Code of Conduct
This Code of Conduct has been formulated with the purpose of unifying and reinforcing the identity, culture and guidelines of conduct of SOLDAVIGIL, S.L., reflecting the ethical commitment in the development of the company’s activities, always with respect for human rights, and which should govern relations with our partners, suppliers, agents or any other type of collaborators.
This Code constitutes an express declaration of the values, principles and guidelines of behaviour that all SOLDAVIGIL, S.L. employees must adopt and will serve as a guide in relation to the performance of their daily professional activity, in their actions with clients, suppliers and external collaborators; and in their relations with public and private institutions and with society in general, acting in accordance with the law and respecting ethical principles.
2. Scope of application
This Code is mandatory and is aimed at all SOLDAVIGIL, S.L. employees, regardless of the type of contract that determines their employment relationship and the position they occupy, including subcontracted workers.
The Management of SOLDAVIGIL, S.L. will adopt the necessary measures to enforce the set of values, principles and rules that make up this Code, disseminating its content, providing training and resolving any doubts that may arise.
Likewise, the Management of SOLDAVIGIL, S.L. will use all means at its disposal to enforce compliance with the values, principles and rules contained in this Code.
3. Values and basic principles of action and behaviour
3.1 COMPLIANCE WITH THE LAW
All SOLDAVIGIL, S.L. employees and managers shall maintain, in the performance of their work and professional activities, strict compliance with current legislation, in accordance with its spirit and purpose.
The actions of a manager that are contrary to the law or the indications or orders that he/she may give in this sense do not relieve the employees who act according to such indications or orders of responsibility.
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.
SOLDAVIGIL, S.L. undertakes to comply with the tax regulations in force in each territory or country where it is present, avoiding the concealment of relevant information, the illegal avoidance of tax payments or the obtaining of undue tax benefits. Likewise, employees shall collaborate with the Tax Authorities to provide the required tax information in accordance with current legislation.
3.2 INTEGRITY AND ETHICS
All SOLDAVIGIL, S.L. employees must carry out their activities with objectivity, professionalism and honesty. Therefore, they must always:
- Provide value and offer Quality and Service in all businesses in which SOLDAVIGIL, S.L. participates.
- Not collect confidential information about markets, products or competition in an unlawful manner.
- Protect confidential information.
- Compete fairly and honestly, avoiding spreading malicious or false information about competitors.
- Respect the intellectual and industrial property rights of both suppliers and customers.
- Oppose all forms of illicit trade and those that violate the regulations in force in each country or territory.
- Not to participate in activities that may involve a conflict of personal and SOLDAVIGIL, S.L. interests.
- Treat all suppliers impartially, selecting them rigorously and objectively, avoiding any conflict of interest or favouritism in their selection.
3.3 RESPECT FOR HUMAN RIGHTS
All actions of SOLDAVIGIL, S.L. and of the people who form part of it shall scrupulously respect the Human Rights and Public Freedoms included in the Universal Declaration of Human Rights of the United Nations.
SOLDAVIGIL, S.L.’s relationship with its suppliers is based on product and service quality, business and commercial practices, including ethical behaviour, transparency, compliance with applicable legislation and respect for human rights.
The selection of suppliers shall be governed by criteria of objectivity and transparency, reconciling the company’s interest in obtaining the best conditions with the convenience of maintaining stable relationships with ethical and responsible suppliers. Any conflict of interest or favouritism in their selection shall be avoided.
SOLDAVIGIL, S.L. employees shall not request information from suppliers or accept information regarding the conditions set for other companies competing with SOLDAVIGIL, S.L.
No employee of SOLDAVIGIL, S.L. may offer, grant, request or accept, directly or indirectly, gifts or handouts, favours or compensation, in cash or in kind, whatever their nature, which may influence the decision-making process related to the performance of the functions derived from their position.
Specifically, SOLDAVIGIL, S.L. employees may only offer or accept reasonable invitations or token gifts that are appropriate under the circumstances, good customs and generally accepted business practices. In case of doubt, the Compliance Committee must be informed so that it can assess the suitability or otherwise of their acceptance. Cash gifts are expressly prohibited.
All employees and managers of SOLDAVIGIL, S.L. are obliged to act, in their relations with customers, in accordance with criteria of consideration, respect and dignity, taking into account the different cultural sensitivity of each person and not allowing discrimination in treatment on the grounds of race, religion, age, nationality, gender or any other personal or social condition prohibited by law.
Likewise, they will contribute their utmost collaboration, professionalism and service mentality to seek the greatest customer satisfaction and will make an effort to anticipate their needs.
3.6 OUR PERSONNEL
SOLDAVIGIL, S.L. supports and endorses the principles embodied in the Universal Declaration on Human Rights, Workers’ Rights and the Conventions of the International Labour Organisation.
Therefore, all employees must respect the principles set out below:
3.6.1 Discrimination and harassment
Any form of discrimination shall be avoided, from the selection process, the definition of profiles and functions, always seeking promotion linked to merit, skills and individual abilities.
A working environment free of any discrimination and of any conduct involving harassment of a personal nature, including abuse of authority, whether physical, psychological or moral, shall be maintained. Under this premise, no discrimination on the grounds of race, nationality, social origin, age, sex, marital status, sexual orientation, ideology, political or trade union opinions, religion or any other personal, physical or social condition will be tolerated.
3.6.2 Professional development and training
SOLDAVIGIL, S.L. is committed to maintaining a training policy for the learning and personal and professional development of its employees in order to achieve the highest performance, quality and satisfaction in the performance of their duties, as well as to provide greater value to customers.
SOLDAVIGIL, S.L. personnel, for their part, shall participate in training programmes to the extent required and shall strive to obtain the maximum benefit from them.
3.6.3 Freedom of association
SOLDAVIGIL, S.L. promotes and respects the rights of freedom of association and collective bargaining in the workplace, in accordance with current legislation.
3.6.4 Health and safety at work
SOLDAVIGIL, S.L. promotes the adoption of health and safety at work policies and adopts the preventive measures established in current legislation and undertakes to provide the necessary means to minimise risks at work, both for its own staff and subcontracted personnel.
All employees, whether in-house or subcontracted, are responsible for strict compliance with health and safety regulations. They shall also make responsible use of the equipment assigned to them according to the activities they carry out and shall disseminate appropriate knowledge to colleagues and promote compliance with risk protection practices.
3.6.5 Eradication of forced labour and child labour
Neither SOLDAVIGIL, S.L. nor any supplier company shall use child labour, and shall ensure compliance with the provisions of the International Labour Organisation in relation to child labour.
Likewise, neither SOLDAVIGIL, S.L. nor any of its supplier companies shall resort to forced or coerced labour and shall ensure a balance between the professional and personal spheres of all its employees.
3.6.6 Protection of personal data and information management.
SOLDAVIGIL, S.L. employees shall not disclose personal data obtained from customers, partners, suppliers, collaborating companies, contractors, other employees, public administrations and the general public so that, in accordance with applicable laws, the privacy and trust placed in the company by these groups is ensured.
3.7 Relationship with the market and the community
3.7.1 External communication
SOLDAVIGIL, S.L. considers its image and reputation as one of its most valuable assets in order to preserve the trust of its customers, suppliers, authorities and its own staff. Therefore, employees and managers must be especially careful with regard to the information that is transmitted to the outside world and may not issue messages or communications that damage the image and reputation of the company, nor express personal opinions on behalf of the company that are contrary to the company’s values.
3.7.2 With regard to free competition
SOLDAVIGIL, S.L. competes in the market in a fair manner, promoting free competition for the benefit of consumers and under no circumstances accepts misleading, fraudulent or malicious conduct.
The employees of SOLDAVIGIL, S.L. will avoid any type of conduct that could constitute an abuse or illicit restriction of competition, will not carry out unfair actions or illicit advertising of the activity of the company’s business, or that of its competitors or third parties; and will avoid any conduct that constitutes or could constitute an abuse or illicit restriction of competition. Obtaining information from third parties, including competitor information, must be done in a lawful manner.
3.7.3 Accuracy of Financial Information
SOLDAVIGIL, S.L. undertakes to provide complete and accurate information about the company. Likewise, it undertakes to cooperate with supervisory or inspection bodies or entities in all that is required in order to facilitate administrative supervision.
SOLDAVIGIL, S.L. staff shall ensure that all transactions with economic significance that are carried out on behalf of the company are clearly and accurately recorded in appropriate accounting records that represent a true and fair view of the transactions carried out.
Accounting standards and principles shall be strictly followed, financial reporting shall be complete and accurate, and adequate internal controls and procedures shall be in place to ensure that accounting and financial reporting comply with applicable laws, regulations and regulatory requirements.
Conduct aimed at avoiding tax obligations or obtaining benefits to the detriment of the Treasury, Social Security and equivalent bodies is expressly prohibited.
3.7.4 Prevention of money laundering
In order to prevent and avoid money laundering or terrorist financing operations, SOLDAVIGIL, S.L. employees, managers and administrators must pay special attention to cash payments that are unusual in relation to the nature of the operation, those made by means of bearer cheques, those made in currencies other than those previously agreed, those made to countries that have no relation to the operation itself, or those that include unknown or unnecessary intermediaries.
In those operations or activities in which there is a risk of money laundering, SOLDAVIGIL, S.L. is obliged to adopt compliance measures based on the identification of the client and collaboration with the competent authorities.
It is expressly forbidden to make payments or collections in cash in excess of the limits set by the local jurisdiction under any circumstances.
3.7.5 Relationship with administrations and political parties
SOLDAVIGIL, S.L. declares its political neutrality in the territories in which it operates and does not finance political parties or their representatives.
All relations with the Administration will be carried out with total transparency, collaborating with Public Bodies in a disinterested manner.
3.7.6 Fighting bribery and corruption
All SOLDAVIGIL, S.L. employees must behave in such a way that their conduct does not induce a public official, authority or private individual to violate their duties of impartiality or any legal precept. From this obligation derives:
- The absolute prohibition to offer any public official, authority or private individual, directly or indirectly, any type of gift, retribution of any other type or undue advantage, with the aim of violating their obligations in order to favour SOLDAVIGIL, S.L.
- The prohibition to carry out any type of behaviour or activity aimed at unlawfully influencing the behaviour of a public official or authority to adopt or not to adopt a decision that could favour the company or related parties.
- The prohibition of receiving, requesting or accepting an unjustified benefit of any nature, with the aim of favouring against third parties the person who grants or from whom the benefit or advantage is expected in breach of his obligations.
These prohibitions also extend to persons closely linked by family or friendship to the public official, authority or private individual.
3.7.7 Protection of the environment
SOLDAVIGIL, S.L. is committed to the protection and conservation of the environment and, therefore, carries out its activity under the premises of optimising the consumption of natural and energy resources, minimising the waste generated, as well as its recycling, reuse and reduction; and controlling the polluting spills and emissions associated with the activity.
All SOLDAVIGIL, S.L. personnel must comply with the environmental legislation and regulations applicable to their area of activity.
4. Monitoring and control
The employees, collaborators and managers of SOLDAVIGIL, S.L. must be familiar with and accept the full content of the Code and, in particular, the principles and rules of conduct set out therein. For this reason, this Code will remain published on the SOLDAVIGIL, S.L. website () and will be published on the SOLDAVIGIL, S.L. website. (www.soldavigil.com) and will be the subject of appropriate communication, training and awareness-raising actions to ensure that it is properly understood and put into practice by the entire organisation.
In order to ensure compliance with this Code, there is a Compliance Committee composed of:
- Susana Argüelles – Finance / HR Director.
- Isabel Argüelles – Operations Director.
The Compliance Committee may act on its own initiative or at the request of any employee, manufacturer, supplier or third party in general, by means of a report made in good faith and based on alleged breaches of this Code that it detects.
To this end, communications made under this Code, whether containing allegations of non-compliance or queries regarding its interpretation or application, may be sent by the following means:
Postal mail to “Compliance Committee”, Polígono Industrial Porceyo I-13, C/ Carl Sagan, 69/45, 33392, Gijón, Spain.
Email address: email@example.com
The Compliance Committee shall have the following basic functions:
- The supervision of compliance with and internal dissemination of the Code among all personnel (direct or subcontracted) of SOLDAVIGIL, S.L.
- The supervision of the complaints channel and the reception of all types of writings related to the application of the Code.
Control and supervision of the processing of cases and their resolution.
- Interpretation of any doubts raised by the application of the Code.
- Updating, improving and modifying the Code of Conduct.
- Informing SOLDAVIGIL, S.L. Management of the main compliance issues.
In all cases, the Compliance Committee will guarantee the confidentiality of all the data and background information handled and the actions carried out, unless the law or court order requires the information to be forwarded; and will guarantee the indemnity of any complainant as a result of the presentation of requests or complaints in good faith to the Committee.
Any breach or non-compliance with this Code that constitutes an offence of a labour nature shall be sanctioned in accordance with the regulations in force, without prejudice to any other responsibilities that the offender may have incurred.
5. Approval and validity
This Code of Conduct shall enter into force on the day of its approval by the Management of SOLDAVIGIL, S.L., and shall be communicated to all employees, and shall remain in force until its cancellation is approved.
In Gijón, on 1st October 2021.