CODE OF CONDUCT
The Board of Directors of HENNEO has approved a Compliance Program with the aim of providing the group of companies with the necessary mechanisms for ensuring legal compliance and fostering ethical and responsible behavior among all its members.
As part of the implementation of the Compliance Program, our Code of Conduct (in Spanish) and the Criminal Risk Compliance and Prevention Program are key documents.
Our Code of Conduct, rooted in HENNEO’s Mission, Vision, and Values, is designed to articulate the commitments and criteria governing the behavior of HENNEO and its personnel in the execution of their professional obligations. We aim for these guidelines to be universally embraced and accepted, unwaveringly upheld by all individuals and entities within the group, thereby reinforcing our corporate culture firmly grounded in our values, which include upholding human and societal rights and being conscious of our roles in society as creators of content, information, and opinion, as well as providers of high-quality products and services.
The Code of Conduct has served as the inspiration for the creation and endorsement of the Criminal Risk Compliance and Prevention Program, which embodies the principle of due diligence aimed at preventing, detecting, and eradicating irregular conduct. HENNEO has meticulously designed and implemented control models that evaluate the risks of committing crimes, ensure comprehension of our internal rules, define responsibilities, and establish procedures for confidential reporting and resolution of any irregularities.
To ensure coordinated management of all matters related to crime prevention and compliance with the Code of Conduct, the Board of Directors of HENNEO has appointed the Chief Compliance Officer as the responsible figure for overseeing the Program. The Chief Compliance Officer holds roles of surveillance, advisory, warning, and evaluation of legal management risks in accordance with legal standards. Additionally, an Ethics and Compliance Committee has been established, comprising the Chief Compliance Officer as a permanent member, alongside internal representatives from each business unit and corporate division.
HENNEO employees, as well as any third parties associated with HENNEO in a professional or employment capacity, may utilize the Ethics and Compliance Channel to report incidents, inquiries, crimes, or serious or very serious administrative violations in accordance with applicable law.
All matters related to the exercise of rights, including access, rectification, opposition, erasure, restriction of processing, data portability, and other specific inquiries regarding the processing of personal data, should be directed to the email address firstname.lastname@example.org.
ETHICS AND COMPLIANCE CHANNEL
The Chief Compliance Officer is vested with functions mandated by law, with a specific focus on ensuring compliance with the Criminal Risk Compliance and Prevention Program, as well as all internal regulations governing the Group. Collaborating with the Ethics and Compliance Committee, the Chief Compliance Officer assumes the following core responsibilities:
Continuously update the Code of Conduct, adapting it to the evolving landscape of HENNEO and its affiliated companies.
Supervise compliance with and internal dissemination of the Code.
Address inquiries concerning the application of the Code.
Propose to the Board of Directors any additional regulatory norms necessary for the application of the Code, and ensure the alignment of HENNEO’s internal policies and rules with the Code.
Periodically assess compliance with the Code, prepare an annual report analyzing its implementation level, and propose appropriate corrective measures to the Board of Directors.
The Chief Compliance Officer (CCO) may take initiative independently or in response to requests from any HENNEO employee or a third party with a direct and legitimate interest. To facilitate this, an Ethics and Compliance Channel has been established for reporting incidents, inquiries, crimes, or serious or very serious administrative violations, with the CCO designated by the Board of Directors of HENNEO as the System Manager. For compliance with Spanish Act 2/2023, of February 20th, regulating the protection of individuals reporting regulatory violations and corruption, the CCO is designated as the internal body within the Henneo Group responsible for receiving, admitting, registering, processing, and resolving complaints involving serious or very serious criminal or administrative violations.
These communications should be submitted through https://henneo.canaletico.app/ and will be received and processed with due safeguards by the CCO. Furthermore, data may be disclosed to the company’s Human Resources Officer when disciplinary actions against an employee may be necessary, to legal advisors when legal measures are required concerning reported facts, to designated data processors, and to the Data Protection Officer.
The CCO and the Ethics and Compliance Committee will ensure:
Confidentiality of all data and background information reported, unless compelled by law or judicial requests. Reports shall remain confidential, and anonymity shall be respected if so desired by the informant.
Comprehensive analysis of the information underlying their actions.
Initiation of appropriate procedures, always acting independently while fully respecting the right to a fair hearing and the presumption of innocence for any affected parties.