SUMOL+COMPAL Code of Conduct
The purpose of the Code of Conduct is to identify a set of ethical principles and practices and rules to be observed by all employees in fulfilling their respective professional duties.
In other words, the Code of Conduct aims to ensure best practices in terms of professional and relationship-based conduct and is intended to:
- Clarify the rules of conduct that all employees must comply with in their relations with each other and with any other interested parties;
- Bolster the trust of all those who deal with SUMOL+COMPAL in its principles and behaviour;
- Ensure a good reputation for S+C.
1. ETHICAL PRINCIPLES
The following ethical principles are especially important for SUMOL+COMPAL:
- Professionalism: to apply the most appropriate knowledge and techniques and the necessary effort to fulfilling the tasks entrusted to each employee. To seek to update and develop knowledge and expertise with a view to improving professional skills;
- Integrity: to act with honesty, abstaining from seeking or accepting any reward, favour or benefit from third parties for any action taken in the service of SUMOL+COMPAL and refusing to intervene in situations in which there is, or may be, a conflict of interests;
- Independence: to act on behalf of SUMOL+COMPAL’s interests and impartially with regard to third parties;
- Good faith: to be trustworthy, fair, loyal and cooperative towards internal and external interlocutors;
- Non discrimination: to make no distinction based on race, gender, sexual orientation, credo, marital status, disability, political persuasion, ethnic or social origin, or place of birth;
- Responsability: • to act within the scope of the responsibility and independence allocated. To protect and preserve SUMOL+COMPAL’s assets by using its resources sensibly and carefully;
- Confidentiality: to maintain the secrecy of information to which employees have access while performing their duties and not use it to obtain benefits for themselves or third parties;
- Non-conflict: to restrain from direct or indirect involvement in activities which compete with SUMOL+COMPAL;
- Loyalty: to protect the good image, credibility and prestige of SUMOL+COMPAL and its brands in every situation;
- Legality: to always act in compliance with the law and the applicable regulations.
2. APPLYING ETHICAL PRINCIPLES IN RELATIONS WITH INTERESTED PARTIES
Some of the ways in which ethical principles are applied in relations with interested parties are presented below:
- To protect the interests of all shareholders at all times through equal treatment and non-discrimination.
- To ensure the accuracy and truth of information provided in real time to shareholders and the market.
- To maintain the confidentiality of information accessed while performing one’s respective duties (all relevant financial market information must remain absolutely confidential. SUMOL+COMPAL has an Investor Support Office whose job is to inform the market in accordance with applicable legislation and CMVM regulations. No employee is authorised to advise or undertake any type of transaction, either directly or indirectly, with regard to SUMOL+COMPAL securities based on privileged information).
- To promote a good working environmenta and have cordial relations with colleagues, regardless the hierarchical level.
- To resolve disputes through open and honest dialogue with total respect for differences of opinion.
- To defend SUMOL+COMPAL’s interests and not those of individuals, groups or areas.
- Don't accept child or forced labor and ensure no type of discrimination whatsoever.
- To ensure transparency about the environmental information provided.
- To adopt practices to promote non-discriminatory wellbeing.
- To treat clients with professionalism, respect, honesty and loyalty in conditions of equality and without any type of discrimination, namely in providing information and handling of complaints.
- To provide clients with excellent products and services in compliance with accepted commitments at all times.
- To maintain a healthy partnership with suppliers based on professionalism and respect in compliance with accepted commitments at all times.
- To select suppliers based on criteria of impartiality and without any form of discrimination but favouring those who most clearly share similar ethical principles to our own.
iii. FINANCIAL INSTITUTIONS
- Promote a loyal and honest relationship with the financial entities, guaranteeing the accuracy and veracity of the information provided.
- Maintain a cooperative relationship with partner universities, promoting greater visibility and attractiveness of S+C among students and contributing to a closer relation between universities and companies.
- Respect consumers, constantly seeking to anticipate and meet their needs and desires through the generation of new proposals.
- Always provide true information about the brands and the company.
f. GOVERNMENTAL, REGULATORY AND SECTORAL ENTITIES
- To collaborate with public bodies and regulators, responding to requests addressed to them and not adopting any behavior which might hinder the exercise of the duties they have been allocated.
- To cooperate closely with the associative entities in the defense of the interests of the sector.
- To maintain cordial relations based on principles of independence, impartiality, clarity and respect.
- To promote and practice fair competition.
- To maintain cordial institutional relations based on mutual respect and honesty.
- To keep with the media and journalists a cordial relationship of respect and sound cooperation, conveying information about S+C activity.
4. GIFTS, INVITATIONS OR OTHER BENEFITS
- No employee may accept or offer any gift or other benefit which may be regarded as an attempt to influence a current or future decision-making process, or as a reward with regard to a decision taken.
- Any employee who accepts a gift or invitation estimated to be worth more than €150 must seek approval by the member of the Executive Committee responsible for the area in question, who must inform the Chair of the Executive Committee of their decision in writing.
- The procedure to be applied togifts or invitations made to the directors is set out in the By-Laws of the Board of Directors.