Fight against
corruption & bribery

Through the Anti-Corruption Sub-Policy, also approved in 2022, the Organization reaffirms and reinforces the requirement for standards of honesty, integrity and transparency as essential principles of action in the development of its activities, all with the commitment to the most rigorous compliance with the principle of "zero tolerance" against any practice that could be qualified as conduct constituting corruption or bribery, understood in the broadest sense.

This "zero tolerance" principle is reiterated in virtually all compliance documents, with declarations of principle in the Code of Ethics and in the Code of Conduct for Suppliers, as well as in other SGEC documents, in which the Organization categorically rejects any type of advantage and/or benefit that is derived from or requires the violation of applicable regulations. Specifically, and with a direct and specific treatment, the Crime Prevention Manual clearly establishes the prohibition of obtaining any advantage for the Organization if this would require committing any case of corruption and/or bribery, providing for prevention, detection and response measures.

The Organization reaffirms and reinforces the requirement for standards of honesty, integrity and transparency as essential principles.

For many years, Alestis has included specific contractual clauses in its contracts with customers and suppliers that provide for termination of the contract in the event that corruption or bribery is detected.

In addition, contributions to foundations and/or non-profit organizations, as well as any donation or contribution, are governed by the Sponsorship and Donations Policy, which aims to ensure a consistent and transparent approach to these actions, as well as compliance with the law and ethical principles. This document states that Alestis will not make donations or sponsorships to political parties. Any action involving donations or sponsorship must be approved by the Communication, Ethics and Compliance, Legal and General Management departments.

For many years, Alestis has included specific contractual clauses in its contracts with customers and suppliers that provide for termination of the contract in the event that corruption or bribery is detected.

This diligence against possible cases of corruption and/or bribery is also applied within the organization with the Gifts and Entertainment Procedure, which requires all employees and managers to report any gift or entertainment received from a third party and to obtain express authorization if the value exceeds €50 or €100, respectively. In addition, there is a procedure for the proper management of conflicts of interest applicable to all members of the organization.  For their part, all proxies are subject to the Proxy Regulation, under which the proxy expressly assumes obligations related to the exercise of their powers, including specific anti-corruption and bribery points.

With regard to the fight against money laundering and terrorist financing, the Alestis Code and the Crime Prevention Manual itself reject the use or possession of assets derived from criminal activity. If a member of Alestis has doubts about the origin of a certain asset, he/she is obliged to inform the Ethics and Compliance Department.

The aforementioned sub-policies are in turn developed and/or supplemented by procedures and guides prepared by the Compliance function in order to facilitate knowledge of and compliance with their provisions throughout the organization. This regulatory function of the E&C area is carried out under a risk approach, which makes it possible to identify and prioritize those areas in which the aforementioned regulatory development is more urgent. In this regard, the following regulations should be mentioned: On-site Services Outsourcing Guide, Donations and Sponsorship Guide, Gifts and Entertainment Guide, Conflict of Interest Management Procedure and Guide, Training and Seminars Guide, Export Compliance Procedures, Personal Data Protection Procedures, E&C Channel and Communications Management Procedures, etc.

The policies, sub-policies, procedures and guides serve not only as a means to facilitate understanding and application of the rules, but also as preventive controls of particular relevance to the prevention of criminal risks. Their updating and adaptation is therefore essential to ensure their effectiveness. In the course of the 2022 financial year, an intensive review work will be carried out, which will culminate in 2023.

The E&C Committee and the Board of Directors are regularly informed of the progress made in the development of the E&C regulations, as well as of the ordinary management activities carried out during the year, the training provided and the strategic objectives set.

All Alestis employees have the right and the duty to report conduct that may involve non-compliance.

In Brazil, anti-corruption, anti-bribery and anti-money laundering policies are included in E&C training and in SE 8503 (Risk Management).

In order to contribute to an adequate control of compliance with applicable regulations, the E&C department has been provided with tools that allow all members of the organization to report any event that may constitute a non-compliance.

All members of Alestis, regardless of their hierarchical position or geographical location, have the right and the duty to report in good faith any conduct in the course of their activities that may constitute a non-compliance, as well as to inform the E&C department of any ethical and compliance issues or dilemmas that may arise in the course of their duties.

To this end, Alestis provides all employees and third parties with a legitimate interest a direct communication channel with the E&C department: the E&C Channel.  This tool allows questions and complaints to be raised within the objective framework of the channel itself. One of the channels foreseen is the digital platform, accessible through the Intranet, the website and in the documentation prepared by the E&C department, in the form of an easily accessible QR code.

E&C Channel QR

Inquiry and complaint tool

The rights and guarantees of persons using the E&C Channel, as well as its operating principles, are regulated in the E&C Channel Organizational Procedure: confidentiality, absence of value judgments, protection of the rights of the person making the complaint and the person being reported, etc. Among these principles, the guarantee of non-retaliation against the person who, in good faith, submits a complaint through the E&C Channel stands out. This guarantee is embodied in the Non-Retaliation Protocol, which has been in effect since 2019.

The Non-Retaliation Protocol is part of the "E&C Channel Regulations" (in preparation), which aims to bring together all its regulations, from the organization of the communication channels to their operating principles, including the specific procedures for managing communications (consultations and complaints, differentiating in the latter case whether the facts are of a criminal nature - Crime Handling Procedure - or non-criminal - Concern Handling Procedure).

In 2022, a total of 70 communications were received through the E&C channel, of which 58 were inquiries and 12 were complaints. This increase in the number of E&C actions compared to the previous year (32 and 7, respectively) is evidence of the organization's confidence in the Compliance function.

With regard to queries, two areas stand out: protection of personal data and gifts and hospitality, which is related to the communication and awareness-raising campaigns launched in 2022 on these issues.

Regarding the complaints received, all but one were accepted for processing, exceeding the criteria of veracity and seriousness required for their processing. Only one, which was anonymous, was not accepted because it did not exceed these parameters. Following the resolution of the complaints, it can be affirmed that none of them is framed in cases that could lead to criminal liability for the organization or for the person denounced, and none of them involves cases of violation of human rights.