1.    Definition

This Code of Ethics and Business Conduct (hereinafter, “the Code”) sets out the principles that are to guide and orient the professional conduct of Amipem Consultores and its employees in the context of their work and professional activities and obligations. This code includes the commitment of Amipem Consultores to act in accordance with values that guarantee responsible behaviour and respect for current legislation in all the Company’s relations with its own employees, with its clients, with its suppliers, with its shareholders and with society in general.

2.    Purpose

The assumption by Amipem Consultores of a code such as the one that has been defined, represents the express commitment of the Company to accept certain criteria of conduct to whose strict compliance it is bound.

3.    Recipients

The Amipem Consultores code is addressed to all its employees, who must know and accept its content and be obliged to comply with it as soon as it comes into force. Suppliers, subcontractors, clients and any third parties that maintain legal relations with Amipem Consultores – hereinafter interest groups – will be covered by the principles of this code as soon as they apply to them.

4.    Principles and values that govern this code

• Faith in private initiative as the driving force of the economy and source of collective prosperity.
• Respect for current legislation.
• La actuación basada en criterios de ética profesional, pauta de nuestro comportamiento.
• La permanente atención a las demandas de productos y servicios que la sociedad solicite y que la Compañía esté en condiciones de suministrar.
• La satisfacción de nuestros clientes, con la calidad comprometida, objetivo prioritario de nuestra oferta de servicios y legítima justificación del beneficio empresarial.
• La vocación de innovación creativa y de liderazgo.
• El mantenimiento de la solvencia económica y la gestión eficaz de nuestros recursos, bases de nuestro proyecto económico y garantía de su continuidad.
• La corresponsabilidad en la gestión y la ordenada delegación de funciones, bases de nuestro estilo de dirección.
• La formación y el desarrollo de nuestros trabajadores, las políticas activas para la conciliación de la vida laboral con la familiar y el respeto al principio de igualdad, pilares de nuestra política de recursos humanos.
• El respeto al medio ambiente y la aplicación de medidas preventivas que garanticen la seguridad y la salud de nuestros trabajadores, marco para el desarrollo de todas nuestras actividades.

5.    Normas generales de conducta que fija el código

• Commitment to human and labour rights: Adherence, respect and compliance with national and international standards in this area.
• Fair competition: Commitment to compete in the markets in a fair manner, complying with competition regulations.
• Health and safety at work:
  • Protection of the integrity and health of our employees through an occupational health and safety policy, based on strict compliance with regulations, training and preventive management of occupational risks.
  • Commitment to provide our employees with the necessary resources to enable them to carry out their duties safely and in a healthy environment.
  • Commitment by employees to strictly comply with occupational health and safety regulations and to make responsible use of the equipment assigned to them, ensuring their own safety and, in general, the safety of all persons who may be affected by their activities.
  • Compliance, both by suppliers and subcontractors with whom the Company operates, with the legal regulations applicable to them in matters of occupational health and safety and environmental protection.
• Environment: Carrying out the Company’s activities with respect for the environment and the environmental impact that they may generate, and complying with the standards established in the relevant regulations.
• Keeping of reliable books and records: The Company’s financial statements shall be complete, timely, accurate and reliable. They shall comply with applicable accounting and tax laws. All books and records of Amipem Consultants shall reflect the nature of the underlying transactions. Such accountability shall include the Company as a whole.
• Bribery and corruption: Amipem prohibits any form of corruption or bribery. Company employees must never, directly or indirectly, offer, promise, pay, solicit or accept monetary or other benefits to obtain, retain or facilitate business or other advantages, whether private or corporate. Employees must also refrain from any activity or conduct that could give rise to the appearance or suspicion of such conduct or an attempt thereof.
• Gifts and entertainment: No business gifts or entertainment should create expectations or give the impression that the recipient has to offer anything in return.
  • Employees may not be influenced by the receipt of favours or attempt to influence others inappropriately through the giving of favours. Employees may only offer or accept reasonable meals and token gifts that are appropriate in the circumstances, and shall not accept or offer gifts, meals or entertainment if such behaviour could create the impression that it constitutes improper influence with respect to the relevant business relationship.
  • No employee shall offer to, or accept from, third parties gifts of any value whatsoever in the form of money, loans, bribes or similar monetary advantages.

Principles for action: Content

1.    Employees

• Compliance with current legislation: All employees shall ensure compliance with the laws and regulations in force in the place where they carry out their activities. Likewise, they shall at all times respect the commitments and obligations assumed by the Company in its contractual relations with third parties.
• Commitment to training: Each employee must attend to their own training, updating and increasing it, using all the means that the Company makes available to them, in order to achieve their full professional development and the attainment of their personal objectives.
• Professional promotion: within its possibilities, Amipem Consultores will try to facilitate internal promotion within its organisation, based on the principles of capacity, competence and professional merit.
• Reconciliation of family and professional life: The balance between work obligations and personal and family life is achieved through a human resources policy that generates measures that make it possible to reconcile the commitment to the Company with the time necessary for the development of a personal life project.
• Professionalism at work: Amipem Consultores’ employees will act in the exercise of the competencies attributed to them by virtue of their positions, putting into practice criteria that lead to the greatest efficiency and following the pertinent guidelines, in each case and according to their respective technical training.
• Management style: The attribution of managerial competencies at all levels of the Organisation shall also entail the assumption of the responsibilities derived from decision-making.
• Principle of non-discrimination and equal opportunities:
  • Commitment to creating a working environment where all employees are treated with fairness, respect and dignity, with particular attention to promoting equal opportunities and treating all employees fairly and without prejudice.
  • No form of discrimination, whatever its cause or origin, will be accepted, nor will forced, compulsory or child labour be tolerated or used. Amipem will also require its suppliers to refrain from such practices and will encourage its customers to do the same.
• Respectful and harassment-free working environment: Amipem Consultants will promote a pleasant and safe working environment. On the other hand, any manifestation of harassment or abuse of authority will be rejected, as well as any other conduct that may create an intimidating, offensive or hostile work environment.
• Use and protection of company assets: Amipem Consultores provides its employees with the necessary resources to carry out their professional activity. All persons working in the Company undertake to make good use of the material and immaterial means made available to them and to protect the assets and property of Amipem against loss, damage, misuse, theft, fraud, misappropriation or destruction. These assets include both tangible and intangible assets: trademarks, know-how, confidential or proprietary information and information systems.
• Information technology and communications resources: IT and communications resources, and especially e-mail and the Internet, are to be used solely and exclusively for the performance of employees’ professional duties, and their use may be subject to monitoring or audits at any time.
• Financial resources: Employees are responsible for the proper use of financial resources provided to them, including travel and entertainment expenses and the provision of Company goods or services.
• Conflicts of interest, business opportunities and other activities: Amipem employees are obliged to disclose any conflicts of interest that may exist between themselves – or persons related to them – and the Company. Nor may they carry out other activities, either in their own name or in the service of third parties, paid or unpaid, when they are incompatible with the obligations derived from their employment relationship with Amipem.
• Business opportunities: Employees may not take advantage, for their own benefit or that of a person related to them, of information or business opportunities of which they have become aware as a result of their work.
• Confidentiality of information: All Group employees are obliged to protect confidential or reserved information of which they are aware by reason of their position and not to use it outside the scope of their employment relationship or disclose it to third parties without the prior written consent of the company, with the exception of requests for information that are legally required by judicial or administrative authorities. Employees who, due to their internal responsibilities or involvement in customer or supplier projects and who may have access to particularly sensitive information, may be required by the Company to sign specific confidentiality agreements in addition to their main employment contract. The Company shall guarantee its employees, suppliers, clients and any third parties that have a relationship with the Company that it will faithfully comply with the regulations on data protection, adopting the pertinent measures in its Organisation to ensure that these regulations are fully effective.
• Intellectual property: The right to use or exploit, in industrial or commercial form, any innovations or inventions that Amipem Consultores employees produce in the course of their work and which may give rise to trademarks, patents, invention models, copyrights, industrial designs, etc., shall belong to Amipem Consultores S.L., who shall protect them under the terms established by law.

2.    Clients

• Confidentiality: It will be guaranteed that the information that Amipem Consultores has about its clients, as a result of its commercial and collaborative relationship, will be duly safeguarded and, where appropriate, protected by the legislation on the protection of personal data.
• Quality of services: The satisfaction of Amipem Consultores’ clients with the services provided and products supplied is the priority objective of our business activity. All employees must be aware that the success in the relationship with clients lies in the correct provision and supply of the same. To this end, and in order to achieve the committed levels of quality, Amipem Consultores provides its employees with the necessary means for the development of their activity.
• Relations with clients: All relations that Amipem Consultores maintains with its clients will be duly documented in the legally appropriate form and expressed in clear terms that allow the rights and obligations arising from the aforementioned relations to be precisely determined.

3.    Suppliers and Contractors

• Selection policy: The selection of suppliers and contractors will be made with criteria of transparency, professionalism, objectivity and free concurrence, in such a way as to guarantee the quality of the good acquired or the service provided and the best economic conditions, valuing, especially, the technical and financial solvency of the supplier and contractor and the experience gained from previous relations with them.
• Confidentiality: The rules of confidentiality of supplier and contractor information to which Amipem has access will be applied.
• Relationship with suppliers: The Company shall promote the above-mentioned principles of supplier selection to be complied with and respected by employees, as well as in the request for bids and in the awarding of works, supplies and services.
  • The company shall take all necessary measures to prevent the personal interests of its employees from having a decisive influence on all the above-mentioned processes.
  • Amipem Consultores shall encourage the continuous evaluation of its suppliers and contractors regarding compliance with environmental, quality and occupational safety requirements.

4.    Control of the implementation of the Code

• Ethics Committee: In order to ensure compliance with the Code of Ethics, there shall be an Ethics Committee (hereinafter the Committee) composed of the Managing Partners of the Company, which shall ensure the impartiality and consistency of its decisions. Decisions shall be taken by a majority of its members. The Ethics Committee shall be chaired by one of the Partners on rotating one-year terms of office.
• Duties: The Ethics Committee shall be assigned the following functions:
  • Interpret this code and resolve queries that arise.
  • Receive and evaluate communications related to the implementation of the code.
  • To process the communications received, if appropriate, until a resolution is issued.
  • Propose to the Administrator as many modifications, clarifications and implementing rules as required for the application of the code.
  • Regularly prepare reports on the level of compliance with the code and make any recommendations it deems necessary to improve its content, facilitate its understanding or ensure that it is safeguarded.
• Communication procedure: Amipem Consultores provides its employees with a channel that allows them to confidentially report any actions or conduct that may be considered to violate the principles set out in this code. The Ethics Committee may act on its own initiative or at the request of any duly identified employee or stakeholder. Any Company employee or stakeholder may report alleged breaches of the Code by the Company or its employees. The procedure shall ensure that the identity of the person reporting an anomalous behaviour is preserved. Likewise, employees may use this procedure to consult doubts or propose improvements to the existing systems in the Company, in the matters covered by the code.
  • Communications containing allegations of non-compliance or queries regarding the interpretation or application of the Code of Ethics may be sent to the Ethics Committee at the address Valentín Beato 11, 4ºB, 28037, Madrid.
  • The Ethics Committee assumes the commitment to resolve any matter that is submitted to its competence and once evaluated, the committee will determine whether or not the complaint is admissible and, if appropriate, will transfer the file with all the information to the General Management of the Company for the adoption of the corresponding measures.