1.- OBJECTIVE
The purpose of the organization's Code of Ethics is to define the general framework of the guidelines for the behavior of all individuals or legal entities that are related, for any reason, with the organization.
These rules should govern the behavior of all individuals or legal entities that relate to the organization at any time and in all situations, in internal and external relations, linked for one reason or another to the organization.
This Code of Ethics is a general description of basic principles that will guide the behavior of the people it concerns. All of this is based on the culture and guidelines for responsible action, which must be shared, accepted and respected by everyone.
Strict compliance with them entails a commitment to legality in the broadest sense, the rules of good corporate governance, transparency, reputation, honorability and responsibility, and is a basic and essential guide to ensure adequate behavior in the professional performance of all persons concerned.
This Code of Ethics reflects the desire to prevent, detect and eradicate situations that contravene regulations, including criminal ones.
2.- SCOPE OF APPLICATION
The SALVI LIGHTING Code of Ethics is addressed to partners, administrators, employees and, in general, to all personnel related for any reason with the organization, regardless of their position, job or responsibility (hereinafter, all of them, the "subject persons" or the "persons concerned").
All members of the organization and, in particular, its governing body, undertake to use all necessary means to disseminate and enforce compliance with the conduct and behavior guidelines of this Code, which should always be the reference model for behavior in all activities related to the organization. The criteria and guidelines of conduct of this Code cannot and do not intend to contemplate all the situations that the members of the organization and the people it concerns will have to face, but they do establish the basic guidelines of conduct that must permeate their behavior.
3.- PRINCIPLES AND VALUES
Generating due trust with all the people who relate to the organization is the basic principle for relationships based on honesty, ethics and good faith, which are the principles of integrity in our activities. This undoubtedly affects not only internal relations but also external relations (with customers, suppliers, collaborators and our environment).
Willingness to serve, proactive, efficient and effective action, focused on excellence, is our basis for the professional responsibility of all, based on integrity and individual and corporate responsibility. These essential principles have a basic objective: the promotion of respect for fundamental human rights and public freedoms, contributing to the improvement of society by providing such principles in all our relationships.
Our behavior must always and at all times be complete, responsible and appropriate to basic rights and strict compliance with regulations, whether we are part of the organization or to all those who act within its scope, especially suppliers and external collaborators.
GENERAL MISSION AND VISION. GUIDING PRINCIPLES OF CONDUCT AND ESSENTIAL STANDARDS OF BEHAVIOR.
The persons subject shall act on the basis of the guidelines of conduct, principles and rules indicated below. The guidelines of conduct, in addition to what has already been mentioned in the previous sections, are always and in any case applied under the principles of loyalty, good faith and strict compliance with the law.
4.1.- General mission and vision
The mission of our organization is based on two pillars:
- Management responsibility and efficiency.
- Social responsibility in relation to the environment: social responsibility, transparency and commitment to customers and competitors.
SALVI LIGHTING aims to be a benchmark for compliance and ethics in the lighting and public lighting sector, both nationally and internationally.
In addition to scrupulously complying with the requirements of current legislation, SALVI LIGHTING seeks to advance to the highest ethical standards and most advanced recommendations.
SALVI LIGHTING, as a legal entity, assumes the firm, irrevocable and unrenounceable commitment to develop all its activities in strict compliance with the applicable regulatory framework, with an ethically impeccable conduct. In addition, it encourages and demands at all times that the conduct of the people concerned by this Code of Ethics also be in the same sense.
Subject persons must follow a strict ethical behavior in all their actions and avoid any conduct that, even without violating the law, may harm or negatively affect the interests, reputation, public image or prestige of SALVI LIGHTING. Never collaborate, either by action or omission, in any act or activity that could involve the violation or breach of the law, or that could compromise, even remotely, the honorability and reputation of the organization to allegedly benefit directly or indirectly, either to customers, suppliers, partners, government, competitors or anyone else.
4.2.- Essential standards of behavior
4.2.1. Respect for Human Rights
Respect for human rights and civil liberties, as well as basic ethical practices, must permeate all actions of the persons involved. The organization assumes the commitment to act in accordance with these principles and the legislation in force. The basic standards regarding respect for Human Rights are the Universal Declaration of Human Rights, which was adopted and proclaimed by the United Nations General Assembly on December 10, 1948; the Convention for the Protection of Human Rights and Fundamental Freedoms (Council of Europe, Rome, November 4, 1950), and the Tripartite Declaration of the International Labor Organization (ILO).
4.2.2. Other essential standards
All persons concerned by this Code of Ethics must comply with the internal rules and procedures, as well as with the instructions that may be approved in its development. The organization, as a legal person, is subject to the criminal liability of legal persons. Accordingly, all persons related or linked to the organization must comply, in any of their actions, with respect for the criminal regulations applicable at all times and which, in numerus clausus, entails the criminal liability of the legal person in accordance with Article 31 bis of the Criminal Code.
5.- BASIC FRAMEWORK OF CONDUCT
5.1.- Respect for basic human rights
Any act, omission or manifestation, physical or psychological, by any means, that compromises the psychological, physical or moral integrity of any person, as well as manifestations of physical or psychological harassment, moral or abuse of authority or any other conduct that may generate an intimidating or offensive environment for the rights of individuals will be rejected and prosecuted.
Persons covered by this Code must be treated with respect at all times; discrimination on any grounds or cause will not be tolerated.
Persons subject to this Code are obliged to treat their colleagues, members of other internal or external teams, superiors and subordinates fairly and respectfully. Likewise, relations between employees of the organization and those of external collaborating companies or entities shall be based on professional respect and collaboration.
5.1.1. Respect and professional development
SALVI LIGHTING promotes the personal and professional development of all managers of its team, as well as all employees and ensures equal opportunities through its performance policies. It rejects any type of discrimination in the work or professional environment for reasons of age, sex, religion, political opinion, national origin, social origin or disability.
From initial selection to subsequent promotion, if applicable, the merit and capabilities of all employees are based on the competencies and performance of their professional duties.
5.1.2. Health and safety at work
Occupational health and safety is part of the basis on which the organization's personnel carry out their activities. Occupational health and safety policies are essential for the professional development of employees and must be scrupulously respected by all persons concerned by this Code.
5.1.3. Privacy
The organization is committed to strict compliance with the rules of personal data protection and privacy of individuals. For this reason, the persons subject to this Code must ensure the protection of personal data processed in the performance of their work activity. In this sense, SALVI LIGHTING is committed to comply and enforce the rules derived from the Organic Law on Personal Data Protection and Guarantee of Digital Rights and the European Data Protection Regulation.
5.2.- Respect for patrimony, property, the market and free competition
5.2.1. General, equity, fraud, property and foreclosures
SALVI LIGHTING is committed to the utmost rigor and strict compliance with the law, respect for private property and the rights of third parties in terms of intellectual and industrial property. It maintains the utmost respect for the market, consumers and free competition. All persons concerned by this Code must respect and enforce respect for the rights derived from property in all its expressions in their acts and actions.
The organization undertakes not to carry out actions that may compromise the assets of others through commercial or contractual operations, agreements or written or verbal agreements that are difficult or impossible to comply with, with excessive charges or payments on account, or to use them for purposes that do not tend to fulfill the contract.
Acts or omissions that may be understood as concealment of collections or payments to third parties who are in a situation of civil, criminal or administrative execution are absolutely forbidden. Any request from authorities regarding withholdings or information shall be duly informed without delay.
It will never collaborate with fraud or frustration of executions or concealment of assets. The organization, just as it demands that third parties respect its intellectual and industrial property rights, is respectful and strict in respecting those held by third parties.
All persons subject to this Code must ensure respect for image rights, intellectual property, trademarks, trade names and industrial property, always applying the organization's internal protocols and instructions.
5.2.2. The market, advertising, consumers and free competition
Respect for business ethics is basic to the organization. Success in business and business life can never mean the breach, even if it is minimal, of free competition, with practices that damage, distort or eliminate competition.
With strict respect for the management authority of suppliers, collaborators and those who provide services for us, we promote, in compliance with the contractual conditions and obligations between the parties, that they adopt the ethical practices and conduct of this Code of Ethics.
Any act of advertising by SALVI LIGHTING will be duly controlled so that, neither directly nor indirectly, it may be even minimally misleading, and so that it never promotes or advertises activities that may be illicit.
5.3.- Respect for general interests, taxation, social security, money laundering and means of payment.
5.3.1. Commitment to Society
The organization is committed to society in general and to the impact and consequences of its activity for our environment.
Through its business activity, its sustainable development contributes to maintaining the social state not only as a legal obligation but also as a duty to society, of which we are all a part.
5.3.2. Taxation and Social Security
For the organization, strict compliance with tax obligations and duties is an expression of our firm commitment to the society to which we contribute. Transparency and respect for tax laws and regulations must preside over any operation, contract or transaction.
Any transaction included in books and records must always contain actual financial and tax information in accordance with international financial reporting standards, and all professionals concerned by this Code should therefore ensure that these requirements are firmly in place.
Imaginary accounts or accounting that may be susceptible to interpretations contrary to the law are prohibited and, accordingly, the criteria of existence, completeness, clarity and accuracy must be strictly followed.
The import or export of goods made by SALVI LIGHTING will always be carried out in compliance with all legal obligations and especially tax obligations.
Likewise, obligations with Social Security and, if applicable, those derived from public subsidies of any kind shall be complied with and executed in accordance with legal obligations, and, in any case, must be reliable and accurate, without application gaps or undue interpretations.
5.3.3. Money laundering and means of payment
The organization categorically rejects money laundering and terrorist financing and has established procedures to avoid any transactions that may be susceptible to irregularity, money laundering or terrorist financing in order to prevent them.
Transactions susceptible to the aforementioned illicit activities, due to their unusual or extraordinary amount, or because they are carried out partly in cash, with checks, means of payment to bearer or endorsements, or carried out in or by banking entities established in tax havens, must be duly supervised and controlled. These circumstances entail the non-execution, execution or stoppage of these transactions or the immediate reporting to money laundering prevention agencies.
We will always be alert to indications of possible irregular transactions and the integrity and identity of the persons with whom we contract; indications which, if they become evidence, will be reported immediately or will directly lead to our refraining from carrying out the transaction.
5.4.- Public safety
5.4.1. Environment
The organization is committed to the environment as the ultimate expression of respect for future generations, and therefore the preservation of the environment is a basic principle of any action of the people concerned by this code.
5.4.2. Public health and drug trafficking
The organization is fully committed to society in terms of protecting the individual and collective health of people. Any activity that compromises people's health in its broadest sense will not be tolerated and is prohibited.
It is forbidden, for all persons concerned by this Code and within the scope of the organization's activity, to carry out acts of cultivation, processing or trafficking, to promote, encourage or facilitate the illegal consumption of toxic drugs, narcotic drugs or psychotropic substances or to possess them for these purposes.
Any type of activity that may involve the custody, even for personal consumption or storage, even temporarily, of illicit substances that may harm public health shall not be tolerated.
Ethics, transparency, corruption, conflicts of interest, political party financing, bribery and influence peddling.
5.5.1. Transparency and Integrity
As part of the fight against unethical conduct and practices, the organization assumes as one of the inseparable principles of regulatory compliance the transparency in all its actions and the strict collaboration of these conducts by all persons subject to this Code, especially with customers and suppliers.
The information received by third parties from the organization, whether natural or legal persons, public or private, must always be complete, truthful and understandable, and in no case may it be misleading. Any type of manipulation, falsification or fraud is absolutely forbidden.
5.5.2. Corruption, bribery and influence peddling
As one of the main categories of fraud, corruption and bribery appear when administrators, managers and employees make use of unethical practices to obtain some kind of direct or indirect benefit for the company or for themselves. SALVI LIGHTING has implemented policies to prevent one of the major risks in business relationships, as part of the so-called anti-corruption policy to prevent and eradicate such risks.
All those affected by this Code and in all their relations, especially with public institutions, all types of administrations, political parties, trade unions or foundations linked to them, must act in accordance with the anti-corruption policies implemented by the organization and in accordance with state, regional and international regulations and provisions for the prevention of corruption and bribery, among which are especially the provisions of the Criminal Code.
Those affected by this Code are prohibited from any type of action or omission that passively or actively aims to influence the will of natural or legal persons outside the organization to obtain any type of benefit through practices that deviate from business ethics. Third parties are also not allowed to use them in their relations. By virtue thereof, those affected by the provisions of this code may not directly or indirectly give, receive, accept or offer gifts, presents or compensation of any kind that tend to improperly obtain any type of advantage or favorable or privileged conditions in their administrative, commercial or professional relations with the organization, public or private entities or administrations. Accordingly, it is expressly forbidden to directly or indirectly make or accept payments or discounts, compensations or gifts not common in the use and practice of commerce and business and, in any case, regardless of the amount, in case of making or receiving them, those affected are obliged to report it immediately, leaving a record in the book of gifts received and issued, and reporting it to their hierarchical superior or directly through the appropriate channels to the compliance officer or supervisory and control body.
Neither the organization nor the persons concerned by this code shall take any action to encourage public officials to engage in impermissible activities or corruption. Likewise, no rewards, gifts, donations or promises shall be solicited, given or offered that imply the loss of objectivity of public officials, including those linked to foreign, international or community states.
It is absolutely forbidden to carry out acts or promises, whatever they may be, that may affect the proper, objective and subject to the principle of legality performance of public administrations and their employees, whether public officials or not, or their spouses, partners, ascendants, descendants or siblings, in any present or future matter that affects the organization, directly or indirectly, or any of the persons concerned by this Code.
These obligations and prohibitions affect not only the administration, management or employees of the organization, but also related third parties, suppliers of goods or services, who must assume such practices, compliance with which will be ensured internally, contractually warning of the consequences of their violation.
5.5.3. Conflicts of interest
It is an essential part of business ethics, and also of the fight against corruption, freedom of enterprise, free competition and the avoidance of conflicts of interest. We refer to a conflict of interest when the interests of the organization and those of any of the persons subject to this Code collide, directly or indirectly, due to professional, personal, family or any other type of interest.
Persons affected by the conflict may not intervene in decision-making on behalf of the organization, even indirectly through a related person. The collision of interests, whatever the reasons, must be avoided in the first place, and then duly reported. In any case, the person concerned shall refrain from representing, taking decisions or making reports or indications, whatever they may be, if there is at least an indirect personal interest. All persons covered by this Code must adhere to the limitations and prohibitions regarding conflicts of interest, with the obligation, in any case, to inform the organization in the event that, directly or indirectly, and through family members up to the third degree, they participate in the governing bodies of other companies that may conflict with the interests of the organization.
All persons covered by this Code shall not only refrain from giving or offering gifts that exceed the reasonable limits of courtesy, but it is especially forbidden to give or accept, for themselves or for related persons, gifts, attentions or favors, material or immaterial, related to their professional work. Only gifts or presents of irrelevant value or of pure courtesy that are generally accepted may be accepted.
5.5.4. Financing of political parties
It is absolutely forbidden to make donations or contributions to state or foreign political parties.
Corruption with our political representatives is not just another form of corruption, but attacks the core of democracy and the basic ethics of relations with our institutions. For this reason, these activities are absolutely forbidden.
6.- INTERNAL FRAMEWORK OF CONDUCT
The basic framework of conduct for all persons concerned by this code, all general or individual behaviors that, directly or indirectly, may benefit the organization and whose eradication is essential, including for the proper functioning of the economy and society (illegal acts that lead to the undermining of the confidence of all public and private operators) is duly regulated. However, this is not sufficient without an internal framework of conduct that protects, in addition to the honorability of SALVI LIGHTING, its internal structures and its own existence as an economic operator.
6.1.- Internal Conflicts of Interest
Once the conflict of interest in general has been duly defined in external policies, in terms of internal conflicts, all employees must avoid collisions of particular interests with those of the organization, especially if they affect decision making.
It is absolutely forbidden to receive gifts directly or indirectly, regardless of their format, that are not considered mere courtesy or absolutely symbolic.
6.2.- Inside information and confidentiality
All persons covered by this code who, due to their professional activity, have privileged or non-public information about the organization, the dissemination of which could, directly or indirectly, harm the organization, without limitation, its honor, credibility, position in the market and in the eyes of consumers, customers and suppliers, shall refrain from making it public or disseminating it by any means and, especially, from providing it or announcing it in the competition or the media.
Confidentiality, as part of the contractual good faith in the organization's relations with the persons concerned by this Code, implies the maintenance of professional secrecy of the information available, be it commercial, economic, strategic, use of operational processes, work systems or any other internal procedure affecting persons, companies, customers or suppliers related to the organization. The confidentiality of the communication of privileged and confidential information may only be exempted at the express legal request of the public, fiscal, social, police or judicial administrations regulating the activities.
6.3.- Protection of assets
The organization is committed and obliged to provide all the necessary means for them to carry out their professional tasks. The organization's resources must always be used responsibly, appropriately and efficiently. Whoever uses them must protect and preserve them from inappropriate uses not permitted by law.
Likewise, the administration of its own or other people's assets shall be carried out in accordance with a lawful purpose and avoiding causing damage to assets, following the principles of loyalty to the purpose for which it is being administered.
It is not permitted to use the organization's professional equipment to download programs or any computer application whose use is not legal or which, even if legal, could damage the image or reputation of third parties or the organization.
6.4.- Use of SALVI LIGHTING's trademark and image
All persons concerned by this Code must exercise the utmost care in the use of the SALVI LIGHTING image and brand, whether such use is in conversations, documents, statements, seminars or press, and without limitation in any professional activity.
The distinctive signs (trade names, trademarks, domain names, etc.) used to distinguish SALVI LIGHTING are owned by the organization. Accordingly, they may not be used by third parties without express authorization.
The organization reserves the right to withdraw, have withdrawn or remove any of the public diffusion of its image or brand that does not conform to its image of honesty and honorability.
6.5.- Relations with partners and dealings with customers and suppliers
The treatment with the customer or supplier shall always be excellent, in accordance with the principles of efficiency and effectiveness. Never act in an overbearing or discriminatory manner.
ACCEPTANCE, RESPONSIBILITIES AND NON-COMPLIANCE WITH THE CODE OF ETHICS
This Code of Ethics and its updates or modifications are mandatory for the persons concerned.
The organization provides the necessary means to ensure that its employees are duly trained in the regulations applicable to the functions they perform, and will establish the necessary internal control models to ensure compliance with the law and ethical values. Persons subject to this Code are obliged to duly inform their immediate superiors or the supervisory and control body of any situation of non-compliance with the law, human rights or ethical values.
The Code of Ethics shall be duly disseminated to the persons concerned and to third parties to whom it is relevant. In addition, the persons concerned by this Code must commit and obligate themselves to comply with it when they start their activity within the organization, without the need for temporary subscriptions or constant reaffirmations beyond those communicated as a reminder of the obligations and guidelines for conduct contained in the Code. The management body has the obligation to promote knowledge of this Code by training the persons concerned and evaluating, where appropriate, the knowledge acquired.
Any doubts, as well as the interpretation or application of the Code of Ethics, should be consulted with the hierarchical superior or, as the case may be, with the person in charge of regulatory compliance. No person subject to this Code, regardless of his or her position, has the power or authorization to compel, request or recommend, directly or indirectly, that the Code of Ethics or its rules be violated. No person concerned by this Code shall justify non-compliance with the Code of Ethics or conduct that contravenes it on the basis of orders from superiors, due obedience or ignorance of the Code of Ethics.
It is the obligation of the persons concerned by this Code of Ethics to duly report any breaches or acts considered contrary to its rules, as well as any bad practices observed in the development of any of their activities related to the organization. This information or, directly, complaints should be sent through the established channels, using the relevant internal information channel.
The externalized reporting and whistleblowing channels are absolutely confidential and, upon request, anonymous.
Infringements, breaches or violations of the Code of Ethics by any of the persons covered by this Code may result in the imposition of sanctions, with the adoption, if appropriate, of the corresponding legal actions. All of the above, in accordance with the internal regulations of the organization and the disciplinary system. All of the above, without prejudice to any criminal liabilities that may be legally enforceable.
In compliance with confidentiality and anonymity, where applicable, and due impartiality in the investigation and management of the organization's disciplinary procedure, the management of the internal information channel and the disciplinary procedure is delegated to the members of the organization's supervisory and control body, whose independence and professionalism are guaranteed by the rules that regulate it.
