code of ethics & conduct grupo antolin of conduct eng.pdf · the principles of the global...

Code of Ethics & Conduct

Grupo Antolin

Propuesta Grupo Antolin 2010 2010


Index

1. - Letter from the President

2. - Introduction to the Code

3. - Enforcement and Application of the Code

4.- Commitment

A) of Grupo Antolin

B) of the employees

5. - Management of Ethics Violations

A) Whistleblowing (Grupo Ethics Link)

B) Ethics Committee



1.- Letter from the President

Since the beginning, Grupo Antolin has had the firm

intention of “doing what is right”. And in the world today, in

constant change, the intention to act responsibly has now

become more important than ever.

We understand Responsible Conduct is the only way to carry

out the actions and decisions of our commercial activity.

This conduct is, furthermore, independent from the location

of the activity and particularly important in developing

countries.

The values of Grupo Antolin are the foundation of our

corporate culture, and are strengthened by our creativity,

leadership, customer focused and sustainability.

Our job is to contribute to the professional and personal

growth of each and every person who is an integral part of

Grupo Antolin, through the creation of an environment of

mutual respect, free from any form of harassment or

discrimination of any kind. We want to be an innovative

company, integrated within the communities in which we

operate. And in this sentiment, the Code of Ethics and

Conduct strives to orient all employees of the company to

this way of acting.

In the corporate strategy of Grupo Antolin, we have

integrated the Ten Principles of conduct and action from the

World Pact of the United Nations on Human Rights, work,

environment and the fight against corruption.

Responsibility is the axis around which our corporate

identity revolves.

José Antolin Toledano



2. - Introduction to the Code

The Code of Ethics and Conduct of Grupo Antolin (hereafter

referred to as the Code) is a living document in which the

principal objective is to guarantee responsible conduct in

the development of our activities.

With this document, Grupo Antolin publicly declares its

commitment to the Universal Declaration of Human Rights,

the principles of the Global Compact of the United Nations

(of which, Grupo Antolinhas been a founding member of

since 2003), and the Organization for Economic Cooperation

and Development (OECD).

The present document reflects these values and should

serve as a guide for the conduct of the company and those

who make up the company. It should instill honesty, ethics

and professionalism in our relationships with our clients,

stockholders, employees, suppliers and with society in

general.

The Code is not a rule of internal regimen, nor is it a

substitute for the collective bargaining agreements or of the

national, international or local legislations. Nevertheless, the

company gives a prioritized level of importance to the

compliance with this Code, of which all employees of Grupo

Antolin should commit to respecting the content and spirit

of the document.

Ultimately, we should always appeal to our sense of

responsibility and good judgment, and seek counsel if ever

there is doubt regarding appropriate corporate behavior.



3. - Enforcement and Application of the Code

This Code of Ethics and Conduct goes into effect on the

same day Grupo Antolin makes its commitment public.

This Code is subject to revisions and updates as the

Company fulfills its obligations of Corporate Responsibility,

as well as from suggestions and proposals made by the

employees and the Ethics and Conduct Committee of Grupo

Antolin.

Grupo Antolin’s commitment to this Code extends to all of

the facilities in which Grupo Antolin is a major partner or has

management control, as well as to the supply chain.

Similarly, this Code applies to all employees associated with

Grupo Antolin, independent from contracts that have been

negotiated in labor relations, the position that is held in the

organization or the territory where employed.

Anyone who violates the Code, Policies or Procedures of

Grupo Antolin is subject to disciplinary actions, up to and

including dismissal. Disciplinary actions are also applicable

to anyone who requests or approves infractions, or has any

knowledge of them but does not act immediately to seek

resolution.



4.- Commitment

A) of Grupo Antolin

Grupo Antolin continuously strives for a sustainable future,

working to decrease the impact our activities generate on

the environment and on the people in the surrounding

communities. For this reason, we are committed to the

specific universal values that govern Grupo Antolin’s

behavior in all activities.

Human Rights:

Grupo Antolin supports the fundamentals of human rights,

and avoids and denounces participation in any commercial

activities that abuse those rights.

Labor Standards:

Grupo Antolin defends the freedom of association and

effectively acknowledges the rights of collective bargaining.

Supports the elimination of all forms of forced labor or

work which is carried out under coercion.

Respects the laws enforced in each country with regard

to work hours.

Implements policies in accordance with local

compensation laws, including minimum wage and

employment benefits.

Opposes illegal child labor practices.

Favors the elimination of discriminatory hiring and

employment practices.

And guarantees a management system with safe and

healthy work standards.



Environment:

Grupo Antolin aspires to minimize the detrimental impact

on the environment from its commercial operations.

Fosters initiatives that promote enhanced environmental

responsibility.

And promotes the development and diffusion of processes

and technologies that are respectful of the environment.

Anti-Corruption:

Grupo Antolin is committed to supporting international and

local efforts to eliminate corruption and financial crime.

Relationships with Competitors:

Grupo Antolin is committed to competing vigorously and

competitively in the marketplace, but in full compliance with

all laws regarding competition in its different commercial

territories.

B) of the employees

• To be honest and trustworthy, basing our

competitiveness on the quality of our products and

services, avoiding situations that confuse

professional responsibilities and ethics, ensuring that

any payment, distribution or gift, for or in the name

of the company, is legal and for legitimate reasons.

• To act in an educated manner that is respectful and

fair to co-workers and professionals of Grupo

Antolin, as well as with our clients and service

providers, applying the company policies in the areas

of diversity and tolerance, without discrimination for

reasons of age, race, color, sex, language, religion,

beliefs, origin, or any other condition or circumstance,

personal and/or social.



• To maintain the necessary level of confidentiality, within

the framework of professional ethics in all work-related

aspects of those areas, to guard all professional secrets

whenever needed, both internally and externally, with

suppliers, clients and competitors.

• To protect our own independence without letting others

influence our professional judgment, and avoid

involvement in any situation where a possible conflict of

interest or circumstance could affect our own impartial

critical judgment and objectivity.

• To achieve a healthy and secure atmosphere fulfilling

and ensuring the necessary security measures and

cleanliness, as well as making responsible use of the

resources and facilities of Grupo Antolin, when and

where work is performed, never working under the

influence of alcohol or drugs or any other illegal

substance that might cause questionable professional

behavior and/or threaten the security of others.

• To prohibit violent behavior, threats, coercion or any

form of intimidation or harassment from co-workers,

management, clients or any other agent of the company.

• To preserve company knowledge by facilitating the

dissemination of information to other Grupo employees

and willingly making available the management systems

of knowledge that enable information to be more

effectively distributed to others within the company.

• To utilize with diligence the proper technical resources

and materials provided by the Company to avoid

damage from misuse, and being responsible for the

possession, proper care of them and their use in

compliance with the rules and enforced internal

guidelines.



• To enforce a belief in creating an agreeable and

respectful work environment, using the tools provided

for all employees by the Company to express the level of

satisfaction with the policies and processes of Grupo

Antolin.

• To contribute to the continued improvement of our

environmental behavior, integrating the environmental

policies of Grupo Antolin into our company’s conduct

and daily activities.

• To denounce any situation that violates the principles

and fundamental Rights of the people and of the

environment of each of the companies in which the

presented code applies.

• To experience the right to express our concerns and

points of view across the established inquiry channels

established to guarantee the freedom of expression.

• To represent Grupo Antolin responsibly in its

development of our professional activities, always and

everywhere, being conscious that whatever proceedings,

omissions or decisions that are made on behalf of Grupo,

directly or indirectly, affect the reputation of the

company.

• To be committed to achieving the maximum quality,

individually, as a part of a team and cooperatively,

always seeking the best continuity.



5. Management of Ethics Violations

A) Whistleblowing (Grupo Ethics Link)

Available to all Grupo Antolin employees is the

Whistleblowing (Grupo Ethics Link) as a way to submit any

complaints and/or incident reports to be considered in a

timely manner. This communication can be made through

the Company’s Intranet, for those who have access to a

computer, and also via the following mail address:

Grupo Antolin

P.O. Box 2069

Burgos, Spain E-09007

The complaints should be identified with all of the necessary

information provided, and with the specific details of the

incident. Anonymous claims will not be accepted.

This information will be received solely by the corporate

office Human Resources Department. Periodically, the

received documentation will be presented to the Ethics

Committee. If it is determined that a complaint is valid and

can be supported, two evaluators will be designated to carry

out any interviews and to compile all of the necessary

information.

The resolution, representing the position of the company

regarding the specific conflict, will be communicated solely

to the interested parties, and will be taken under

advisement.



It is the responsibility of each of us to apply the contents of

this Code of Ethics & Conduct in an appropriate manor, and

to in turn, help others to do the same. From here forward,

we would like to encourage everyone to express their

concerns and to inform us, in good faith and with

impartiality and respect, of any conduct or situation that is

contrary to the commitments stated in this document.

In consideration of Grupo Antolin, as a whole and in its

global position, when faced with situations concerning

corporate conduct in its International efforts, the

established policies of the company of destination and of

the origin should be available to adequately make any

decisions. If there is any doubt, however, each professional

should use their best judgment to determine the best way

to respond to the situation, seeking assistance from co-

workers, from those who are responsible, and if necessary,

from the company by submitting their concerns to the Ethics

Committee for consideration.

B) Ethics Committee

Grupo Antolin has created an Ethics Committee with the

charge to watch over the development, revision and the

fulfillment of the Code of Ethics and Conduct. And has the

authority to resolve the ethics-related conflicts that occur

within the company.

The Committee consists of a cabinet of internal

professionals, as well as of external experts in the areas of

Corporate Responsibility, labor and legal matters.

The objectives of the Ethics Committee are:

1. - To evaluate the level of symmetry between the values of

the company and the actual social and cultural environment

of the company.

2. - To develop and update the values and the present Code,

based on the internal needs of the company.



3. - To oversee the complete adaptation to the ethics

principles and values within Grupo Antolin.

4. - To guide and support the professionals of the company.

5. - To identify, analyze and give responses to unresolved

issues.

The Ethics Committee is, furthermore, committed to

periodically providing updates on the direction of Grupo

Antolin with respect to the number and the severity of

discovered incidents, the number of interventions by the

committee and the number of corrective actions brought to

resolution, as well as an extension of knowledge of the Code

of Ethics and Conduct on behalf of the professionals of de

Grupo Antolin.

I have read, understand and am committed to

respecting the spirit and the language of the Code of

Ethics and Conduct of Grupo Antolin

http://intranetga/LOGIN/AprobarCodigoConducta.asp

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