ANTI-CORRUPTION POLICY

 

  1. Target

In accordance with our Code of Conduct and with the purpose of preventing and mitigating all fraud activities that may affect our operations, our business partners and other stakeholders related to our organisation, at Tempel we have established our Anti-Corruption Policy, defining guidelines to ensure regulatory compliance in terms of fraud prevention, mitigating and preventing all corruption actions that violate current laws or contravene our corporate principles.

 

  1. Regulatory compliance

We are aware of and abide without limitation by the applicable laws, statutes, regulations and codes in force regarding anti-corruption, anti-money laundering and anti-fraud, such as:

 

  • Circular 1/2016, on the criminal liability of legal persons in accordance with the reform of the criminal code carried out by Organic Law 1/2015.
  • Organic Law 1/2015 of 30 March 2015, which amends Organic Law 10/1995 of 23 November 1995 on the Criminal Code.
  • Organic Law 5/2010, of 22 June, which amends Organic Law 10/1995, of 23 November, of the Criminal Code Circular 1/2016, on the criminal liability of legal persons in accordance with the reform of the Criminal Code carried out by Organic Law 1/2015.

 

It is our commitment as an organisation to keep up to date with the laws that regulate our activity and that establish general compliance guidelines in all areas, including the prevention of fraud and corruption.

 

  1. Detecting cases of corruption
  • AuditsAs internal measures to detect corruption, we regularly carry out internal audits to monitor different areas of our organisation and our activities.

 

Furthermore, our customers and suppliers have the right to audit the fulfilment of our contractual commitments, obligations and commitments arising from business relationships, with our prior consent and under existing confidentiality agreements.

  • Supplier evaluation and supplier relationsWe conduct annual assessments of our suppliers, ensuring that they meet quality standards. We sign agreements and codes of conduct with our business partners, encouraging ethical behaviour throughout our value chain.
  • Channels of complaintIn the event that our collaborators or other stakeholders wish to report any action that they consider to be in breach of any regulation or to be considered unethical behaviour, Tempel has an e-mail address where they can report this type of activity: buzon.etico@tempelgroup.com.

 

  1. Prohibition of remuneration and bribes

Tempel, S.A., nor any of its subsidiaries or persons that control them, their partners, directors, managers and employees, shall offer, promise or deliver any payment or retribution that may influence the will or objectivity of their business partners and other entities related to their commercial activity.

Similarly, none of our employees, officers or directors may receive payments or valuables from customers and suppliers. The acceptance or giving of gifts and invitations is subject to the following conditions:

 

  • Only gifts that fall within the scope of social customs and practices shall be considered as such. These gifts may not exceed the amount of 50 euros, with a limit of 150 euros being set for the value of gifts that may be accepted during the period of one year from the same natural or legal person.
  • It is expressly forbidden to give gifts consisting of cash or gift cards or cheques that can be used as cash, regardless of their form, duration, rules of use, whether or not they are within the previously established amount.
  • Regular gifts of a symbolic and promotional nature of little economic value, such as pens, diaries, notebooks, etc., may be accepted. Invitations to conferences, courses, meals, professional meetings, as long as they do not exceed the limits considered reasonable in social customs, according to the hierarchical level of the employee or manager receiving the invitation.

 

In the event that any member of the organisation receives any undue remuneration, this must be reported immediately to his or her superior, who will arrange for its return and make the respective clarification with the supplier, client or interested party.

 

  1. Others commitments
  • Not to influence the will or objectivity of persons outside the company to obtain any benefit or advantage through the use of unethical practices and/or contrary to applicable law.
  • Not to fund or otherwise support, directly or indirectly, any political party, its representatives or candidates.
  • Do not use donations to cover up improper payments.
  • To faithfully and properly reflect all the company's actions, operations and transactions in the company's books and records.
  • Report in a timely manner through the established reporting channels any act or suspicion of wrongdoing or suspected wrongdoing that could be considered fraudulent.
  • Build long-term relationships with reliable business partners and make it impossible to do business with individuals or legal entities with proven unethical or criminal behaviour.
  • Apply our corporate principle of transparency to all activities.

 

  1. Disciplinary measures

Employees who violate the provisions set out in this policy shall be subject to the appropriate disciplinary measures, including, where applicable, termination of contract, as well as other possible legal actions and/or sanctions. Tempel also reserves the right to take any measures it deems appropriate against business partners who violate this policy.

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