Code of Conduct

Codan group

The purpose of this Code of Conduct is, in addition to meeting the current regulatory environment, to reaffirm the principles of action and values that must govern the business activity and actions of all persons, natural and legal, related to the Codan Group, and who are included within the group's scope of action, whether they are employees, governing bodies, managers, service providers, collaborators, independent professionals, shareholders or participants, being of obligatory compliance for all of them, as well as being obliged to collaborate for said compliance.

The aforementioned principles are complementary to the legislation established or to be established and applicable.

The Codan Group guarantees equal treatment, rejecting any type of discrimination on the grounds of age, gender, race, colour, religion, sexual orientation, social condition, marital status, nationality, political opinion or family responsibilities, defends the fundamental rights and principles of people, guarantees health and safety at work, and decent and fair working conditions, in accordance with the legislation in force. It ensures compliance with working and rest time, and promotes a healthy working environment where harassment is not tolerated in any of its forms or expressions.

Codan Group, its directors, governing bodies, employees and collaborators must act at all times committed to maintaining a safe working environment, with equal opportunities, and with full respect for people's dignity, ensuring and committing themselves to avoid any harassing, hostile, offensive, intimidating, abusive or abusive behaviour or behaviour that could damage reputation, and must be reported immediately.

Codan Group guarantees the veracity and transparency of its financial information in accordance with the applicable accounting principles, and complies with tax regulations. The information disclosed is truthful, accurate and complete. Its activities and relationships are completely lawful, and intolerant of fraud, not admitting actions that involve the use of the business activity to launder money, ensuring that any income comes from lawful and legal activities, and applying due diligence in order to mitigate the risk of money laundering and the financing of terrorism.
Codan Group acts to ensure that its relations with third parties do not involve a conflict of interest, rejecting any situation or behaviour involving bribery, corruption, fraud, or any circumstance involving influence on a business decision, as well as not taking advantage of information, goods or services for personal benefit or for the benefit of a third party. The directors, employees and collaborators of Codan Group will abstain from carrying out actions in which their personal interests prevail over the interests of Codan Group.

Codan Group maintains a constant commitment to the Environment, ensures the correct compliance with the environmental legislation applicable to its activity, acts with respect and protection of the environment, developing its activity in a sustainable way, and adopting preventive and active measures to reduce and improve the impact related to its activity, as well as favouring circularity criteria, and promotes the reduction of emissions and waste, and the increase of recycling.
Codan Group guarantees the confidentiality of the personal information provided by the managers, employees and collaborators, who are in turn obliged to maintain the secrecy of the information they receive, or of which they may have access with such confidential or sensitive nature, even after the termination of relations.
Codan Group respects the current legislation on personal data protection, privacy, confidentiality and security, carrying out the protection in accordance with the Data privacy policy and is committed to non-disclosure without the express consent of the interested parties, unless such disclosure is legitimate according to the current regulations.
The directors, employees and collaborators of Codan Group undertake to keep secret the confidential information to which they have access due to the development of their activities.

Communications channel

Codan Group has implemented a COMMUNICATIONS CHANNEL, managed as an Internal Information System for the prevention of infringements in all its spheres of influence.

This Internal Information System is an anonymous, confidential and secure channel through which any conduct, act or omission contrary to the principles contained in this Code of Conduct, or inappropriate conduct, irregularities and infringements can be reported, as well as complaints and queries.

The Internal Reporting System implemented is available at the following link: COMMUNICATIONS FORM.

Communications may be submitted in writing through the form contained in the link indicated, or may be made verbally by requesting it through said form.

The Internal Information System implemented guarantees the confidentiality of the identity of the informant and of any third party mentioned in the communication and in subsequent actions, their data being protected. Likewise, the person to whom the communication refers shall not be informed of the identity of the informant, except in cases of strict necessity or in the framework of legal proceedings. However, anonymous reporting is also possible.

Whistleblowers shall be protected from any act of reprisal, which shall be deemed to be any act or omission involving unfavourable treatment.

Whistleblowers shall have at their disposal at all times any advice they may require on the use or for the use of this Internal Reporting System.

The general principles governing the operation of the Internal Information System in place guarantee respect for fundamental rights, the legal security of the system, accessibility, confidentiality and respect for the principle of minimum intervention, the prohibition of reprisals, impartiality and the presumption of innocence.

The actions or omissions, and in general the behaviours with non-observance of legality and/or contrary to the Code of Conduct, as well as to the internal regulations of Codan Group, will give rise to the application of the corresponding sanctioning regime, according to the seriousness of the non-compliance.

The data provided or obtained in the procedures corresponding to the Internal Information System, will be treated by Codan Group with the strictest compliance of the legislation on personal data protection.

The communications referred to herein, and consisting of actions or omissions that could constitute infringements of the European Union Law, or that could constitute a serious or very serious criminal or administrative infringement, including those that imply economic losses for the Public Treasury and for the Social Security, can be made through external information channels, before the Independent Authority for the Protection of the Informant, A.A.I., or before the corresponding authorities or autonomous bodies, either directly or after previous communication through the corresponding internal channel.

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