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Criminal and Anti-bribery Compliance Policy

The SICE TyS Group, the organisation of enterprises comprising it and, especially, its Governing/Management Body and Senior Management are fully committed to promoting a truly ethical professional culture and to reaffirm their commitment to and demand from all members of their Organisation compliance with and respect for current legislation in its broadest terms and, most specifically, at the criminal level, including observance of the Corporate Compliance Programme, extending the latter to encompass and be binding  for all persons involved in the Group’s activity, with the aim of avoiding the commission of any type of criminal act.

This Criminal and Anti-bribery Compliance Policy, in keeping with its General Policy; its Environmental Quality and Occupational Risk Prevention Policy; and with the aims strived for by the Organisation as a whole, intends to identify, prevent, detect and react proactively to any sign of a criminal offence that could jeopardise the stability of the Group's business activity.

To achieve this, technical, organisational, staff, monitoring and control measures have been implemented throughout the Organisation, encompassed within a framework of commitment by the SICE TyS Group to continuous improvement of the aforesaid measures, including the establishment of a penalisation system applicable in cases of non-compliance with the Criminal and Anti-bribery Compliance Policy.

This Criminal and Anti-bribery Compliance Policy of the SICE TyS Group, promoted, approved and undertaken by the Governing/Management Body and by Senior Management, is included in the Corporate Compliance Programme and specifies the following:

  • Identification of the activities where a criminal act could be committed, expressly prohibiting the perpetration thereof and putting in place the necessary means of prevention.
  • Minimisation of the Organisation's exposure to criminal and bribery risks by establishing proper risk management protocols and control mechanisms.
  • Establishment and dissemination of an ethical business culture at all levels of the Organisation, setting out an adequate framework for the definition, review and attainment of objectives in terms of the prevention of criminal offences whilst.
  • Engaging all Professionals of the SICE TyS Group and other Stakeholders in complying with the provisions of the Corporate Compliance Programme and this Criminal and Anti-bribery Compliance Policy, as well as in the obligation to report in good faith awareness of facts or conducts that can be reasonably suspected of constituting criminal acts or that may involve the risk of a criminal offence.
  • The SICE TyS Group has established adequate communication channels, guaranteeing both confidentiality and the absence of reprisals for complainants. Access to the data and addresses of these channels can be found on the web pages of the Group Companies and through other means of disseminating information used by the latter.
  • The establishment of a Corporate Compliance Control Body endowed with autonomous powers of initiative and control, with independence in the exercise of its functions.
  • Audit and assessment of the degree of criminal compliance and to implement decisions on the basis of the results obtained, updating and progressively improving the Corporate Compliance Programme, adapting it to changes in external and internal factors that affect the Organisation's activities.
  • Applying the corresponding penalisation measures in the event of a breach of any of the obligations and requirements established in the Corporate Compliance Programme, or contrary to the Criminal and Anti-bribery Compliance Policy.