Definitions
Corruption: Offer, promise, grant, receive, request or accept an unjustified benefit, for oneself or a third party, to unduly favour another in the acquisition or sale of goods, in the procurement of services or in commercial relationships.
Extortion: a person, for profit, forcing another, with violence or intimidation, to carry out or not perform a legal or business action to the detriment of their financial position or that of a third party.
United Nations Global Compact: voluntary corporate initiative that asks companies to endorse, support and put into practice a set of fundamental values in the areas of Human Rights, Labour, the Environment and Anti-Corruption, which are set out in 10 principles.
Facilitation payment: small payment made to public officials in a lower position, whose purpose is to encourage them to expedite or facilitate the performance of their duties, such as access to public services or obtaining licences.
Gift: in a broad sense, in this Policy, it includes the gift itself, freebies, advantages, favours, free items or any other physical present or pecuniary donation.
Bribery: corrupting someone with gifts to obtain something from them.
Our goal
Okodia is committed to strict compliance with the legislation on the prevention and fight against corruption, implementing the principles included in the Code of Ethics and Conduct and extending compliance with this not only to all the employees in our company but also to our commercial partners.
As a defender of the United Nations Global Compact, Okodia undertakes to comply with the ten principles established under that Compact, including working to fight corruption in all its forms, including extortion and bribery (Principle 10).
As a sign of compliance with these principles, the Board of Directors has approved this Policy, which must be understood as an essential tool for avoiding Okodia and the other people within the scope of application of this Policy behaving in a way which is contrary not only to the legislative provisions, but also, where relevant, to the aforementioned fundamental principles for conduct. That is why this Policy governs the actions, including those that are prohibited, whether carried out directly or indirectly or through a person.
Scope of application
This Policy is applicable to Okodia, to its employees, managers and members of the board of directors. They must all be aware of and comply with it. Okodia will encourage its affiliated companies and suppliers to adopt the standards of conduct and values similar to those established in this Policy.
Accepting gifts
Gifts will only be accepted in the cases admitted by social norms, in accordance with the following criteria:
- Gifts may not be accepted if, due to their extraordinary value or the circumstances in which they are made, it can be understood that their reason or purpose exceeds traditional greetings, either for traditional celebrations or for personal reasons (name days, anniversaries, etc.).
- Gifts will not be accepted when they are offered by individuals or companies involved in supplier tender processes.
In any case, the recipient may contact their hierarchical superior if they have any questions regarding this matter.
Giving gifts
It is prohibited to offer or grant any type of gift if the intention is for the recipient to favour Okodia or the person granting it in relation to the procurement of goods or services or in the resolution, management or processing of files or decisions of any nature.
Gifts, freebies or advantages may be offered to third parties free of charge, provided they are those listed in the catalogue approved by the Marketing department.
Extortion, bribery, facilitation payments, influence peddling, political parties and sponsorships
Any conduct that could constitute extortion, bribery or attempted bribery, or a facilitation payment is prohibited, even if it is not intended to result in the obtaining of an undue advantage.
Likewise, any activity that may constitute influence peddling for the purpose of obtaining a decision that may directly or indirectly create a benefit or prevent a loss for Okodia, for the rest of the individuals covered by this policy or for a third party is prohibited.
Okodia will comply at all times with the national regulations on the funding of political parties.
Sponsorship activity is intended to provide economic support for the sponsored parties so that they can carry out their sporting, charitable, cultural, scientific or similar activities in exchange for their commitment to collaborate with Okodia’s publicity activity.
Complaints channel
If employees have evidence, concerns or suspicions regarding any form of corruption, they must immediately notify this to their superior or the Company’s CSR officer.
Any reports made by the people covered by this Policy will be processed through the email address [email protected], respecting the confidentiality of the sender. Okodia will not tolerate any reprisals against anyone who, in good faith, reports facts that could constitute a breach of this Policy. Employees who violate these provisions will be subject to the corresponding disciplinary measures, including termination of their contract, as well as other possible actions and/or legal sanctions.
In the event that complaints or reports of suspicious conduct are raised by customers, this must be processed by email using the address [email protected], identifying the person reporting the query or complaint, detailing the circumstances involved and providing, as far as possible, the evidence or indications that support it. They must also identify the person(s) responsible for the alleged breach.
