Code of Ethics and Conduct

Why the Code of Ethics and Conduct


Grupo Avintia’s Code of Ethics and Conduct constitutes the company’s express declaration of the values, principles and rules all of the Group’s managers and employees must follow in the responsible performance of their professional activity and relationships with other employees, managers, clients, suppliers and external collaborators, shareholders, public and private institutions and the general public.

“The purpose of this code is to establish a series of general conduct guidelines which will guide Grupo Avintia’s employees on how to act while carrying out their professional activity”

The conduct criteria established in this Code do not attempt to address all possible situations in which Grupo Avintia’s employees may find them selves. It does, however, establish a series of general conduct guidelines which will guide them on how to act while carrying out their professional activity. In order to do this, the purpose of theCode is to prevent any criminal and unlawful actions from being committed by any and all individuals subject to this Code.

Question: Why does Grupo Avintia have a Code of Ethics and Conduct?

Answer: This Code of Ethics and Conduct was born from my strong conviction, as president of Grupo Avintia, of the need to manage the company in an ethical and responsible way, thus ensuring its long-term sustainability and profitability.


Scope of Application

These rules must be complied with by all of Grupo Avintia’s employees (and, therefore, all employees who work for the companies belonging to the Group) regardless of the type the position they hold in the company.

Moreover, Grupo Avintia will promote and encourage the adoption of behaviour guidelines similar to those defined in this Document by its suppliers and collaborating companies.

When establishing business relationships with other companies or professionals, one of the selection criteria will be that said companies and professionals have adopted principles of management and conduct similar to those established in this Code.



“These rules must be complied with by all of Grupo Avintia’s employees”

The Code of Ethics and Conduct is in force in all national and international markets in which the Group or any of its subsidiaries carry out their business activities. It must be applied both in Spain and abroad, always taking any legal, cultural, societal and economical differences from the various countries in which Grupo Avintia operates into consideration.


General principles and values


What do we want our interactions to be like and how do we want to be considered by those who surround us?


One of Grupo Avintia’s goal sis that each and every individual and entity subject to this Code complies with the ethical principles laid out below in all of their relationships with their employees, the market and the society in general.

  • Contribute to social and economic development, always acting in a responsible and upstanding manner.
  • Provide good working conditions.
  • Comply with and respect all the applicable national and international legislation.
  • Respect all human rights and public liberties recognised in the United Nations’ Declaration of Universal Human Rights. Contribute to both social and economic development through technology and innovation, the efficient and responsible use of resources and competition.
  • Promote sincerity, equality, truthfulness, honouring commitments and transparency.


Compliance Committee

Grupo Avintia’s Compliance Committee is an autonomous, collegial and independent entity comprised of representatives of the various areas which make up the Group and who are appointed by the Board of Direction. Its main duties are:

  • Implement, monitor, supervise, evaluate and improve the methods used to prevent and detect criminal activity.
  • Safeguard the principles, values and guidelines of behaviour established in this Code of Ethics and Conduct.
  • Ensure the proper operation and management of the ¡Dilo! channel.

“The compliance committee of Grupo Avintia watches over the confidentiality of the ¡Dilo! channel”



The ¡Dilo! Channel


The doubts, questions and claims made via the ¡Dilo! channel contribute to the detection of possible criminal activity and are a way for the Code of Ethics to be fully implemented, constantly improving the prevention system.

“Don’t think that you are acting in the best interests of the company when you hide an action or incident. The positive thing for the company is not to hide the negative aspects but to address and resolve them.”



Question: Will my supervisor find out that I’ve notified the ¡Dilo! channel of a wrong doing?

Answer: No, absolutely not. Our internal communication channel is completely confidential. To ensure such confidentiality, the Compliance Committee has agreed to hire a company specialized in handling these services, therefore, your communication will never reach your supervisor.




Is it in line with Grupo Avintia’s values? Have you been asked to do something you believe is wrong and could damage the company? Are you aware of any unethical or possibly illegal conduct carried out by the people surrounding you such as colleagues, clients, suppliers, etc.? Do you have to make a decision but aren’t sure what ethical consequences are involved? What would happen if you saw this published in the media?




Ask yourself who will be affected. Yourself? A colleague? Third parties related with the company?

What guidelines should you follow? Does it adhere to professional standards? And to the Group’s values? Is there any legislation regarding this issue? Is it illegal? How do you think clients or other third parties related to the company would react?




What are your options? What are the most probable results of each? Are there any alternative solutions which don’t imply an ethical conflict? You should ask for any assistance and advice needed in order to be able to make the best decision.




Test your decision with the following questions. How do you feel? Are you bothered by the results? Would you feel uncomfortable if others knew what you did? Ask for further advice if needed and only take action when you are completely sure of your decision and your good intentions.




Present your concerns to the Compliance Committee via the ¡Dilo! channel or directly to the company’s compliance department. Talk about it and weigh all the variables with experts from the sector as much as you need. Think about what you’ve learned during the process and if there is any aspect of it that needs to be changed.

How to decide what’s right


Here at Grupo Avintia, we are completely sure of our principles and values and are 100% committed to them.

All of our actions must be completely in line with these ethical values and principles. While this Code of Conduct may not contemplate all of the possible situations our employees my encounter in their day-to-day activities when carrying out their professional duties as employees of the company, it does attempt to provide a guide which will assist them in make decisions in potentially conflictive situations or ethical dilemmas within the established legal framework and in accordance with our morals and ethics.

For this reason, we offer the following outline as another tool which can help employees make decisions. It must be remembered that this is not an all-inclusive tenet and that each situation must be evaluated individually, considering the specific context in which it occurs. If you have doubts, don’t hesitate to ask ¡Dilo! for help.


Question: Who must comply with this Code?

Answer: Anyone who is part of any of Grupo Avintia’s companies, regardless of the delegation or if they are part of the companies’ staff or hired by an external third party.

Question: Facing a situation of conflict, what does the Code of Ethics recommend to me?

Answer: In a situation that makes us doubt, we must ask our selves the following questions:

Is it legal?

Is it in line with our values and our Code?

Do I feel confortable with the way I proceed?

Would I feel good with the way I actif it was broadcasted on the media?

Question: If I have doubts about the legality of an action or the repercussion it may have on the reputation of the company, what should I do?

Answer: First, talk to your superior. If that is not posible or they can’t clear your doubts, take it to the department involved in the action. If foustill have doubds contact the Compliance Committee or the ¡Dilo! channel.

Question: Can someone from Grupo Avintia access my data?

Answer: No, the only person who can access the data is the compliance officer (with the prior consent of the user), who, together with the Compliance Committee, ensure that the identity of the user is protected.

These videos pretend to answer the frequently asked questions about our Code of Ethics and Conduct. However, if you have any other query do not hesitate in using the channel ¡Dilo!


Download Grupo Avintia’s CODE OF ETHICS AND CONDUCT

Integrity: the DNA behind our conduct