This code of ethics provides the knowledge and the implementation of a corporate culture in GRAMA, firmly grounded in the compliance of their values and the innovation of their services. It establishes a set of values and guidelines designed to assure an ethical and responsible behavior for all the people who maintains a working relationship with GRAMA including customers, staff, employees, partners, suppliers and shareholders.

This code of ethics covers the commitment of GRAMA with the values of business ethics and clarity in all scopes, and it also answers to the new treaty obligations of crime prevention in the field of criminal liability of legal entities.

Values and guidelines

Effective management

  • We want to manage our business as effectively as possible through a responsible administration that covers all our activities with full transparency to our staff and partners.

Expertise

  • The people of GRAMA is a very key asset, so we are continuously training and raising awareness of our staff about domestic regulations, laws and good practices.

Value for customers

  • We are highly committed to our services, for providing a high added value to customers because they are the focus of our activities. For this purpose, we are seeking to fit our portfolio as best as possible to their needs, so that we can build a long-term relationship of mutual trust and benefit.

Confidentiality of information and protection of personal data

  • We have communicated to our staff the importance of protecting the held information and knowledge, in addition to the duty to comply the rules of resources uses and security standards established in the internal regulations of GRAMA.

Compliance with applicable laws and internal regulations

  • All employees and partners of GRAMA are required to comply with entity’s rules and procedures and the applicable regulations wherever we carry out our business activities.

Risk management and compliance targets

Following a full risks analysis over our business, we have found out the next compliance targets:

Copyright

To respect and comply with copyrights.

Public Tax Authorities and Social Insurance

To comply with Public Tax Authorities and Social Insurance.

Consumers

Avoid the commission of crimes against the market and consumers.

Environment

Avoid committing crimes against the natural resources and environment.

Assets and patrimony

Avoid committing crime of concealment of assets.

Corruption

Avoid committing corruption crimes between individuals.

Fraud

Avoid committing crimes of fraud.

Bankruptcy

Avoid committing criminal bankruptcy.

Money laundering

Avoid committing crimes of money laundering.

Computer damages

Avoid committing crimes of computer damages.

Secrets

Avoid committing crimes of discovery and disclosure of secrets.

Industrial property

Protect and enforce industrial property rights.

All assumptions that may interfere in achieving these targets are managed by our analysis and risks treatment process and the KRiO software. In that annual procedure, we plan periodic risks assessment of failures, or when relevant changes take place at our business.

In addition to this risk assessment, on March 1th 2016 we have developed a Compliance Statement document version 1.0, which we keep available to all stakeholders that request it.

Our internal regulations

This ethical code was approved by the Manager of GRAMA and published on March 1st, 2016.