Code of Ethics and Conduct
GRUPO ANTOLIN
This Code replaces all the previous Codes of Ethics and Conduct and completes the policies and
guidelines that govern our Group and our companies. This text remains the only Code valid
throughout the entire scope of Grupo Antolin and if necessary, due to special and extraordinary
circumstances of a local nature, it will be supplemented by a special appendix adapted to the
corresponding country.
Compliance with the code is a condition for forming part of the team of professionals at Grupo
Antolin. However, this conduct requirement does not imply an employment contract or a job offer.
Grupo Antolin prefers to work and interact with people, groups of people, institutions or any other
form of organization that share the principles and commitments contained in this code;
encouraging the adoption of international standards of conduct and action in line with that
described in this document.
This code does not specifically address each and every one of the situations that could arise in the
running of our business. It also does not provide a list of responses to be able to deal with all the
business situations that could occur on a daily basis, nor can it replace common sense when
deciding how to act or behave.
Grupo Antolin reserves the right to review, amend and update the content of this code or its
sections at any time, in order to make it more flexible to the changing expectations and needs of
the company, its stakeholders, the current legislation and the commitments acquired in any or all
of the matters contemplated in it.
The content of the Ethical Code may not be unilaterally amended as this is the exclusive
responsibility of the Ethics Committee which, where necessary, will establish the corresponding
local appendix in order to complement it and meet local demands in each specific matter.
Any amendment, whole or part, of its content will be communicated promptly to all its recipients,
again obtaining their adherence to the procedures and systems designed for such purpose.
The original language of this document is Spanish (Castilian). The text is available in the languages
of the countries in which Grupo Antolin operates, in order to facilitate its understanding and
acceptance by the entire workforce. In the event of any conflict, the reference document is the
Spanish version which will prevail over all others.
This publication is the property of Grupo Antolin. For any queries concerning the Code or its
content, please contact:
Grupo Antolin - Code of Ethics and Conduct
Ctra. Madrid-Irún, km. 244.8
09007 BURGOS – SPAIN
Tel.: +34 947 47 77 00
Fax: +34 947 48 49 19
Email: [email protected] / [email protected]
www.grupoantolin.com
The text of the Code of Ethics and Conduct has been approved by the Board of Directors ofGrupo Antolin within the framework of its meeting held on October 8, 2015.
“One team,
one model of conduct.”
Being a leading sustainable company has always been the goal for Grupo
Antolin, a family company created more than 50 years ago as a result of the
dream of two entrepreneurs which, thanks to people like you, has become one of
the main suppliers of technology for car interiors.
The inclusion of sustainability in the company's business strategy has allowed us to
embrace aspects of an ethical, social and environmental nature, beyond the
vision of the traditional company. Innovation, financial strength and
internationalization are combined with ethics, good governance and
transparency as the pillars of our progress, reinforced with the publication of our
first Code of Ethics and Conduct in 2010.
The development of the Group, its adaptation to the new growth scenarios and
the new demands from customers and expectations of the other stakeholders,
have prompted the development in 2015 of a new version of this document, as a
mandatory corporate standard, with responsibilities shared by all of us who form a
part of this great team.
Given the impossibility of covering each and every one of the situations that could
arise when running our business, the Code is conceived as a roadmap that
summarizes our firm commitment to complying with human rights, dialog with
stakeholders, respect for strict compliance with legislation, the creation of a safe
working environment, the fight against corruption and, finally, environmental and
socially responsible commitment wherever Grupo Antolin is present. Additionally,
we must strive to ensure that these commitments are also shared by any person or
organization who maintains a business relationship with the Group.
I would like to take this opportunity to encourage you to make any suggestions or
comments, through the channels provided, regarding anything contained in this
Code or its application, which allows us to be a unique role model, a true
reflection of the company's values since its creation.
L e t t e r f r o m t h e P R E S I D E N T
Ernesto AntolínPresident
Contents
1. I Our Corporate Culture…………………5
2. I The Code of Ethics and Conduct…...6
3. I The Code: Our commitment……….....8
4. I The Code: The Team……………....….10
5. I The Transparency Channel……........14
6. I The Ethics Committee……………...…17
7. I Action Protocol………...................….18
8. I Acceptance………………………..….19
About the Code……………….………...….21
Glossary of terms
Internal legal references
Summary Annex
GRUPO ANTOLIN
Code of Ethics and Conduct4
M
A
I
Ns t r e a m i n g
Customer focus LeadershipCreativityI Positive response to change
I Innovative thinking
I Drive to be the best
I Communication
I Trust
I Development of people
I Sense of belonging
I Professionalism
I Pro-activity
M I S S I O N
V I S I O N
Ethics
Good
Governance
Transparency
V A L U E S
To be the leader in solutions for interior
car trims due to our technological
capacity, providing competitive interior
car trim solutions.
To be the preferred market option due
to our capacity for innovation and
competitiveness, offering an attractive
return to our shareholders and being a
sustainable leading company for our
employees and society.
competencies
O u r CORPORATE CULTURE shared values for sustainable development
CORPORATE
CULTURE
CODE OF ETHICS
AND CONDUCTOUR COMMITMENT THE TEAM
WHISTLEBLOWING
CHANNELTHE ETHICS
COMMITTEE
ACTION
PROTOCOL
GRUPO ANTOLIN
Code of Ethics and Conduct
5
1
T h e C o d e o f E t h i c s a n d C o n d u c t
WHAT is it?
I The Grupo Antolin Code of Ethics and Conduct (together with the Grupo Antolin Policies and
Guidelines, hereinafter the Code) is a living document approved by the Ethics Committee
and endorsed by the Board of Directors. Its main aim is to ensure ethical and responsible
behavior when running our business.
WHY do we have it?
I With this document, Grupo Antolin makes public its commitment to the guidelines in the
Universal Declaration of Human Rights, the Guiding Principles on Business and Human Rights,
Children's Rights and Business Principles, as well as with the principles of the United Nations
Global Compact (of which it has been a founding partner in Spain since 2004) and the
guidelines and principles of the International Labor Organization (ILO) and the Organization
for Economic Co-operation and Development (OECD).
WHAT is it for?
I This text is a reflection of the values that must guide the conduct of the company and the
people who work for it. It must lead to honesty, ethics, professionalism and transparency in our
relations with the customers, shareholders, employees, suppliers and society in general.
WHO has written it?
I The Grupo Antolin Ethics Committee, consisting of internal and external professionals, experts
in matters of Corporate Responsibility and labor and legal issues, has been responsible for
producing the final text.
In producing it, the needs and expectations of our main stakeholders have been taken into
account, as well as the regulatory and market requirements applicable to our business.
TO WHOM does it apply?
I The Code applies to all employees connected to Grupo Antolin, regardless of the
employment contract that determines their relationship with the company, the position they
occupy in the organization and the country in which they work.
Grupo Antolin extends its commitment to all subsidiary companies in which it is the majority
shareholder or has management control, as well as to its supply chain.
WHEN does it apply?
I The Code of Ethics and Conduct enters into force on the very day that Grupo Antolin makes
its commitment public.
Those who violate the Code or the policies and procedures of Grupo Antolin will be subject to
disciplinary measures proportionate to the offense, and will be punished to the full extent
allowed by the current regulations. Disciplinary action will also be taken against anyone who
orders or approves infringements or is aware of them and does not immediately act to
remedy them.
2an action model
CORPORATE
CULTURE
CODE OF ETHICS
AND CONDUCTOUR COMMITMENT THE TEAM
WHISTLEBLOWING
CHANNELTHE ETHICS
COMMITTEE
GRUPO ANTOLIN
Code of Ethics and Conduct
6
ACTION
PROTOCOL
HOW is it applied?
I The Code is not a set of internal rules, nor does it replace any collective agreements or
national, European or international legislation. However, the company places great
importance on compliance with this Code, so all Grupo Antolin employees must be aware of
and respect the content and spirit of the document.
The Code must be read and interpreted jointly with Grupo Antolin's Policies, Guidelines and
Management Model. These Policies and Guidelines implement the commitments contained in
the Code and are available in the systems provided by the company through the Intranet
page and on its website.
In the event that the rules existing in a certain jurisdiction are more permissive than those
contained in this Code, the guidelines contained in the Code will prevail.
However, the current law, employment contracts and application of specific policies may
vary depending on the geographical location. See the different appendices to obtain
specific information about your country or region where applicable.
In the event of a conflict between local laws or employment contracts and a company
policy, these will take priority over the company policy. Furthermore, local policies and
practices must be adapted to reflect the Company's international policies.
Lastly, we must always call on our sense of responsibility and good judgement and in the
event of any doubt over the correct business conduct talk to our line managers, to the
Management or to the Ethics Committee, if deemed necessary.
WHERE can I find it?
I The Grupo Antolin Code of Ethics and Conduct is available to everyone working in any of the
companies that form part of the organization.
http://intranet.grupoantolin.com/sites/apps/EC
A printed version of the text is included in the procedure for welcoming new joiners, and a
copy of it can be requested at any time from the Human Resource department of each
company.
The official Spanish version and the English version are available to the general public on the
Grupo Antolin website. http://www.grupoantolin.com/en/people
T h e C o d e o f E t h i c s a n d C o n d u c t
2an action model
CORPORATE
CULTURE
CODE OF ETHICS
AND CONDUCTOUR COMMITMENT THE TEAM WHISTLEBLOWING
CHANNEL
THE ETHICS
COMMITTEE
ACTION
PROTOCOL
GRUPO ANTOLIN
Code of Ethics and Conduct
7
Compliance with the Code of Ethics and Conduct is a necessary condition for forming part
of the team of professionals at Grupo Antolin. This applies from the moment their
relationship starts with the company. The company will request that, after reading it, the
employee agrees to it through signing it or providing online acceptance.
T H E C O D E : O u r
Human RightsGRUPO ANTOLIN supports Fundamental Human
Rights, avoiding and reporting any commercial,
economic and industrial activities that abuse
those rights.
GRUPO ANTOLIN acts with due diligence to
identify, prevent, mitigate and remedy any
possible negative impact and consequences
that its activities may have on human rights,
either directly or through its supply chain.
.
Through its international expansion Grupo Antolin is contributing to the global development
of the economy and society. It focusses on creating a sustainable future and working on the
impact of our activity on the environment, people and the social environment in which we
operate. We are committed to universal values that govern the behavior of the Group in all
its activities.
Labor StandardsGRUPO ANTOLIN defends the freedom of
association and the effective recognition of the
right to collective bargaining.
I It supports the elimination of all forms of forced
and compulsory labor.
I It respects the current legislation on working hours
in each country.
I It applies wage policies that are consistent with
the local legislation, including respecting
minimum wage conditions.
I It supports the abolition of child labor.
I It is in favor of the abolition of discriminatory
practices in employment and occupation.
I And it implements an occupational health and
safety management system.
The EnvironmentGRUPO ANTOLIN aspires to act in a way that
minimizes the harmful impact on the
environment of its industrial, commercial and
economic operations.
I It encourages initiatives that promote
greater environmental responsibility.
I And it promotes the development and
dissemination of environmentally-friendly
processes and technologies.
GRUPO ANTOLIN is committed to preventing,
detecting and eradicating any illegal actions
carried out within the scope of its
responsibilities, in its name or on its behalf and
for its benefit, by any of its legal
representatives, de facto or de jure
administrators and employees. For this
purpose, Grupo Antolin has a model which
organizes and manages criminal risks.
GRUPO ANTOLIN bases its relationships with
employees and ex-employees and their
family members, as well as with candidates,
customers, suppliers and other groups of
people directly or indirectly related to the
company, on the protection of confidential,
secret and personal data.
3 as a company, as a customer, as a supplier
Diversity and equalityGRUPO ANTOLIN establishes and develops policies
that include equality of treatment and
opportunities between men and women without
directly or indirectly discriminating on the basis of
sex, race, color, language, religion, opinion, origin
or any other personal and/or social condition or
circumstance.
GRUPO ANTOLIN considers diversity in all policies
regarding people management, treating it as a
cross-cutting factor that is used as the foundation
for all decisions taken in this area.
Safety in operationsGRUPO ANTOLIN provides mechanisms* that act across the entire organization and govern the
environment of control and the information and communication systems, effectively eliminating
the risks of errors with a material impact in the area of financial information.
* set of monitoring procedures and activities that include controls over the processes, systems, accounts and transactions, as well
as general controls for the Company, which include the control activities belonging to the Board and Senior Management which
affect everything.
GRUPO ANTOLIN
Code of Ethics and Conduct8
Data protection
GRUPO ANTOLIN recognizes, respects and complies with the international, regional and national
standards for behavior, including the legislation on tax and town planning issues in the countries
and territories where it operates; as well as their culture, customs and history.
Legislation
GRUPO ANTOLIN respects and promotes children's rights within its sphere of influence
Anti-corruptionGRUPO ANTOLIN is committed to supporting international
and local efforts to eliminate corruption and financial
crime, always complying with the anti-money laundering
laws that apply in any competent jurisdiction.
GRUPO ANTOLIN will not tolerate any type of corruption
(accepting or offering money to obtain improper
commercial gain), preparing organizational models to
assess and ensure compliance with the Ethical Code
where convenient or when the laws require this.
GRUPO ANTOLIN operates its business without breaching
the national or international laws relating to international
trade, economic embargoes and export controls that
apply in the countries in which it operates.
GRUPO ANTOLIN defines a fiscal strategy and a policy for
the control and management of risks, as well as the
approval of investments and operations with special risk,
based on compliance.
GRUPO ANTOLIN will facilitate the work of auditing or
supervisory individuals, organizations and inspection
bodies.
C O M M I T M E N T 3
Information transparencyGRUPO ANTOLIN ensures, through its
appropriate management and control
bodies, that it provides a true
representation through its information,
paying special attention to the financial
and economic information that reflects
the company's economic, financial and
equity position in accordance with the
generally accepted accounting
principles.
External relationsGRUPO ANTOLIN is committed to
competing in the market vigorously and
fairly, and will do so in full compliance
with all the anti-trust laws in the different
countries in which its commercial
practice is carried out.
GRUPO ANTOLIN is committed to
collaborating with people, groups of
people, entities, associations and public
and private organizations on research
and development into innovative
solutions for intelligent mobility that
contributes to the ongoing
development of society.
InnovationGRUPO ANTOLIN incorporates
innovation into our daily activity
throughout the entire value chain,
promoting technological progress and
positively contributing to the sustainable
future of the car.
Non-funding of the political,governmental and terrorism spheresGRUPO ANTOLIN strictly limits the use of the company's
resources with regards to supporting political causes or
campaigns. It will not pay any amount, or provide any
services, to political parties, holders of public office or
candidates for those offices, administrative authorities or
their employees, even if those contributions are
considered legal by virtue of the laws of the country
where those payments may be made.
However, GRUPO ANTOLIN respects the right of everyone
providing their services in any of the businesses forming
part of the company to be involved in political or religious
activities or in private non-profit initiatives, provided that
they are carried out outside working hours and do not
interfere with the professional development of their
activity and that they are not carried out using the name,
conditions or resources of the organization.
as people and as members of society
GRUPO ANTOLIN
Code of Ethics and Conduct
9
GRUPO ANTOLIN may be involved in sponsorship, patronage or social welfare activities, on its own
behalf or in association with third parties, always seeking projects and alliances that offer value to
the company and/or its stakeholders and that apply the values and principles contained in this
Code.
Any form of economic action, aid or mediation that provides financial or any other type of support
to the activities of terrorist elements or groups is PROHIBITED.
SustainablecontributionGRUPO ANTOLIN contributes directly and
indirectly, as a result of its business,
products, technology and services, to
the global and local development of the
economy, society and the environment
of the communities where it operates.
GRUPO ANTOLIN is committed to protecting and maximizing the value of the investments made by
shareholders, promoting the reasonableness of the return on these.
Economic sustainability
10
The
company
HUMAN RIGHTS LEGISLATIONLABOR
STANDARDS
THE ENVIRONMENT DATA
PROTECTION
SAFETY
IN THE
OPERATIONS
DIVERSITY AND
EQUALITY
ECONOMIC
SUSTAINABILITY ANTI-CORRUPTION
NON-FUNDING
OF THE POLITICAL,
GOVERNMENTAL
AND TERRORISM
SPHERES
SUSTAINABLE
CONTRIBUTION
INFORMATIVE
TRANSPARENCY INNOVATION EXTERNAL
RELATIONS
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OUR ACTION MODEL
GRUPO ANTOLIN
Code of Ethics and Conduct
Our staff INTEGRITY RESPECT CONFIDENTIALITY
INDEPENDENCE WELLBEING, HEALTH AND SAFETY
RESPONSIBLE MOBILITY KNOWLEDGE MANAGEMENT
RESPONSIBLE ENVIRONMENTAL BEHAVIOR RESPONSIBLE USE
OF RESOURCES QUALITY IN MANAGEMENT IMAGE AND
REPUTATION FREEDOM OF EXPRESSION PRIVACY OF
INFORMATION MAINSTREAMING SUSTAINABILITY
PROHIBITING CONTRIBUTIONS ON BEHALF OF THE GROUP
ABSENCE OF A CONFLICT OF INTERESTS CULTURE OF
COLLABORATION AND MANAGEMENT
4
WELLBEING, HEALTH AND SAFETYLooking after their health and ensuring a healthy
and safe environment by complying with and
enforcing the standards and measures on healthand safety, as well as responsibly using the Group's
resources and facilities, regardless of where the
work is carried out; never working under the
influence of alcohol, drugs or any other substance
that may impair the professional behavior and/or
safety of the person themselves and those who
surround them.
Nobody may use, posses, manufacture, distribute,
administer, transport, promote or sell legal, illegal or
illicit substances, or drugs paraphernalia, in the
performance of the Company's economic,
industrial and commercial activities or in the
Company's facilities.
INTEGRITYBeing honest and trustworthy, basing our
competitiveness on the quality of ourproducts and services, avoiding situations
that muddy professional and ethical
responsibilities, ensuring that any
payment, expense or gift by or on behalf
of the company is legal and for legitimate
purposes, in accordance with the
international and national laws against
corruption.
RESPECTTreating in a polite, respectful and fair
manner all professionals in Grupo Antolin,
as well as the customers, serviceproviders and other stakeholders,
applying the company's policies in
matters of diversity and tolerance, without
any discrimination on the basis of birth,
race, color, sex, language, religion,
opinion, origin, or any other personal
and/or social condition or circumstance.
Not carrying out or tolerating violent
behavior, threats, coercion or any form ofintimidation or harassment by the
managers and colleagues or the
customers, suppliers or any other agent
related to the company.
Striving to create a pleasant andrespectful working environment, using the
tools provided by the company available
to all employees in order to express our
degree of satisfaction with the policies
and processes of Grupo Antolin.
CONFIDENTIALITYMaintaining the necessary confidentiality, within the
professional ethical framework, in all those aspects
relating to the work where it is necessary to maintain
professional secrecy, both internally and externally,
with suppliers, customers, competitors and potential
investors; even after the termination of the labor
relationship.
INDEPENDENCEEnsuring our independence, not allowing ourselves
to be influenced by factors other than ourprofessional judgement, avoiding involving ourselves
in any situation or service where, due to a possible
conflict of interest or any other circumstances, our
impartiality or the objectivity of our judgement may
be affected.
RESPONSIBLE MOBILITYDriving safely, respectfully and responsibly, in
accordance with the applicable legislation, road
standards and signs and taking the necessary
precautions for our own safety and the safety of
the passengers in our professional and/or work
related journeys.
OUR STAFF
11GRUPO ANTOLIN
Code of Ethics and Conduct
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PRIVACY OF INFORMATIONEnsuring the accuracy and integrity of all the information andcommunication disseminated internally and externally with due
prior authorization from the company.
Respecting the private life of people and refraining from sharing
information relating to their professional and/or personal life
obtained during the development of their work or professional
activity, either informally or by chance.
KNOWLEDGE
MANAGEMENTPreserving the knowledge ofthe company, facilitating its
dissemination to other
employees in the Group and
making it available through
the knowledge management
systems enabled in the
company for such purpose.
RESPONSIBLE ENVIRONMENTAL BEHAVIORContributing to the continuous improvement of ourenvironmental behavior, integrating the environmental policy of
Grupo Antolin into our daily conduct and activities within the
company.
RESPONSIBLE USE OF
RESOURCESUsing the technical and
material resources made
available by the companywith due diligence, in order to
prevent damage arising from
their misuse, being
responsible for both their
custody and suitable storage,
as well as for ensuring that
they are used in accordance
with the current internal laws
and regulations.
QUALITY IN MANAGEMENTApplying the processes defined by the Organization forachieving objectives in the running of our business and
reasonably ensuring compliance with the standards
applicable to the company, the effectiveness and efficiency
of the operations, the reliability of the information and the
safeguarding of the company's assets, staff and information.
Undertaking to achieve the best possible quality as an
individual, as a team and as a corporation, always seeking
continuous improvement.
IMAGE AND REPUTATIONRepresenting Grupo Antolin in a responsible manner whilecarrying out our professional activity, always and everywhere,,
being aware that any action, omission or decision on our part
directly or indirectly affects the reputation of the company.
Contributing to the prestige of the Group, avoiding criticizing it,
starting or supporting any boycott, negative campaign orcommunication or any other action that harms the company,
regardless of its nature or the means used, including the mass
media and social networks.
FREEDOM OF EXPRESSIONFeeling the right to express ourconcerns and points of view
through the consultation
channels established to ensure
the freedom of expression.
Reporting any situation that
violates the fundamental
principles and rights of the staffand/or the environment in the
companies to which this code
applies.
MAINSTREAMING SUSTAINABILITYIntegrating social, environmental and economic issues into the actions and decisions adopted,
taking into account the interests of all parties involved at all times.
12GRUPO ANTOLIN
Code of Ethics and Conduct
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ABSENCE OF A CONFLICT OF INTERESTChecking the available information, including financial, on its potential business partners andsuppliers before establishing business relations with third parties, in order to establish their
respectability and the legitimacy of their activities.
Not providing services to competing companies or those in the same sector or undertaking or
carrying out business or commercial activities similar to those carried out by Grupo Antolin, which
interfere with their obligations and interests towards the Group, cause it harm or imply preferentialtreatment as a result of the existing relationship that goes beyond the professional area.
Not forming part of the Board of Directors of other companies or investing directly or indirectly in
the capital of a customer, supplier or other public or private entity of any kind that has relationswith the Group, either in the parent company or its subsidiaries; nor taking advantage of their
belonging to the Group in order to benefit from personal purchases made on the same
beneficial terms agreed for Grupo Antolin, unless the contract between these individuals and
Grupo Antolin expressly authorizes this and/or it respecting the company's procedures in this
regard.
PROHIBITING CONTRIBUTIONS ON
BEHALF OF THE GROUPNot offering or accepting any contributions,
payments or any other valuable item on behalfof Grupo Antolin in relation to political
candidates, government officials, customers,
suppliers or any other person or organization,
with the intention of influencing them or
obtaining an unfair advantage for the
company or on its behalf for its own benefit.
Always precisely documenting, in the systemsand records provided by the company, any
payment, expense or contribution made on
the behalf of, by and/or for Grupo Antolin,
including expenses and any gift or reward,
following the procedures defined by the
organization in this regard.
CULTURE OF COLLABORATION AND
MANAGEMENT Creating a model for conduct in
accordance with the ethical principles
contained in this Code and encouraging apositive climate for the transparent
exchange of ideas, mutual support and
shared information in an open and
reciprocal way with sufficient thoroughness
that allows us to act and decide.
Offering leadership and guidance that
demonstrates to others that respecting the
Code is a fundamental element of their workthrough the continuous communication,
notification and explanation of the
obligations and authorizations relevant to
their area of work.
Relying on the members of the team,
agreeing on clear, measurable and realistic
objectives, giving them their own
responsibility and significant room for
maneuver, recognizing a job well done and
especially valuing the most importantachievements, without ceasing to monitor
compliance with this code and the
standards existing within their area of
responsibility.
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14GRUPO ANTOLIN
Code of Ethics and Conduct
5Whistleblowing
T h e T r a n s p a r e n c y C h a n n e l
CORPORATE
CULTUREOUR COMMITMENT THE TEAM
WHISTLEBLOWING
CHANNEL
ACTION
PROTOCOLCODE OF ETHICS
AND CONDUCTTHE ETHICS
COMMITTEE
It is the RESPONSIBILITY of
each and every person
who forms part of Grupo
Antolin to apply the
content of this Code of
Ethics and Conduct
appropriately, helping
others to do the same.
All managers must ensure
that the employees in
their area of responsibility
are aware of it and
comply with the
commitments and
principles included in this
Code.
We would like to
encourage you to
express your concerns
and report, in good
faith, with impartiality
and respect, any
behavior or situations
contrary to the
commitments outlined
here.
Taking Grupo Antolin as a whole as an international business, when we are
faced with situations relating to business conduct on international trips, we
must consider the policies in place in the country of destination and those of
the country of origin so that we can take the right decisions. However, in the
event of any doubt, each professional must examine their own conscience to
determine the best way to deal with the situation, seeking help from
colleagues, managers and, where necessary, the company itself, referring
the issue to the Ethics Committee [email protected]
MANAGING TRANSPARENCY
15GRUPO ANTOLIN
Code of Ethics and Conduct
5Whistleblowing
T h e T r a n s p a r e n c y C h a n n e l
I What is it? The Transparency or Whistleblowing Channel at Grupo Antolin is the official
channel made available to all employees of Grupo Antolin by the company, also
accessible to people outside the organization, used to send any complaints and/or reports
under the scope of this Ethical Code considered necessary, including those of an
economic, financial and/or accounting nature, that may arise in the running of the
business.
The Transparency Channel is also the means to facilitate the secure formulation of any
query about the scope and applicability of the Group's model for organizing and
managing criminal risks, as well as for notifying or reporting situations of breach or risk in
relation to the conducts regulated by it.
I What is considered appropriate to report? In general, any violation, omission or
legal or moral attitude that goes against any of the values, commitments or principles
contained in the text of the Grupo Antolin Code of Ethics and Conduct, the model for
organizing and managing criminal risks or any company policy and the applicable
legislation should be reported.
Any type of threat or reprisal against anyone who in good faith has reported any possible
infringements or has requested clarification about the application of anything set out in the
previous paragraph is considered an infringement.
Additionally, also considered as an infringement will be the behavior of anyone who in bad
faith accuses other people of violations, conduct or omissions and/or misuses this channel
without any grounds for that, with the sole purpose of personally or professionally harming a
person.
I What is the procedure to follow? The first person to turn to with any queries or
doubts regarding compliance or otherwise with this code is your immediate line manager
or their immediate line manager, the local Department of Human Resources and, where
appropriate, the company's Committee, if applicable.
If the query or doubt regarding the reported event is not dealt with, could compromise the
responsibility of the person reporting it, seriously affects the physical or moral integrity of this
or another person and/or poses a significant risk to the activity or reputation of the
company, the Transparency Channel must be used as the official channel for reporting
these types of situations.
I How can I access it? Reports may be made in writing either through the company's
website for those with access to a computer or through the following PO Box:
https://extranet.grupoantolin.com/Web/GA.CanalTransparencia.Web/Default.aspx?Lang=
EN
Grupo Antolin
PO Box 2069
09007 Burgos (Spain).
I Is it anonymous? Anyone making a report must identify themselves, providing all the
necessary details along with the details of the person being reported. However, this is while
at all times guaranteeing the confidentiality of the identity of the complainant and the
information provided, preventing any other person from accessing any details that could
identify them. Anonymous complaints will not be accepted.
CORPORATE
CULTUREOUR COMMITMENT THE TEAM
WHISTLEBLOWING
CHANNELACTION
PROTOCOLCODE OF ETHICS
AND CONDUCT
THE ETHICS
COMMITTEE
16GRUPO ANTOLIN
Code of Ethics and Conduct
5Whistleblowing
T h e T r a n s p a r e n c y C h a n n e l
I What guarantee of protection do I have? Grupo Antolin is committed to supporting a
culture in which any legal or ethical concerns may be expressed without fear of reprisal. The
company's policy prohibits any form of reprisal, threat or disciplinary and/or discriminatory
measures against people who, in good faith, use this channel to report omissions, conduct or
behavior that is suspected to be contrary to the current legislation or the principles and
policies of the company, including this code.
I Who can see my request? This information is only received by the Corporate
Department for Corporate Social Responsibility who will be responsible, in view of the details or
information provided, for deciding whether to launch the appropriate procedure for each
type of request.
The documentation is regularly submitted to the Ethics Committee and, where appropriate,
the Audit Committee. This determines whether a complaint is founded and, if it is, the
complaint is dealt with following the defined process which will be adapted, where
appropriate, to the specific case and country.
Any exchange or transfer of details and information coming from the Transparency Channel
between subsidiaries and/or investees of Grupo Antolin considered necessary for the correct
analysis and resolution of the reported situation will require the consent and approval of the
interested parties from the moment that their request is made official through the
Transparency Channel.
The start of proceedings will be communicated to the person being reported as soon as
possible, and in any case within the period of three months from the making of the complaint,
always respecting the principle of confidentiality for the Transparency Channel mentioned
above.
The decision will be communicated exclusively to the interested parties and will be made
following the instructions contained in the Internal Regulation that governs the Committee,
representing the position of the company with regards to the conflict.
I How long does it take to resolve a complaint? There is no estimated time as each
request is dealt with personally and varies depending on the reported situation, information
available, people involved, languages and any other circumstance involved that affect its
resolution.
I For how long is the data saved? The personal data collected as a result of the process
for making a complaint via the Transparency Channel will be deleted as soon as all the
internal audit and/or legal measures resulting from the investigation carried out and
necessary for its resolution have been performed.
The Transparency or Whistleblowing Channel is corporate in nature.
Please consult the local appendix, where relevant, for any possible amendment
of the foregoing depending on the country in order to adapt it to local
legislative requirements.
CORPORATE
CULTUREOUR COMMITMENT THE TEAM
WHISTLEBLOWING
CHANNELCODE OF ETHICS
AND CONDUCT
THE ETHICS
COMMITTEEACTION
PROTOCOL
17GRUPO ANTOLIN
Code of Ethics and Conduct
6guidance, support and guaranteeT h e E t h i c s C o m m i t t e e
Grupo Antolin has created an Ethics
Committee that is entrusted with the task of
ensuring the creation, updating and fulfilment
of the Code of Ethics and Conduct, with the
power to resolve ethics-related conflicts that
arise in the company.
CORPORATE
CULTUREOUR COMMITMENT THE TEAM
WHISTLEBLOWING
CHANNEL
CODE OF ETHICS
AND CONDUCTTHE ETHICS
COMMITTEE
WHAT IS IT?
The Grupo Antolin Ethics Committee is a
collegiate deliberation body, of a
consultative and interdisciplinary nature,
created to analyze and provide advice on
questions of an ethical nature which may
arise in the working environment, with the
ultimate aim of contributing to increasing
respect for and compliance with the
content of the Grupo Antolin Code of
Ethics and Conduct.
The Ethics Committee is a body with
autonomous initiative and control powers
and the responsibility to develop, monitor
and apply the Grupo Antolin model for
organizing and managing criminal risks.
OBJECTIVES
1.- To assess the level of alignment
between the company's values and its
social and cultural reality.
2.- To develop and update the values
and this Code on the basis of the needs of
the environment.
3.- To monitor appropriate compliance
with the ethical principles and values
within Grupo Antolin.
4.- To develop, monitor and apply the
model for organizing and managing
criminal risks.
5.- To serve as a guide and support for the
company's professionals.
6.- To identify, analyze and respond to
infringement situations.
The Committee also undertakes to
regularly report to the Management of
Grupo Antolin about the number and
seriousness of the incidents detected, the
number of interventions by the
Committee and any corrective actions
undertaken, as well as the degree of
awareness of the Ethical Code amongthe professionals of Grupo Antolin.
WHO IS IT?
The Committee is formed by a minimum of
3 and a maximum of 7 professionals who
are internal or external to the company,
experts in Corporate Responsibility and,
labor, judicial and legal issues. Their
appointment and dismissal is the
responsibility of the "Appointments and
Remuneration Committee".
WHEN DOES IT ACT?
The Grupo Antolin Ethics Committee
analyzes possible ethical conflicts arising in
relation to employees in any of the Grupo
Antolin companies or in relation to people
external to the organization who directly or
indirectly affect the company, reported
through the Transparency Channel at the
request of the Corporate Social
Responsibility team.
TO WHOM DOES IT REPORT?
The Grupo Antolin Ethics Committee carries
out a dual reporting of its activity: to the Chief
Executive Officer -CEO- of the company and
to the Audit Committee.
Contact: [email protected]
…
Board of Directors
Audit
CommitteeAppointments
and
Remuneration
Committee Ethics
Committe
eCEO
… HR
CSR
ACTION
PROTOCOL
Alleged situation subject to a complaint
Complaint
Website
SPANISHhttps://extranet.grupoantolin.com/Web/GA.Canal
Transparencia.Web/Default.aspx?Lang=ES
ENGLISHhttps://extranet.grupoantolin.com/Web/GA.Canal
Transparencia.Web/Default.aspx?Lang=EN
PO Box 2069
09007 BURGOS (SPAIN)
Receipt of complaint by CSR
Transferred to the Ethics Committee
Preliminary investigation
Filing of the proceedings Continuation of the proceedings
Internal Investigation by the Ethics or
Audit Committee for members of the Boards of Directors
Preparation of final report
Yes it is confirmed No it is not confirmed
Adoption of appropriate
measures for the
Accused Party
consistent with the application
of the current legislation for
this type of conduct
if necessary, or the model for
organizing and managing
criminal risks when applicable.
Adoption of measures to
improve the working
environment if necessary
Monitoring of the reported
situation until the risk
disappears
If the report was intended to
damage someone:
Adoption of appropriate
measures for the
Accusing Partyconsistent with the
application of the current
legislation for this type of
conduct
if necessary
Filing of the proceedings
Monitoring of the reported
situation until the risk
disappears
Filing of the proceedings
18GRUPO ANTOLIN
Code of Ethics and Conduct
7in the event of breaches or misconduct
A c t i o n p r o t o c o l
CORPORATE
CULTUREOUR COMMITMENT THE TEAM
WHISTLEBLOWING
CHANNEL
ACTION
PROTOCOLCODE OF ETHICS
AND CONDUCT
THE ETHICS
COMMITTEE
Possibility of an
ex-officio
initiation by the
Ethics
Committee if it
detects
misconduct or a
breach
19
I have read, understood and am committed to
respecting the spirit and letter of the Grupo Antolin
Code of Ethics and Conduct
SignatureCORPORATE
CULTUREOUR COMMITMENT THE TEAM
WHISTLEBLOWING
CHANNEL
ACTION
PROTOCOLCODE OF ETHICS
AND CONDUCT
THE ETHICS
COMMITTEE
GRUPO ANTOLIN
Code of Ethics and Conduct
A c c e p t a n c e
8
A b o u t t h i s C o d e
20
Glossary of Terms
A
APPOINTMENTS AND
REMUNERATION
COMMITTEE
[Committee appointed by the Board of Directors chaired by an independent
director, responsible, among other broader functions, for appointing the
members of the Ethics Committee.]
AUDIT COMMITTEE
[Committee appointed by the Board of Directors chaired by an independent
director, responsible for "monitoring" internal control, risk management, the
internal control of financial information system, as well as corporate governance
and the possible criminal liability of the legal entities; also ensuring compliance
with the "codes of ethics and conduct" (avoiding conflicts of interest) and to
which the Ethics Committee reports in our Group.]
B
BRIBERY[Offering or receiving any gift, loan, fee, reward or other advantage in relation
to any person in order to obtain something from them, generally illegal or
immoral.]
C
CHILD LABOR
[Any work or service performed under the general minimum age for admission
to work or employment, which is 15 years (13 for light work) and 18 years for
dangerous work (16 under certain strict conditions). There exists the option to first
establish the general minimum age at 14 years (12 for light work) when the
economy and educational services are insufficiently developed. ]
CODE [Set of rules or order on any matter.]
CODE of
BUSINESS ETHICS
[Document voluntarily written by a company which sets out a series of principles
and behaviors that must be followed and observed by the entire workforce of a
company or business.]
COLLECTIVE
BARGAINING
[Voluntary process through which employers and employees freely discuss and
negotiate their relationship, in particular the terms of employment and working
conditions. It involves the employers themselves or their organizations, and the
unions or, in their absence, representatives freely appointed by the employees.]
COMMITMENT[Declaration of principles, a promise or keeping to your word, formalized by
means of an agreement, promise or contract.]
COMPLICITY
[Involvement in any case of abuse, situation or activity that is illicit or contrary to
the ethical principles of conduct which the staff, companies, governments or
other types of entities are undertaking.]
GRUPO ANTOLIN
Code of Ethics and Conduct
.
21
Glossary of TermsA b o u t t h i s C o d e
CCONDUCT [Set of actions with which a human being responds to a situation.]
CONFIDENTIALITY[Ownership of the information, which ensures that only authorized staff can
access this information.]
CONFLICT of INTERESTS
Institutional. [Arises when, as a result of other activities or relationships, an
organization cannot provide impartial services, when the objectivity of the
organization to carry out the work corresponding to the mandate is or may
be affected, or the organization has an unfair competitive advantage.]
Personal. [A situation in which the private interests of a person -such as
external professional relations or personal financial assets- interfere or may
be understood to interfere with the carrying out of their official or
professional duties.]
CORRUPTION[Abuse or misuse of the entrusted power, duties and/or resources for their
own benefit, be it financial or otherwise.]
D
DISCRIMINATION
[Any distinction, exclusion or preference that causes rejection or inequality in
opportunity or treatment as a result of race, color, sex, religion, political
opinions, nationality of origin, social background or any other personal
and/or social circumstance.
Indirect. Situation in which an apparently neutral provision, standard or
practice places some people at a particular disadvantage compared to
others, unless that provision, standard or practice can be objectively
justified as having a legitimate purpose and that the means to achieve this
purpose are necessary and appropriate.]
DIVERSITY
[Variety, dissimilarity, difference, distinction between large numbers of
different people, animals or things.
Cultural diversity. Reflects the multiplicity, coexistence and interaction of the
different cultures in the world and that therefore form part of the common
heritage of mankind in certain areas.]
E
ENVIRONMENT
[Surroundings formed by natural and artificial elements that are interrelated
and modified by human or natural action; in which the life of living beings is
developed and allows their interaction, determines the way of life of society
and includes the natural, social and cultural values that exist in a given
place and time.]
ETHICS [Set of moral rules that govern human behavior.]
ETHICS COMMITTEE
[Collegiate deliberation body, of a consultative and interdisciplinary nature,
created to analyze and provide advice on questions of an ethical nature
which may arise in the working environment, with the ultimate aim of
contributing to increasing respect for and compliance with the content of
the Grupo Antolin Code of Ethics and Conduct.]
GRUPO ANTOLIN
Code of Ethics and Conduct
.
22
Glossary of TermsA b o u t t h i s C o d e
E
EQUALITY[Universal legal principle that recognizes that all people are equal in rights
and opportunities in the eyes of the law, which must take into account the
differences between individuals and groups.]
EXTORTION[Act of asking or enticing another to commit bribery, accompanying this
demand with threats that endanger the personal integrity or lives of the
people involved.]
F
FORCED LABOR [Any work or service obtained from a person under the threat of any penalty
and for which that individual has not offered themselves voluntarily.]
FREEDOM OF
ASSOCIATION
[Respect for the right of all employers and workers to freely and voluntarily
create groups in order to promote and defend their professional interests,
and to join these groups.]
FREEDOM OF
EXPRESSION[Fundamental right to freely speak, express and share one's own thoughts.]
G
GLOBAL COMPACT
[International initiative that promotes the implementation of 10 universally
accepted principles to promote corporate social responsibility (CSR) in the
areas of Human Rights, Labor Standards, the Environment and the Fight
against Corruption in the business activities and strategies of companies.]
H
HUMAN RIGHTS[Rights inherent to all human beings, irrespective of nationality, place of
residence, sex, national or ethnic origin, color, religion, language, or any
other condition. These rights are interrelated, interdependent and indivisible.]
I
ILO
[International Labor Organization. Tripartite United Nations organization
founded in 1919 dedicated to promoting labor rights, enhancing decent
employment opportunities, improving social protection and strengthening
the dialog in addressing work- related issues.]
IMPACT [Any type of contingency or event that may cause or result in damage.]
INVESTEE COMPANY [Entity in which another company with 50% or less of the share capital
participates but does not exercise control. ]
MMODEL FOR
ORGANIZING AND
MANAGING CRIMINAL
RISKS
[Structured and organic system of procedures and control activities, which
should be carried out in a preventative manner, aimed at preventing and/or
detecting the carrying out of different types of crimes that may generate
criminal liability for the legal entity.]
MONEY
LAUNDERING
[Set of mechanisms or procedures designed to give the appearance of
legitimacy or legality to goods or assets that are the proceeds of crime.]
GRUPO ANTOLIN
Code of Ethics and Conduct
.
23
Glossary of TermsA b o u t t h i s C o d e
NN+1 [The direct manager of the employee.]
N+2 [The superior of the direct manager or N+1.]
O
OECD
[Founded in 1961, the Organization for Economic Co-operation and
Development (OECD) brings together 34 member countries and its mission is
to promote policies that improve the economic and social welfare of people
around the world.]
P
PATRONAGE
[Support in monetary form or in kind given to the community for carrying out
various projects of a social, cultural and scientific developmental nature, as
well as for environmental preservation, which operate more qualitatively and
over the long-term to improve the image of the company that is doing the
sponsoring.]
PREVENTION[Adoption of measures, even before having completed scientifically proven
tests, which help to prevent a delay in the application of these measures
being able to eventually cause injury or damage.]
R
REPUTATION[Strategic asset based on the favorable perception of the company by the
different stakeholders.]
RISK [Probability of an adverse event, impact or consequence occurring.]
S
SOCIAL ACTION
[Conduct or practice of the person or company who has influence over the
conduct or practice of other individuals, companies or society in order to
meet basic needs that, for different reasons, a group of the population
cannot meet and that contributes to the development and progress of
society.]
SPONSORSHIP
[Form of communication that enables a brand to be directly linked to an
event that is attractive to a certain audience, in order to increase the
recognition and image of the company and/or its products in the short-
term.]
GRUPO ANTOLIN
Code of Ethics and Conduct
.
24
Glossary of TermsA b o u t t h i s C o d e
S
STAKEHOLDERS
[Entities or individuals that may be significantly affected by the activities,
products and/or services of Grupo Antolin; and whose actions may affect,
within reason, the ability of Grupo Antolin to successfully develop its strategies
and achieve its objectives.
Six main groups: Shareholders, Customers, Employees, Investors, Suppliers and
Society.]
SUBSIDIARY COMPANY[Entity controlled directly or indirectly by a parent company, either because
the latter holds more than 50% of the share capital or voting rights, or
because it effectively controls its management.]
SUSTAINABILITY[Sustainable quality, especially referring to the characteristics of
development that meet the needs of the present without compromising the
needs of future generations.]
T
TRANSPARENCY
CHANNEL
[Official channel made available to all employees of Grupo Antolin by the
organization, also accessible to people outside the company, used to send
any complaints and/or reports under the scope of this Ethical Code that are
considered necessary, including those of an economic, financial and/or
accounting nature, that may arise in the running of the business.]
U
UNIVERSAL
DECLARATION OF
HUMAN RIGHTS
[Common ideal through which all people and nations must strive so that,
both the individuals and the institutions constantly being inspired by it,
promote, through teaching and education, respect for these rights and
freedoms and ensure, through national and international progressive
measures, their universal and effective recognition and application, in terms
of both the populations of the Member States and those of the territories
placed under their jurisdiction]
GRUPO ANTOLIN
Code of Ethics and Conduct
.
Page Policy. Commitment. WHERE CAN I FIND IT?
Page 5 Mission, Vision and Values http://sharepoint.grupoantolin.com/SiteDirectory/HR/Cor
porateDevelopment/corpculture/default.aspx
Page 6 The Code of Ethics and
Conduct
http://intranet.grupoantolin.com/sites/apps/EC
http://www.grupoantolin.com/en/people
Page 6
Page 7Grupo Antolin Policies and
Guidelines
http://intranetga/Documentacion/Procedimientos/Index.
asp?tdoc=Proc&openMGG=yes&op=consultar&tipo=24
http://sharepoint.grupoantolin.com/Pages/Default.aspx
http://sharepoint.grupoantolin.com/sites/dci/how_to/def
ault.aspx
Page 6
Page 8United Nations Global
Compact Principleshttps://www.unglobalcompact.org/what-is-
gc/mission/principles
Page 6
Page 8Human Rights:
International Human Rights
Charter
http://www.un.org/en/universal-declaration-human-
rights/index.html
http://www.un.org/es/rights/overview/charter-hr.shtml
Page 6
Page 8Human Rights:
Guiding Principles on
Business and Human Rights
http://business-humanrights.org/en/un-guiding-principles
Page 6
Page 8Labor Standards:
Tripartite Declaration of the
ILO
http://www.ilo.org/empent/Publications/WCMS_094386/l
ang--en/index.htm
Page 6 Labor Standards:
Organization for Economic
Co-operation and
Development
http://www.oecd.org/
Page 8 Commitment:
CSR policy
http://intranetga/Archivos/Procedimientos//IN/Processes
//I-P02-K%20CSR%20POLICY.doc
Page 8
Page
12
The Environment:
Environmental
Management Model
http://intranetga/Redirect.asp?Destino=/documentacion
/medioambiente/Default.asp?Carpeta=&IdLanguage=IN
Page 8
Page
11
Page
12
Data Protection:
Law on the Protection of
Personal Data (LOPD)http://sharepoint.grupoantolin.com/SiteDirectory/LOPD/d
efault.aspx
Page 8
Page
11
Occupational Health and
Safety: Occupational
Health and Safety Model
http://intranetga/Documentacion/Prevencion/Default.as
p25GRUPO ANTOLIN
Code of Ethics and Conduct
This list contains the corporate and international principles, policies and guidelines on which
the different commitments outlined throughout the Grupo Antolin Code of Ethics and
Conduct are based and implemented. Available on the website and/or Intranet of the
company, they must be read and interpreted in accordance with the current international,
regional and local legislation and behavior standards.
Internal legal referencesA b o u t t h i s C o d e
.
Page Policy. Commitment. WHERE CAN I FIND IT?
Page 8 Labor Standards:
Wage Policy
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=3
86
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=6
10
Page 8 Occupational Health and
Safety: OHSAS 18001http://www.aenor.es/aenor/normas/ediciones/fichae.as
p?codigo=4032
Page 8
Page
11
Diversity and Equality:
Principle of Diversity and
Equality
http://sharepoint.grupoantolin.com/SiteDirectory/Respon
sabilidadCorporativa/Diversidad/default.aspx
Page 8
Page
12
Safety of Information:
Telematic Code
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=8
35
Page 9 Economic sustainability.
Risk Management
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=1
148
Page 9 Anti-corruption:
Strategy Management
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=1
082
Page 9 Anti-corruption:
Purchase Management
http://intranetga.grupoantolin.com/Redirect.asp?Destino=/Documentacion/Procedimientos/ViewDoc.asp?doc=895
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=5
95
Page 9 Anti-corruption:
Financial controls:
. Investments
. Economic Control of
Projects
. Transfer Pricing
. Closure and
Consolidation of Financial
Statements
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=3
97
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=8
37
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=5
37
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=1
135
26GRUPO ANTOLIN
Code of Ethics and Conduct
Internal legal referencesA b o u t t h i s C o d e
.
Page Policy. Commitment. WHERE CAN I FIND IT?
Page 9 Information transparency:
Exterior informationhttp://www.grupoantolin.com/es/sala-de-prensa-inicio
Page 9 Information transparency:
Reconciliation of banking
and financial accounts
Cash Count
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=1
216
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=1
217
Page 9 Innovation:
Innovation Management
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=8
74
Page
11Integrity:
Management of travel and
representation expenses
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=3
74
Page
11Responsible Mobility:
European Mobility Charter
http://www.erscharter.eu/es/node
Page
12 Knowledge Management:
Knowledge Management
Model
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=1
210
Page
11Freedom of Expression:
Motivation and working
environment
http://intranetga.grupoantolin.com/Documentacion/Pro
cedimientos/ViewDoc.asp?doc=864
Page
12Use of Resources:
Resource Management
http://intranetga.grupoantolin.com/Redirect.asp?Destino
=/Documentacion/Procedimientos/ViewDoc.asp?doc=8
68
Page
12
Page
15
Freedom of Expression:
Transparency Channel
https://extranet.grupoantolin.com/Web/GA.CanalTransparencia.Web/Default.aspx?Lang=EN
Page
12 Image and Reputation:
Media Protocol
http://sharepoint.grupoantolin.com/sites/RIMK/ComProto
col/Forms/AllItems.aspx
Page
12 Quality in Management:
Management Model
http://intranetga/Documentacion/Procedimientos/Index.
asp
Page
13Collaboration and
Management:
Performance Management
System
http://intranetga/Aplicaciones/SGDv2/SGDIndex.asp
27GRUPO ANTOLIN
Code of Ethics and Conduct
Internal legal referencesA b o u t t h i s C o d e
.
GRUPO ANTOLIN CODE OF ETHICS AND CONDUCT
The Code
I A living document.
I Approved by the Ethics Committee.
I Endorsed by the Board of Directors.
I A single code is valid throughout the entire
scope of Grupo Antolin.
I It applies to all employees linked to Grupo
Antolin, to all subsidiary companies in which it is
the majority shareholder and in those in which it
has management control, as well as to its supply
chain.
I Its compliance is a condition for forming part of
the team of professionals at Grupo
Antolin.
I It may not be unilaterally amended as this is
the exclusive responsibility of the Ethics
Committee.
I It is not a set of internal rules, nor does it
replace any collective agreements or
national legislation.
I It must be read and interpreted jointly with
Grupo Antolin's Policies, Guidelines and
Management Model.
I Available in 27 languages on the company's
Intranet and in Spanish and English on the
Group's website.
Objective I To ensure ethical and responsible behavior when running our business.
Human Rights
Compliance with the legislation
Labor Standards
Data protection
Diversity and equality
Economic sustainability
Anti-corruption practices
Sustainable contribution
Information transparency
Innovation
The absence of funding of the
political, governmental and
terrorism spheres
Collaboration and participation
of Grupo Antolin to:The Commitment
Integrity Respect Confidentiality Independence Well-being, health and safety Responsible
mobility Knowledge management Responsible environmental behavior Responsible use of
resources Quality in management Image and reputation Freedom of expression Privacy of
information Mainstreaming sustainability Prohibiting contributions on behalf of the group
Absence of a conflict of interests Culture of collaboration and management
Model of conduct
A b o u t
,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,00000000000
Grupo Antolin –
Code of Ethics and ConductCtra. Madrid-Irún, km. 244.8
09007 BURGOS – SPAIN
+34 947 47 77 00
+34 947 48 49 19
www.grupoantolin.com
Always rely on your sense of responsibility
and good judgement and/or,
Talk to your direct line manger, their line
manager or the Management or;
To the Human Resources Department
and, where relevant, the Works Council if
appropriate or;
To the Ethics Committee, if deemed
necessary.
If your query or doubt does not obtain a
response, you may use the Transparency
Channel.
in the event of not receiving a
response or
if the event may compromise the
responsibility of the person who reported it or,
severely affects the physical or moral
integrity of this or another person
and/or,
poses a significant risk to the activity
or reputation of the company.
Is entrusted with the task of ensuring the creation, updating and fulfilment of the Code of
Ethics and Conduct with the power to resolve ethics-related conflicts that arise in the
company.
Develops, monitors and applies the Grupo Antolin model for organizing and managing
criminal risks
Formed by a minimum of 3 and a maximum of 7 professionals that are internal and
external to the company.
Carries out dual reporting of its activity: to the CEO of the company and to the Audit
Committee
CONTENT QUERIES Correct business conductText interpretation
It is the RESPONSIBILITY of everyone forming part of Grupo Antolin to apply the
content of this Code of Ethics and Conduct appropriately, helping others to do the
same.
The Ethics Committee
N+1
N+2
HR and/or
Works Council if necessary
WHISTLEBLOWING CHANNEL
1
COMPLAINTS or REPORTSBehavior contrary to the GA values, commitments and/or principles
23
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