Anti-corruption policy
VERSION 1 · DATE: 19/07/2024 · DOCUMENT SECURITY LEVEL: Internal use. Its reproduction, distribution or communication outside the recipient is not permitted without authorization. Once this document is printed, the user must ensure that it matches the latest version available on the Server.
Purpose
As members of the United Nations Global Compact, Ecomanagement Technology, hereinafter EcoMT, has a firm commitment to corporate sustainability and to complying with the highest standards of integrity, transparency and respect for legality and human rights. This policy reaffirms that commitment and develops, in particular, the fight against bribery and corruption mentioned in its Code of Conduct.
The purpose of this policy is to ensure that, under no circumstances, EcoMT’s employees or collaborators will engage in unethical practices that could be interpreted as inducing a lack of impartiality, transparency or integrity in the performance of their duties or in that of the third parties with whom they interact, whether in the public or private sphere.
This commitment against bribery and corruption is not an option. EcoMT applies the principle of zero tolerance towards practices that contravene that commitment.
Scope
This policy is applicable to all its directors, executives and employees (hereinafter, employees) and to all persons and companies that collaborate and interact with EcoMT (hereinafter, collaborators).
This policy is applicable to all the countries in which EcoMT operates, with the appropriate adaptations according to the legal framework existing in each country. In Spain, compliance will be given to, among others, the Criminal Code, the United Nations Convention against Corruption and the OECD Convention on corruption. In the event that there is any discrepancy between this policy and the Spanish regulatory standards, or those of other countries, the stricter standard will apply.
The approval of this policy, as well as of any internal procedure or additional rule on this matter, must have the approval of EcoMT’s Management.
Prohibited practices
The materialization of the commitment against bribery and corruption undertaken by EcoMT is the absolute prohibition of engaging in the following unethical practices or conducts:
- Offering, promising or granting, directly or indirectly, bribes to any third party, whether belonging to the public or private sphere.
- Offering, promising or granting, directly or indirectly, facilitation payments to initiate or facilitate administrative processes or procedures.
- Offering, promising or granting, directly or indirectly, gifts, presents or courtesies to any third party that may induce possible favorable treatment or reciprocal considerations.
- Offering, promising or making, directly or indirectly and on behalf of EcoMT, contributions for political purposes.
- Obtaining favorable treatment by using sponsorship or donation.
- Requesting, accepting or receiving any kind of unjustified benefit or advantage in order to unduly favor a third party in the purchase or sale of products, contracting of services or in any other commercial or business relationship.
- Establishing business relationships with third parties without complying with the minimum due diligence duties in knowing third parties.
- Signing, on behalf of EcoMT, any type of false or invalid documented agreement.
Permitted practices
EcoMT understands that, as part of business and commercial relationships, the exchange of gifts is a common standard. Therefore, it permits the receipt and giving of these, as long as they have an irrelevant or symbolic economic value and present no exception in relation to the current legislation.
Whistleblowing channel
Any employee who has doubts or concerns regarding any aspect of this policy should go to their director or area manager or to Management. In any case, EcoMT provides its employees with a confidential whistleblowing channel through which any type of suggestion, question, suspicion or complaint can be conveyed.
EcoMT’s Management will receive these communications for their analysis and the consequent decision-making. They will always be treated in a strictly confidential manner and no reprisals will be tolerated against the people who, in good faith, make use of them.
Dissemination
In order to guarantee compliance with this policy, EcoMT will disseminate it among all its employees and collaborators and will keep it accessible to them at all times. All employees and collaborators who enter into a contractual relationship must accept the precepts established herein.
Validity
This policy will be applicable from the moment it has been approved by Management and made available to all employees and collaborators.
