The aim of Grupo Paradell Code of Ethics is to establish the guidelines that must govern the ethical behaviour of all its administrators and employees in their daily work, with regard to the relationships and interactions it maintains with all its stakeholders. These are its own employees, customers, suppliers and external collaborators, shareholders, public and private institutions and society in general.
This Code of Ethics is based on the definition of the Mission, Vision, Values and Principles of Grupo Paradell, which it complements, and constitutes a guide for action to ensure appropriate behaviour in the professional performance of its employees, in accordance with current legislation and established internal regulations. Grupo Paradell Code of Ethics reflects the principle of due diligence applied by the Grupo Paradell to prevent, detect and eradicate irregularities related to breaches of the Code and established internal rules, including those related to criminal offences. The company understands that diligence in these matters requires, among other things, designing and implementing control models that regularly analyse the risks in the matters covered by this Code, ensure awareness of the rules in the organisation, define responsibilities and establish procedures that allow confidential notification of irregularities, as well as their resolution. The company understands that the procedures it has in place, including the Criminal Prevention Model, enable it to respond to the above elements.
CEO Grupo Paradell Consultores
Scope of application
Grupo Paradell Code of Ethics is aimed at its directors, managers and, in general, all Grupo Paradell staff, regardless of the position they hold or the place where they work. The guidelines of conduct contained in this Code are mandatory and affect all investee companies in which the Grupo Paradell has management control. Furthermore, Grupo Paradell will promote and encourage its suppliers and collaborating companies to adopt behavioural guidelines consistent with those defined in this Code of Ethics. When circumstances so advise, the company may ask its suppliers, collaborating companies and counterparties to formalise their commitment to comply with the Code or with the guidelines it establishes. Likewise, the application of the Code may be extended to any person or organisation linked to Grupo Paradell when the company deems it appropriate and the nature of the relationship makes it possible. The Board of Directors and First Level Management of Grupo Paradell will use all the means at their disposal to disseminate the Mission, Vision, Values and Principles of Grupo Paradell, and to enforce compliance with the guidelines for conduct contained in this Code. Likewise, they will be a reference model in their behaviour and level of compliance with the Code. The criteria for conduct contained in this Code are not intended to cover all situations or circumstances that Grupo Paradell employees may encounter, but rather to establish general guidelines for conduct that will guide them in the way they act during the performance of their professional activity.
Grupo Paradell’s guiding principles of conduct
Grupo Paradell believes that the trust of its shareholders, customers, suppliers and external collaborators, as well as the social environment in which it operates, is based on the integrity and responsibility in the professional performance of each of its employees. Integrity is understood as acting ethically, honestly and in good faith. Professional responsibility is understood as acting proactively, efficiently and with a focus on excellence, quality and willingness to serve. Grupo Paradell expects all its employees to behave with integrity and responsibility in the performance of their duties. Grupo Paradell also expects its suppliers and external collaborators to behave in accordance with these principles. All Grupo Paradell employees may consult any doubts about the interpretation of the guidelines for conduct that appear in this Code and must report, in good faith and without fear of reprisals, any breach of the guidelines of the Code that they observe in their professional performance, to their hierarchical superior or to the company's Management.
The Code of Ethics sets out specific guidelines for action in the following content areas:
- Respect for legality, human rights and ethical values.
- Respect for people.
- Professional development and equal opportunities.
- Cooperation and dedication.
- Health and safety at work.
- Use and protection of assets.
- Corruption and bribery.
- Irregular payments and money laundering.
- Corporate image and reputation.
- Loyalty to the company and conflicts of interest.
- Treatment of information and knowledge.
- Customer relations.
- Relations with shareholders.
- Relations with collaborating companies and suppliers.
- Respect for the environment.
Respect for legality, human rights and ethical values
Grupo Paradell is committed to always acting in accordance with current legislation, with the internal regulatory system established with internationally accepted ethical practices, with full respect for human rights and civil liberties. Grupo Paradell activities and operations are carried out in accordance with its Mission, Vision, and Values statement. All Grupo Paradell employees must comply with the laws in force in the countries in which they operate, in accordance with the spirit and purpose of those laws and must behave ethically in all their actions. Likewise, they must avoid any conduct, even if it does not violate the law, that could damage the reputation of Grupo Paradell in the eyes of the community, the government of the country or other bodies, and negatively affect its interests. Grupo Paradell employees must act with honesty and integrity in all their contacts or transactions with the authorities and officials of the different governments and administrations, ensuring that all the information and certifications they submit, as well as the declarations they make, are truthful. All employees must be aware of the laws that affect their work, requesting, where appropriate, the necessary information through their superior or the corresponding bodies. No employee shall knowingly collaborate with third parties in the violation of any law, or participate in any action that compromises respect for the principle of legality. For its part, the company shall provide the necessary means for its employees to be aware, at all times, of the external and internal regulations relevant to the functions they perform and shall establish the necessary internal control models to ensure compliance with the law and ethical values.
Respect for people
Grupo Paradell rejects any manifestation of physical, psychological or moral harassment or abuse of authority, as well as any other conduct that may generate an intimidating or offensive environment with the rights of individuals. Employees of the Grupo Paradell must treat each other with respect, fostering cordial relations and a pleasant, healthy and safe working environment. All employees are obliged to treat their colleagues, superiors and subordinates fairly and respectfully. In the same way, relations between employees of Grupo Paradell and those of external partner companies or entities shall be based on professional respect and mutual collaboration.
Grupo Paradell considers the integral development of the individual to be important, which is why it will facilitate the necessary balance between professional and personal life.
Professional development and equal opportunities
Grupo Paradell promotes the professional and personal development of all its employees, ensuring equal opportunities through its policies. It does not accept any kind of discrimination in the workplace or professional sphere on the grounds of age, race, colour, sex, religion, political opinion, national origin, social origin or disability.
Furthermore, Grupo Paradell supports and is committed to the application of public policies established to promote greater equality of opportunities and to foster a corporate culture based on merit. The selection and promotion of Grupo Paradell employees is based on the competencies and performance of professional functions, and on the criteria of merit and ability defined in the job requirements. All employees must actively participate in the training plans that Grupo Paradell makes available to them, involving themselves in their own development and committing themselves to keeping the necessary knowledge and skills up to date, in order to promote their professional progress and contribute value to customers, Grupo Paradell shareholders and society in general. Persons holding management or leadership positions must act as facilitators of the professional development of their collaborators, to encourage their professional growth in the company.
Cooperation and dedication
Grupo Paradell fosters an environment of cooperation and teamwork to make the best use of all its skills and resources. All Grupo Paradell employees must act in a spirit of collaboration, making available to the other organisational units and people any knowledge or resources that may facilitate the achievement of objectives and interests. However, this obligation shall not contravene the legal limitations on the separation of activities relating to participation in other organisational structures and the provision of commercially sensitive information contained in legislation. In addition, where required by law, those responsible for the day-to-day management of certain activities should be encouraged to have effective decision-making powers over those activities, subject to appropriate supervision by Grupo Paradell. Employees must work efficiently during the working day, make the most of the time and resources that the company places at their disposal, and try to contribute maximum value in all the processes in which they participate.
Health and safety at work
Grupo Paradell promotes the adoption of occupational health and safety policies and adopts the preventive measures established in current legislation in this area. It also promotes and encourages the application of its occupational health and safety standards and policies by the collaborating companies and suppliers with which it operates. Grupo Paradell considers safety to be an individual responsibility and a condition of employment, which is why it will not allow unsafe behaviour that could cause serious harm to people and/or installations. To avoid such unsafe behaviour, there are a series of red lines that must not be crossed by Grupo Paradell employees, as indicated below:
- Conceal work accidents or very serious incidents, or induce third parties to do so, caused in the execution of activities on behalf of the company, whether by its own personnel or any external collaborator providing services.
- Falsifying safety records.
- Ordering non-compliance with safety regulations.
Use and protection of assets
Grupo Paradell provides its employees with the necessary resources to carry out their professional activity and undertakes to provide the means to protect and safeguard them. All employees must use the company's resources responsibly, efficiently and appropriately in the context of their professional activity. They must also protect and preserve them from any inappropriate use that could be detrimental to the interests of the company.
The company does not permit the use of the equipment it makes available to its employees to use computer programmes or applications whose use is illegal, which may damage its image or reputation, or to access, download or distribute illegal or offensive content.
Corruption and bribery
Corruption and bribery occur when employees use unethical practices to obtain some benefit for the company or for themselves. Corruption and bribery are one of the categories of fraud. Grupo Paradell is opposed to influencing the will of people outside the company to obtain any benefit through the use of unethical practices. Nor will it allow other people or entities to use such practices with its employees. Grupo Paradell employees may not accept, directly or indirectly, gifts or compensation of any kind intended to improperly influence their business, professional or administrative relations, whether with public or private entities. Likewise, employees may not make, either directly or indirectly, payments, gifts or compensation of any kind that are not considered to be part of the normal course of business, in an attempt to improperly influence their commercial, professional or administrative relations with both public and private entities. Those third parties that Grupo Paradell may use for the commercial development of the company must assume, in their relations with private and public entities, commitments similar to those set out in this Code. In addition, in the performance of their professional duties, employees shall ensure compliance with the internal control established to prevent irregularities and undue advantages in the company's relations with third parties.
Irregular payments and money laundering
Grupo Paradell has established policies to prevent and avoid irregular payments or money laundering originating from illicit or criminal activities in the course of its operations. The aforementioned policies establish specific controls on those economic transactions, both collections and payments, of an unusual nature or amount made in cash or with bearer cheques, as well as on all payments made to entities with bank accounts opened in tax havens, identifying in all cases the ownership of the same. Grupo Paradell employees will remain alert to any cases in which there may be indications of a lack of integrity on the part of the people or entities with which Grupo Paradell maintains relations. Finally, Grupo Paradell employees will carefully review any extraordinary payments not foreseen in the corresponding agreements or contracts.
Corporate image and reputation
Grupo Paradell believes that one of the basic elements that contribute to its corporate image and reputation is the establishment of responsible citizenship relations in the communities in which it operates. All employees must consider the interests of local communities in the course of their work. Grupo Paradell considers its corporate image and reputation as one of its most valuable assets to preserve the trust of its shareholders, customers, employees, suppliers, authorities and society in general. All employees must take the utmost care to preserve the company's image and reputation in all their professional activities. Likewise, they shall monitor the respect and correct and appropriate use of the corporate image and reputation by employees of contractors and collaborating companies. Employees must be especially careful in any public intervention, and must have the necessary authorisation to speak to the media, participate in professional conferences or seminars and in any other event that may have a public dissemination (including comments on social networks), as long as they appear as employees of Grupo Paradell. Grupo Paradell does not finance political parties or their representatives or candidates in the countries where it operates. Employees' involvement or collaboration with political parties is on a personal basis and is completely unrelated to the company's activities. The company will apply due diligence to ensure the respectability of the organisations and causes it is supporting, complying with the established internal regulations, which include the Due Diligence process for counterparties, which analyses, among other things, reputational risk. On a regular basis, the company will make public the names of the main organisations it supports through its social activities.
Loyalty to the company and conflicts of interest
Conflicts of interest arise in circumstances where employees' personal interests, directly or indirectly, are contrary to or collide with the company's interests, interfere with the proper performance of their professional duties and responsibilities or involve them personally in a company transaction or economic operation. Grupo Paradell believes that the relationship with its employees should be based on the loyalty that stems from common interests. In this sense, it respects the participation of its employees in other financial or business activities as long as they are legal and do not unfairly compete or clash with their responsibilities as employees of Grupo Paradell. In this regard, employees must abide by the limitations on participation in companies established in the applicable legislation. Employees must inform the company if they or their close relatives participate or will participate in the governing bodies of other companies that may conflict with the interests of Grupo Paradell.In carrying out their professional responsibilities, employees must act loyally and in the best interests of Grupo Paradell. They must also avoid situations that could lead to a conflict between personal interests and those of the company. Therefore, Grupo Paradell employees must refrain from representing the company and from intervening in or influencing decision-making in any situation in which they directly or indirectly have a personal interest.
Information and knowledge processing
Grupo Paradell considers information and knowledge to be one of its main and essential assets for business management, which is why they must be subject to special protection. It declares the truthfulness of information as a basic principle in all its actions, so employees must truthfully transmit all the information they have to communicate, both internally and externally, and under no circumstances will they knowingly provide incorrect or inaccurate information that could mislead the recipient. All employees who enter any type of information into Grupo Paradell computer systems must ensure that it is accurate and reliable. In particular, all Grupo Paradell economic transactions must be clearly and accurately reflected in the corresponding records, through the corresponding Accounting Accounts, as well as all the operations carried out and all the income and expenses incurred. Grupo Paradell employees shall refrain from any practice that contravenes the commitment to clearly and accurately reflect all economic transactions in the Grupo Paradell Accounts.All employees of Grupo Paradell must maintain the strictest confidentiality with regard to all confidential information to which they have access as a result of their professional activity. Employees who have confidential information about the company, or about important aspects of the company's strategy, policy, plans or assets, must preserve it so that it cannot be used inappropriately and must refrain from using it improperly for their own benefit or that of third parties. In case of any doubt as to the nature of the information, employees should treat it as confidential until they are instructed otherwise. Grupo Paradell ensures that the information and knowledge generated in the company flows properly among all its employees and organisational units to facilitate the management of activities and enhance the development of people. All information and knowledge, understood as the conceptual result of the integration of diverse information generated within the company, is the property of Grupo Paradell under the terms referred to in current legislation. Employees have the duty to preserve the company's knowledge by facilitating its dissemination to other employees of Grupo Paradell and making it available to the knowledge management systems set up within the company. Employees must ensure that they do not share commercially sensitive information between Grupo Paradell companies when required to do so by applicable law. Grupo Paradell complies with the data protection legislation in force in each country, respecting the right to privacy and protecting the personal data entrusted to it by its customers, employees, suppliers and external collaborators, candidates in selection processes or other persons. Grupo Paradell employees protect the intellectual property of Grupo Paradell and third parties, including but not limited to patents, trademarks, domain names, copyrights (including software copyrights), design rights, database extraction rights and rights to technical know-how. In their dealings with third parties, employees shall scrupulously follow the rules and procedures in this area in order to avoid infringing the rights of third parties.
Grupo Paradell assumes, leads and promotes the commitment to quality, providing the necessary resources to achieve excellence and establishing the appropriate measures to ensure that the quality policy is practised by all employees in accordance with these principles. Grupo Paradell competes in the market in a fair manner, and does not accept deceitful, fraudulent or malicious conduct that leads the company to obtain undue advantages. All employees of Grupo Paradell must act with integrity towards the company's customers or its internal customers, aiming to achieve the highest standards of quality, excellence in service provision and the long-term development of relationships based on trust and mutual respect.
The information or advice provided to customers must always be sufficient, truthful, timely and appropriate. Under no circumstances may customers be provided with misleading, ambiguous or insufficiently rigorous information that could mislead them or lead them to take the wrong decisions.
The purpose of Grupo Paradell is the continuous creation of value for its shareholders, which is why it is committed to providing objective, transparent, adequate and timely information on the evolution of the company and under equal conditions for all its shareholders. Similarly, Grupo Paradell is committed to developing the necessary basis for the participation of its shareholders in the decisions that correspond to them.
Relations with partners and suppliers
Grupo Paradell considers its suppliers and collaborating companies to be an essential part of achieving its growth and service quality improvement objectives, seeking to establish relationships with them based on trust and mutual benefit. Grupo Paradell is committed to promoting among its suppliers and external collaborators, without prejudice to the fulfilment of contractual conditions, and under the premise of respect for the power of management, practices in accordance with the guidelines of conduct included in this Code of Ethics. When circumstances make it advisable, the company may require its suppliers and collaborating companies to undertake to expressly endorse and comply with the provisions of this Code.
All Grupo Paradell employees who participate in supplier and external collaborator selection processes are obliged to act impartially and objectively, applying transparent criteria and complying strictly and without exception with internal regulations on the subject, including the Due Diligence procedure for counterparties, which analyses and evaluates the risk of operations with third parties, quality and cost criteria and avoiding the collision of their personal interests with those of the company. Grupo Paradell also offers its contractors, suppliers and external collaborators the possibility of confidentially, in good faith and without fear of reprisals, contacting the Code of Ethics Committee when they believe that the practices of Grupo Paradell employees do not comply with the provisions of this Code. The agreements established between the Grupo Paradell and its suppliers or collaborating companies include clauses regarding compliance with certain ethical, social and environmental standards.
Respect for the environment
Preserving the environment is one of Grupo Paradell basic principles of action. Consequently, it has defined a policy and implemented an environmental management system. Grupo Paradell employees must know and accept this policy and act at all times in accordance with the criteria of respect and sustainability that it inspires, adopt habits and conduct related to good environmental practices and contribute positively and effectively to the achievement of the established objectives. Likewise, employees must strive to minimise the environmental impact derived from their activities and from the use of the facilities, equipment and means of work placed at their disposal, striving for their efficient use. In their relations with contractors or external collaborating companies, Grupo Paradell employees shall transmit these principles and demand compliance with the environmental procedures and requirements applicable in each case.
Acceptance of and compliance with the Code
Compliance with this Code of Ethics is mandatory for all Grupo Paradell employees and for third parties who have voluntarily undertaken to comply with it. The company will communicate and disseminate the content of this Code of Ethics to all its employees and to those third parties for whom it is relevant.
Employees must formally undertake to comply with the Code when they join the company, in the novation of their contracts and in those other circumstances in which the company deems it appropriate. In addition, the company will periodically require its directors and employees to formally state that they are aware of and comply with the guidelines for conduct established in the Code and will hold training sessions on the different aspects of the Code.
Grupo Paradell expects all its employees to be highly committed to complying with its Code of Ethics. All employees may be assessed on the basis of their compliance with this Code. Non-compliance will be analysed in accordance with internal procedures, legal regulations and agreements in force, and if applicable, the appropriate sanctions will be applied. Any doubts that may arise regarding the interpretation or application of this Code of Ethics should be consulted with the line manager or, if necessary, with the Code of Ethics Committee.
No one, regardless of level or position, is authorised to ask an employee to contravene the provisions of this Code of Ethics. No employee may justify improper conduct on the basis of a superior order or ignorance of this Code. Breaches of the Code of Ethics jeopardise Grupo Paradell reputation and could compromise its solidity. For this reason, all Grupo Paradell employees are obliged to report any breach or malpractice they may observe in the course of their professional activities to their line manager or to the Code of Ethics Committee.
Grupo Paradell has established formal channels supervised by the Code of Ethics Committee, so that all its employees can make enquiries or report breaches of the provisions of this Code in good faith and without fear of reprisals.
Code of Ethics Commission
The Code of Ethics Committee is a consultative and recommendatory body whose purpose is to: - Promote the dissemination, knowledge and compliance with the Code of Ethics. - To interpret the Code of Ethics and guide actions in case of doubt. - Facilitate the resolution of conflicts related to the application of the Code of Ethics. - Facilitate and manage a channel of communication for all employees, suppliers and collaborating companies to carry out, in good faith and without fear of reprisals, consultations or communications of non-compliance with the Code of Ethics or any other related information. - To report to the Governing Bodies of Grupo Paradell on the dissemination of and compliance with the Code of Ethics, as well as on the activities of the Committee itself, drawing up recommendations or appropriate proposals to keep it up to date, improve its content and facilitate the application of those aspects that require special consideration. The Committee will be made up of the Management Committee of Grupo Paradell.
The Code of Ethics comes into force on the day of its publication to all employees and will remain in force until its cancellation is approved. It will be reviewed and updated periodically by the Management Committee, at the proposal of the Code of Ethics Committee, which will take into account the suggestions and proposals made by employees and the commitments acquired by Grupo Paradell in terms of social responsibility and good governance.