Reiterate the commitment of AICONTROLLER with strict compliance with the rules on prevention and fight against corruption1, developing the principles set out in the Code of Ethics and Conduct and extending its compliance not only to all employees of the companies in which AICONTROLLER Group exercises direct or indirect control of the management, but also to our collaborators2.
AICONTROLLER Group rejects all forms of corruption by applying a zero tolerance criterion regarding any breach of this policy.
In order to prevent corruption, AICONTROLLER Group will carry out all its activities in accordance with the legislation in force in all fields of activity and in all the countries in which it operates, in accordance with its spirit and purpose, and undertakes to :
Do not influence the will or objectivity of people outside the Company to obtain any benefit or advantage through the use of unethical practices and / or contrary to applicable law.
Not to give, promise or offer, directly or indirectly, any good of value3 to any natural or legal person, in order to obtain undue advantages for the Company.
Do not allow any facilitation payment4.
Not to finance or show support or support of any other kind, directly or indirectly, to any political party, its representatives or candidates.
Do not use donations to conceal undue payments.
Not to solicit or to receive in an undue way, directly or indirectly, commissions, payments or benefits of third parties on the occasion of or with cause in the operations of investment, disinvestment, financing or expense carried out by the Company.
Pay special attention to those cases in which there are signs of lack of integrity of the persons or entities with which business is conducted, in order to ensure that Repsol establishes business relationships only with qualified individuals and entities with an adequate reputation.
Reflect faithfully and adequately all actions, operations and transactions of the Company in the books and records of the same.
Promote internal training in the prevention and fight against corruption.
1 Corruption: Consistent behavior in bribery, offering or promise to another person holding public office, or to private persons, in order to obtain advantages or benefits contrary to the law or that are of a fraudulent nature.
2 Collaborators: Contractors, suppliers, agents, distributors or free professionals.
3 Good value: Cash or cash equivalent, gifts, loans, gratuities, benefits or benefits of any kind.
4 Facilitation payment: Small amount payment made to people with decision-making powers belonging to the public or private sector, whose purpose is to speed up or facilitate the performance of their responsibilities, such as access to public services, obtaining of ordinary licenses or business permits, administrative procedures and / or unloading of goods.
If the employees have evidence, doubts or suspicions regarding any form of corruption, they should immediately inform their hierarchical superior, the Legal Services or the Group Controller of AICONTROLLER Group. Both the employees of the company and any third party may also transmit their doubts or concerns through the official communication channels of AICONTROLLER.
AICONTROLLER will not tolerate any retaliation against anyone who, in good faith, communicates facts that could constitute a breach of this policy.
Employees who violate these provisions will be subject to appropriate disciplinary measures, including the termination of the contract, as well as other possible actions and / or legal sanctions. Likewise, AICONTROLLER reserves the right to adopt the measures it deems appropriate against employees who fail to comply with it. AICONTROLLER considers that complying with this policy is the responsibility of all its employees.
This policy was approved by the Board of Directors of AICONTROLLER, on January 14, 2019.