We are a Group that works towards business excellence and that actively promotes compliance with national and international norms and guidelines related to the different aspects or dimensions of our economic activities.
Quality in what we do, transparency in what we report and respect, both for the people and the environment, are the keys to understand our vision in the context of corporate responsibility.
Quality needs to be understood not only as it relates to the excellence of our products but also to excellence in our management systems and as the key to the culture of our organization. For this reason we understand as a fundamental requirement our ISO certifications and as a necessity our focus on the EFQM management system.
As a company quoted on the Madrid stock market the Azkoyen Group rigorously applies the CNMV regulations on financial information and transparency as well as the recommendations on good corporate government as set out by the same entity.
In addition to the importance we place on the maintenance of our ethical code, we have systematically implemented and maintained the standards ISO 45001 (Risk Prevention at Work) and ISO 14001 (Management of Environmental Risks) throughout the organisation.
This Compliance Manual establishes the organisation, prevention, management and control model for criminal risks in the AZKOYEN GROUP.
In light of the regulatory changes in criminal matters, and in line with its culture of ethics and compliance, AZKOYEN has developed a compliance plan for the prevention crimes and has compiled existing the procedures and controls for the effective prevention and mitigation of this risks, especially criminal risks, culminating in the creation of the Compliance Model.
For this reason, in preparing this Manual, a detailed analysis has been carried out of the criminal risks that may arise in the different areas of AZKOYEN, taking into account on the one hand the existing policies and controls, and on the other the sensitivity to criminal risks detected in the specific processes, depending on AZKOYEN’s sector and the activities.
Azkoyen Group declares its absolute rejection of any type of practice related to committing criminal acts, especially with regard to corruption. For this reason, and in accordance with the principles laid down in its Code of Conduct and in its Compliance Model, the Group will complying with all anti-corruption laws, strictly prohibiting all forms of active or passive corruption in Azkoyen, without distinction of origin, destination, amount, etc., even where these illicit acts could benefit the Group.
Therefore, all Group executives and employees must comply with the Code of Conduct and the approved business policies, which establish that no corruption practice should or may be committed under any circumstances, as a means to obtain personal benefits or any advantageous treatment for Azkoyen. It is therefore a pivotal duty on all the members of the Group to comply with the standards and guidelines contained in the Anti-Corruption System as laid down in this document. Failure to comply with these provisions may result in appropriate employment, civil or potential criminal charges.
This document describes the fundamental elements of the Azkoyen Anti-Corruption System (hereinafter, the “System”), its close relationship and adherence to both (i) the Compliance Model developed in Azkoyen, and (ii) existing regulatory standards in this area (in particular ISO 37001 on Anti-Corruption Management Systems i.e.).
This is because anti-corruption models or policies are an important foundation of the compliance policy implemented in the Group. Ultimately, the anti-bribery policy and the support for the management system help the organisation to avoid the costs, risks and harm of engaging in corruption, while improving and consolidating its reputation and corporate ethics.
The growing importance of the implementation of compliance systems in the Group, together with a consolidated international awareness against corruption, has led the Group to create this Anti-Corruption System which defines the key points to achieve adequate prevention of this type of risk in its business activity.
The Whistleblower Channel is aimed at all professionals (as established below) of all companies that form Azkoyen Group that have or may have knowledge of an irregularity committed by any other worker, manager or counsellor, as well as customers and suppliers.
The objective of the whistleblower channel is the reception, retention and treatment of complaints about irregularities or breaches of the regulations, committed by employees or companies.
It is a confidential communication channel open to employees, customers, suppliers, shareholders, etc., linked to the Azkoyen Group, the Audit Committee and the Company’s Management.
Scope of complaints
Any possible irregularity or non-compliance related to bad financial, accounting, commercial or regulatory compliance practices committed by employees or companies of the Azkoyen Group may be reported.
Communication of the complaint
The communication will be made from the Azkoyen Group website, by completing the attached form that will be sent to the Azkoyen Group’s Whistle-blower Channel.
Complaints will be received by the members of the Support Unit, the Audit and Human Resources Management Committee of Azkoyen Group
Content of the complaint
The complaints received must contain the necessary data to carry out the analysis of the reported facts. Thus, the received communications must meet at least the following requirements:
The Azkoyen Group have a Code of Conduct which defines the guidelines of behaviour that make the company a prestigious reference in all its areas of activity and geographical locations where it interacts, and which is applicable to all the employees of the Group and its companies. Its compliance is absolutely mandatory for both employees and management teams.
This Code of Conduct forms an intrinsic part of the Internal Conduct and Corporate Governance rules. This document translates the principles and concepts of the “Corporate Compliance Model” of Azkoyen Group and all of its component companies to individual behaviour.
This Code of Conduct has been formally approved by the Board, and all employees must read, understand, and apply it in their daily behaviour.
