Ethics and Good Governance
GRUPO CONCENTRA, by decision of the Board of Directors of CONCENTRA INVERSIONES, S.L., has established a Regulatory Compliance System or "Criminal Compliance", at Group level, which meets the requirements of Article 31 bis of the Criminal Code introduced by Organic Law 1/2015, of 30 March, which amended Organic Law 10/1995, of 23 November on the Criminal Code, and entered into force on 1 July 2015.
The Board of Directors has considered it appropriate to incorporate into the Compliance system essential aspects of the SDG objectives that are inherent and already existing in relation to governance, social responsibility, sustainability, etc., at GRUPO CONCENTRA, as well as the various European regulations on due diligence and sustainability.
In accordance with the above, the Board of Directors of GRUPO CONCENTRA has become aware of the need to adapt the organisation's regulatory content not only to the legal imperative determined by the latest regulatory and corporate standards, but to the ethical and moral principles from which they directly derive, resulting from GRUPO CONCENTRA's commitment to the principles of ethical and regulatory compliance and to the highest standards of security and protection.
The Regulatory Compliance Body of GRUPO CONCENTRA, in compliance with the duty of continuous review, and in view of the latest legal and jurisprudential amendments and the implementation actions carried out by the Company, keeps this Regulatory Compliance System updated.
The Criminal Regulatory Compliance System of GRUPO CONCENTRA, adopted by the Board of Directors, comprises the Compliance Policy Statement, as well as the Compliance Manual, Risk Report and complementary policies and protocols.
Regulatory Compliance Body
The Board of Directors of GRUPO CONCENTRA has appointed a Regulatory Compliance Body responsible for monitoring the operation and observance of the prevention and detection of possible offences, within the framework of the Company's activities, as well as supervising and monitoring the effectiveness of internal controls for crime prevention and compliance with the ethical standards established in the company.
Compliance Policy Statement
The regulatory compliance policy sets out the general principles that inspire the content and that are applicable to all internal regulations of GRUPO CONCENTRA and that affect its members, as well as the actions they carry out.
GRUPO CONCENTRA declares and manifests its commitment to the highest levels of regulatory compliance, as well as to the ethical and moral principles from which they directly derive. Accordingly, compliance with and acceptance of the principles of objectivity, integrity, confidentiality, transparency, neutrality, responsibility, accountability, honesty and anti-corruption agreements are considered to form an integral part of the guiding principles of the Organisation. In accordance with the above, GRUPO CONCENTRA manifests its zero tolerance towards the commission of unlawful acts or, even without violating the law, actions that may be understood as unethical, so that its activity, and that of its personnel, is perceived by all agents that relate to it as being opposed to fraud and corruption in any of its forms, as well as to any other breach or regulatory infringement.
General Code of Conduct or Code of Ethics
Internal code of the Organisation that sets out the basic guidelines and general principles that must govern and be applied in the actions of GRUPO CONCENTRA members. This Code has been conceived in such a way as to function as the "cornerstone" of the compliance culture of GRUPO CONCENTRA, which aims to guide the actions of all its members in the performance of their duties and in their commercial and/or professional relationships.
Communications Channel or Ethics Channel
GRUPO CONCENTRA has enabled an Internal Information Channel (https://grupo-concentra.factorial.es/complaints), as a key and suitable element for supervision, control and prevention, in the field of ethical and regulatory compliance, with the purpose of promoting a culture of transparency, ethics and freedom from conduct involving corruption, fraud or administrative and/or criminal breaches, in accordance with the provisions of Law 2/2023, of 20 February, on "Protection of Whistleblowers".
This channel provides a confidential and secure means for anyone who has a relationship with the organisation to report any suspicious or illegal operation without fear of reprisals.
Anti-Corruption Policy and Conflicts of Interest Management Procedure
GRUPO CONCENTRA has acknowledged the need to have, and adopt as its own, an anti-fraud policy, in accordance with the provisions of international agreements, Article 31 bis of the Criminal Code and Order HFP/1030/2021, of 29 September, which configures the management system of the Recovery, Transformation and Resilience Plan, in accordance with the framework established in Regulation (EU) 2021/241 of the European Parliament and of the Council, of 12 February 2021, establishing the Recovery and Resilience Mechanism.
General Code of Conduct for Third Parties
This Code aims to ensure that GRUPO CONCENTRA collaborators and/or suppliers carry out their business activity in accordance with the General Code of Conduct of GRUPO CONCENTRA and applicable legislation, also avoiding behaviour that may be considered unethical.
Download THE GENERAL CODE OF CONDUCT FOR THIRD PARTIES
Good Tax Practice Policy
Policy that establishes the principles and guidelines for action in tax, fiscal and accounting matters that must be taken into account and applied by GRUPO CONCENTRA members in order to guarantee compliance with applicable regulations.
General Policy for Relationships and Contracting with Clients, Collaborators and/or Suppliers
This policy aims to establish guidelines or models of behaviour complementary to the General Code of Conduct for GRUPO CONCENTRA members when relating to and/or contracting with clients; collaborators and/or suppliers; Public Administration, public entities, authorities, officials or public administrative personnel.
Procedure for Action in Case of Inspection or Administrative Supervision
Document that establishes the procedure for action that GRUPO CONCENTRA members must take into account to ensure compliance with the requests of the inspecting authorities, establishing the commitment to cooperate with said authorities, guaranteeing the protection of the legitimate interests of GRUPO CONCENTRA and its members.
Criminal Action Protocol
GRUPO CONCENTRA has a procedure for action in the event that knowledge is obtained of the alleged commission of a crime committed within GRUPO CONCENTRA or in response to communications or complaints received through the ethics channel implemented for reporting breaches and infringements of internal regulations that could entail criminal liability for the Organisation.
Money Laundering Prevention System
GRUPO CONCENTRA has established a money laundering and terrorist financing prevention system that specifies the internal control measures necessary for compliance with applicable regulations in this area, with the objective of guaranteeing the protection of the financial system in general and GRUPO CONCENTRA in particular against this threat.
Disciplinary System
GRUPO CONCENTRA has established and made known to its personnel a disciplinary system as a means of sanctioning those actions that violate GRUPO CONCENTRA's internal procedures and regulations.
The determination of sanctions has been carried out taking into account the applicable Collective Bargaining Agreements, as well as the provisions of the Workers' Statute and/or specific applicable regulations.
