race, colour, creed, religion, country of origin, nationality, sexual orientation, age, disability and other characteristics covered by protection policies.
We do not tolerate any physical or verbal conduct that impedes or interferes with the ability of others to perform their work, or that creates a hostile work environment, including inappropriate touching, leering, inappropriate language, drawings, communications (written, electronic or telephone) or other inappropriate personal interactions.
Management encourages employees to report any situation of discrimination or harassment at work to their line manager or to the Company's Human Resources Department through the Whistleblowing Channel (firstname.lastname@example.org). In the event that it is that supervisor who has behaved inappropriately and contrary to this policy, or that supervisor or manager does not appear to be taking appropriate action, or that the employee is uncomfortable reporting the situation to that supervisor or manager, the employee should promptly report the conduct directly to Human Resources.
The Company prefers that such complaints be made in writing, although verbal complaints will be accepted. Employees must never tolerate inappropriate behaviour.
4.7. Commitment to corporate social responsibility We believe in Corporate Social Responsibility, which is why we are committed to society and the environment in order to reduce the possible impact generated by our activity. We seek to contribute to the development of society by echoing the concerns and expectations expressed by our employees and customers, to whom we respond based on our values.
Our Corporate Responsibility contributes to the sustainable development of the communities in which we carry out our business, promoting respect and diversity in the different work teams, we support and guarantee equal opportunities and, above all, we contribute to better management of natural resources and the environment, promoting awareness and innovation in energy efficiency and minimising the impacts derived from our activity. This is how the Group expects to meet the expectations of our employees by integrating all these goals in our areas of activity at global, country and operating centre level.
4.8. Data protection The personal data collected, stored and/or used by the Group will be registered and processed in compliance with the obligations established in the Organic Law on Data Protection (regulations in force at any given time), ensuring the recognition of the rights (of information, access, rectification, etc.) established in the aforementioned Law.
The transfer of personal data (whether of customers, suppliers, employees or third parties) to unauthorised persons is strictly prohibited, as is improper access to such data (by unauthorised persons or for purposes other than internal business use), and anyone infringing this prohibition may incur the offence of article 197.2 of the Penal Code, regardless of the responsibilities in the field of employment.
4.9. Intellectual and Industrial Property and External Communication The recipients of this Code shall respect the intellectual and industrial property of the Group and that of third parties, not making use of others' creations either for their own benefit or for the benefit of the Group without the certainty that the rights allowing their use have been duly acquired.
The improper use of trademarks, patents, know-how, logos, audiovisual content, or any other type of creation by the Firm is expressly prohibited and must only be used for the purposes indicated by the Group. Furthermore, statements to the media shall be made, without exception, through persons specifically authorised for this purpose by the Group, in order to ensure uniformity in the communication made to the outside world.
4.10. Compliance with securities market guidelines The Group is committed to complying with the guidelines of the Spanish Securities Market Commission (CNMV) on stock market crime, and has specific protocols in place to prevent the commission of this type of crime.
4.11. Training plan
The Group has a Training Plan for both Corporate Compliance and Tax Compliance, which aims to train and update all members of the Group in the implementation and operation of the protocols and programmes, and the Group is committed to continuous training, especially in the event of legislative reforms that may affect the operation of any of the protocols implemented.
5. Compliance with the code of conduct
Compliance with this Code of Conduct shall be required of all Group employees and third parties who have voluntarily undertaken to comply with it. The Group shall also communicate and disseminate the contents of this Code of Conduct to all its employees, who shall formally commit themselves to the provisions of the Group's Code of Conduct and shall adapt their professional conduct to the principles and actions set forth therein. All employees may be assessed on the basis of their compliance with this Code. Non-compliance will be analysed in accordance with internal procedures and legal regulations.
Any questions that may arise regarding the interpretation or application of this Code of Conduct should be referred to the line manager or, if necessary, to the HR Department.
Suspicions or knowledge of possible breaches must be reported to the Compliance Officer through the procedure designed for this purpose, the most relevant characteristics of which will be notified through the Protocol on the Whistleblowing Channel, using the e-mail address: email@example.com.
Since its approval by the Governing Body, this Code of Conduct of the Group has become part of the organisation's regulations, remaining in force until its cancellation, revocation or updating is approved.
In approving any updates to the Code of Conduct, special consideration will be given to the recommendations and proposals made by the Compliance Body.