CODE OF ETHICS AND CONDUCT
AREA OF APPLICATION
The Code of Ethics and Conduct must inspire the actions that Vallas y Cercados ® organizes or encourages. Its content is mainly based on various texts written by both administrative and business entities of recognized ethical solvency, and adapted to the characteristics of the activities of Vallas y Cercados ® It will be observed by the staff representing Vallas y Cercados ® in any assignment, administrative action or management.
In order to achieve this purpose: The Code will be distributed to employees and collaborators, respectively so that they are aware of its content. The scope of the Code may be extended to any other person linked to the Group when, due to the nature of said relationship, their actions may affect, to some extent, the reputation of Vallas y Cercados ®
The content of the Code will prevail over that of those internal regulations that may contradict it, unless they establish more demanding conduct requirements. The application of the content of the Code, in no case, may give rise to the violation of the applicable legal provisions. If such a circumstance is appreciated, the contents of the Code must comply with the provisions of afore-mentioned legal provisions. The Code does not alter the existing employment relationship between the corresponding Group entity and its employees, nor does it create any special right or contractual relationship.
Employees and collaborators, both in the actions they carry out as a result of their relationship with Vallas y Cercados ®, and in those in which it could be interpreted that they are attributable to this Group or could affect its reputation, must comply with the content of the Code, which is based on ethical values, among which those that are key must be outlined:
Total respect for the dignity of the person and the rights that are inherent to him. Respect for the equality of people and their diversity, which requires, with respect to all types of personal and professional relationships derived from the Group’s businesses and activities, a respectful and equitable behavior in which there is no room for discriminatory attitudes based on sex , ethnic origin, creed, religion, age, disability, political affinity, sexual orientation, nationality, citizenship, marital status or socioeconomic status.
Strict Compliance with Legality, which requires full adherence, without exception, the obligation to observe the legislation applicable to the activities and operations of the Group and the actions related to them.
Professional Objectivity, which demands decision making and actions taken without accepting the influence of conflicts of interest or other circumstances that could question the integrity of Vallas y Cercados ® or its employees or collaborators.
Ensuring compliance with this commitment to ethical behaviour demands Responsible Conduct, which in turn requires:
Responsibility for actions, both institutional and individual, strictly adjusted to the principles and criteria of the Code, and a responsible attitude, which involves employees and collaborators in the identification, immediate communication and resolution, where appropriate, of ethically questionable actions.
RELATIONSHIP AND INTEGRITY
In the relationships that Vallas y Cercados ® establishes with its customers, suppliers, employees and with the community in which it carries out its business and activities, the ethical values contained in the Code and, particularly, the commitments and guidelines for action contained in this Chapter will be applied.
Customer relations Vallas y Cercados ® places customers at the heart of its dealings, in order to establish lasting relationships with them based on the reciprocal contribution of value and mutual trust.
Vallas y Cercados ® is committed to the continual review of its organisational processes to ensure constant improvements with regards to the attention and service its customers deserves.
Vallas y Cercados ® expects its clients to behave in accordance with the law and based on the ethical principles of the company and its relationship and social commitment.
Transparency: Vallas y Cercados ® is committed to provide its clients with timely, accurate and easy-to-understand information about its products, as well as clear and truthful information on: The fundamental characteristics of the products and services that Vallas y Cercados ® offers or supplies them. The commissions, fees, remuneration, prices and other costs that, with a general or particular nature, are applicable to them. The procedures established in the Vallas y Cercados ® Group to channel your claims and resolve incidents. This commitment requires special diligence in the professional performance of all persons with responsibility for the maintenance of information systems and processes.
Selection process and hiring of staff. By and large, the selection processes of Vallas y Cercados ® will be open, so that the greatest number of people with suitable qualifications to fill vacancies can gain full access, and will be developed according to objective assessment methods that take in consideration of the professional qualification and capacity of the candidates. The people on whom the selection and / or hiring of personnel depend, directly or indirectly, will guide their decisions and actions in a totally unbiased manner to prevent any form of bias or objectivity. With regards to their judgment and in accordance with the criteria established in the selection and hiring procedures, a neutral stance of the highest integrity is upheld.
The anagement and its style. Vallas y Cercados ® encourages teamwork as the architect of the generation of value, promoting a healthy climate of trust based on open relationships, mutual respect and support and ease of communication as a critical element in the integration of its professionals, stimulates creativity individual and encourages responsible decision-making, assuming the possibility of error. Promotion within staff at Vallas y Cercados ® will uphold equal opportunities and the recognition of the merit and capabilities of the individual measured through the assessment of their skills and performance. In compliance with these commitments, employees with their dependents must: Inform their collaborators about all critical aspects that must be taken into account for the correct performance regarding their duties. Identifying the training needs of your collaborators. Facilitate attendance and use of the corresponding training actions. Carry out periodic staff assessments in an objective and rigorous manner.
Occupational health and safety. Guaranteeing an environment free of health risks in all its activities and projects undertaken is a one of the most important aims achieved by Vallas y Cercados ® thanks to adopting standards and procedures, inspired by the best practices in occupational health and occupational risk prevention.
Recommendations. Ensure the safety of all those whose health could be affected as a result of their acts or omissions. Vallas y Cercados ® firmly upholds that both the objective of preserving a healthy work environment and that of achieving high productivity within a professional environment is incompatible with the consumption of illegal psychotropic substances or alcohol abuse. The performance of labour functions under its effects will be sanctioned in accordance with the applicable regulations. Relations with suppliers Vallas y Cercados ® considers that the effective articulation of the processes of acquisition of goods and services, particularly in business groups of its nature, constitutes a relevant source of value creation. Vallas y Cercados ® especially values those suppliers who share the principles that underpin the Code. Corporately established criteria that regulate the acquisition of goods and services will be applied, so that these are carried out in accordance with the following principles: Promote, whenever possible, the concurrence of a plurality of suppliers of goods and services whose characteristics and conditions offered are adjusted, at all times, to the needs and requirements of Vallas y Cercados ® Ensure that the acquisitions of goods and services are produced by reconciling the search for the most suitable conditions advantageous for Vallas y Cercados ® in each transaction, with the maintenance of the value attributed to sustained relationships over time with certain strategic suppliers. Guarantee the objectivity and transparency of the decision processes, avoiding situations that could affect the objectivity of the people who participate in them.
Political neutrality Vallas y Cercados ® carries out its business and professional activity without interfering, conditioning or influencing political pluralism in the territory in which it is located. As a result, relations with political parties, trade union organizations and other actors in political life will be governed by the principle of legality, respecting and applying the legal system and regulations.
Caring for the environment. Vallas y Cercados ® expresses its commitment to disseminate and encourage the adoption of environmentally sound practices among its employees and collaborators, and among other third parties with whom it is related. It will adopt measures to minimize the impact on its activities.
Gift delivery. Employees will refrain from offering or giving gifts or gifts to third parties that could have the purpose of promoting bias or causing improper influence or benefit or favour for Vallas y Cercados ®. In this way, only those gifts or donations may be offered or made in accordance with the procedures and authorisation and control requirements that are applicable by the governing bodies. Certain jurisdictions establish specific restrictions when the offer or delivery of gifts or gifts is intended for a public office. Afore-mentioned restrictions may be extended to any official or employee of the public sector, national, foreign or of international organisations, as well as candidates or leaders of political parties or trade union organisations. Any situation that could present any type of doubt regarding the legal provisions that may be applicable, should be consulted with the Legal Advice of Vallas y Cercados ®. Employees are obliged to scrupulously observe the restrictions that may arise from them.
It is the responsibility of all employees to collaborate in the aim to guarantee that all actions of Vallas y Cercados ®, within the framework of its activity, comply with the criteria and guidelines of action contained in the Code. Personal conflicts of interest. The impossibility of identifying and responding to each of the personal conflicts of interest that, in practice, may arise, means that the content of the Code is directed towards the establishment of criteria and guidelines for action that, respecting the private sphere of employees’ decisions, ensure their essential professional objectivity.
General criteria for the prevention of personal conflicts of interest. Employees must identify, in the performance of their duties, any situation that could affect their professional objectivity. All those situations referred to in the previous paragraph must be brought to the attention of the employee’s hierarchical superior as soon as they are perceived, and in advance of any action that could be affected by them. Any doubt about the way in which the potential conflict of personal interest should be resolved should be consulted with the governing bodies, whose opinion will be binding. Employees will not accept personal benefits or financial compensation from any client or supplier of Vallas y Cercados ®, or from any other natural or legal person who tries to do business with the Group. For the purposes of the Code, attendance at social events, seminars and other types of training activities that have been duly authorized in accordance with established procedures, as well as invitations to professional lunches, will not be considered as personal benefit. In general, only promotional gifts or courtesy details may be accepted. In any case, if its economic value exceeds 100 euros, the beneficiary must make the gift available to Vallas y Cercados ® which, depending on its nature, will determine its final destination. Vallas y Cercados ® and its employees must ensure the timely dissemination of this criterion among their customers and suppliers. Information registration and document preservation Information registration Regardless of the responsibilities specifically assigned to certain areas of the Group regarding the integrity and availability of information, employees are responsible for its reliability, precision, integrity and updating. Of the data incorporated into the different types of records owned, used or processed by Vallas y Cercados ® (physical or logical). From the information prepared in the development of their functions. The exercise of such responsibility is particularly relevant with respect to the data and reports that are necessary for the preparation of the Group’s financial statements, since their proper recording and interpretation are essential to ensure the correct application of the valuation criteria corresponding to each balance. accounting, transaction or contingency.
Respect for people’s dignity. In no way shape or form can the work, professional or contractual relationships established by Vallas y Cercados ® employees with other people, may be used to encourage situations of harassment or intimidation or any other that threatens their personal dignity or their discrimination. Collaboration with supervisors and official bodies Employees are obliged to collaborate with the bodies and areas of supervision and control of Vallas y Cercados ®, with external auditors and with official bodies that act in the exercise of their functions, as well as with any third party that Vallas y Cercados ® had designated for specific purposes that require or involve such collaboration. Failure to comply with this obligation, false statements, those that seek to lead to erroneous conclusions or the simple concealment of information, may lead to the adoption of disciplinary measures, as well as other types of civil or criminal actions in which both Vallas y Cercados ® and the corresponding employee could be involved.
Political activities. The right of employees to participate in legally recognised political activities must be exercised in such a way that those activities cannot be understood, in any way, as attributable to Vallas y Cercados ® or could question its commitment to political neutrality. Likewise, such participation must not affect the professional objectivity of the employee or diminish his dedication to the Group beyond what, where appropriate, the legislation in force may establish. In particular, those employees who, in the exercise of their rights, undertake a political activity must respect the following requirements: Carry out possible political activities outside working hours and at the facilities and works of Vallas y Cercados ® In the case of employees included in political campaign candidacies, avoid any reference in the electoral campaign, verbal or written, to the link that relates to Vallas y Cercados ®.
External communication. Generally speaking, the power to disseminate information on TECHNICAL CONSULTANCY, in circumstances other than those related to institutional presentations on the Group’s financial statements or on the evolution of its businesses and results, is limited to those specifically designated persons. For this purpose in the governing bodies and in the corresponding departments with their authorisation. The adoption of this criterion requires compliance with the following guidelines for action by employees: Any person who, on behalf of a media, requests any type of information or opinion as a result of their relationship with Vallas y Cercados ® , must be sent to the corresponding Department of Communication and Image. Participation in any event (interview, presentation, publication of articles, etc.) that could imply the public dissemination of information on Vallas y Cercados ® is reserved to the directive bodies or entities proposed by them. Personal integrity and activities, or the issuance of opinions that could be attributed to Vallas y Cercados ® (other than those issued by the specialised departments to which said function would have been specifically attributed), must have the prior approval of the corresponding Communication and Image Department.
Development of other professional activities. In the event that the performance of professional activities other than the provision of services to the Group is permitted by the working conditions of the employees, they may perform them when: They do not imply a decrease in the expected effectiveness in the performance of the tasks. Functions developed in Vallas y Cercados ®, do not limit the availability or schedule flexibility required to certain functions in Vallas y Cercados ®, do not imply the development of functions or the provision of services, of any kind, for competitors of the Group. As a consequence of the special relevance of the managerial functions of Vallas y Cercados ®, the people who perform them must focus their professional efforts on the development of their role within the Group, avoiding the performance of other professional activities other than those related to: Activities charity, charity or social services, provided they do not involve any remuneration. Family affairs and businesses, provided they are sporadic in nature and do not pose any conflict of interest with the Vallas y Cercados ® businesses. The teaching or the development of content aimed at the dissemination of knowledge. Other types of activities that Vallas y Cercados ® could promote due to its social interest or because it considers them appropriate for the interests of the Group. Regardless of the responsibilities specifically assigned in the Group to certain areas of its organisation in terms of safeguarding the assets, tangible and intangible goods (jointly, the resources) owned by Vallas y Cercados ®, employees have the following obligations: Use the Vallas y Cercados ® resources efficiently and appropriately, and only for the performance of their professional activity at Vallas y Cercados ® or for those cases that may be provided for in the corresponding internal regulations. Protect the resources of Vallas y Cercados ® and preserve them from inappropriate uses. Personal integrity that could result in economic damage or deterioration of the Group’s reputation. Except in the cases provided for by the corresponding internal regulations, it is not allowed to dispose of the resources owned by the Group and of those others delivered in custody by third parties (within which there is any type of information referring to them) outside the facilities of Vallas y Cercados ® work projects.
Responsible attitude. Preserving the Corporate Integrity of Vallas y Cercados ® transcends mere personal responsibility for individual actions and requires the commitment of employees to outline, through their timely communication, those situations that, although not related to their actions or scope of responsibility, they consider ethically questionable in accordance with the content of the Code and, especially, those from which the breach of current legislation could be derived. The recipients of these communications or, where appropriate, those who attend them, have the following obligations: Preserve the anonymity of the person who has communicated, in good faith, legitimate concerns about possible breaches of current legislation or about apparently questionable situations from an ethical point of view. Inform the communicating person of the resolution adopted on the situation in question. In general, both the reported situation and, where appropriate, the information related to its resolution, must be adequately safeguarded by all the people involved in the communication process and in the eventual investigation process. Vallas y Cercados ® prohibits any act of retaliation against any employee for the mere fact of having communicated, in good faith, the situations described in this section. Vallas y Cercados ® expects from its employees, and particularly from those who perform managerial functions, a proactive attitude in identifying ethically questionable situations. Termination of the relationship with Vallas y Cercados ®. Any person who ends the relationship with Vallas y Cercados ® that gave rise to their adherence to this Code will refrain from using any information obtained during their relationship with the Group, including lists or relationships of clients, suppliers, collaborators and staff. Employees assume that the work carried out for the Group, whether or not it is considered intellectual property, belongs exclusively and in its entirety to Vallas y Cercados ®. Reports, proposals, studies, programs and any other product derived from the professional activity in the Group will remain in the possession of Vallas y Cercados ® without the outgoing person being able to copy, reproduce or transmit them in any way without written authorization from Vallas and Cercados ® Employees undertake to return the material owned by Vallas y Cercados ® that they have in their possession at the time of ceasing their activity in the Group.