Code of ethics and conduct

Message from the Chairman

In a complex, globalized and constantly changing environment, Kreab is in direct contact daily with many different interlocutors: companies, employees, citizens, media, associations, political and institutional spheres, etc., with whom we exchange relevant information. The values of Excellence, Commitment, Respect, Integrity and Transparency are the fundamental pillars of our work, and we must make them the first priority for all of us at Kreab when making decisions with all of the aforementioned stakeholders.

As Kreab’s management is aware of the need to establish the appropriate measures to ensure the best compliance with these values, as well as the maximum observance of all national and international regulations, Kreab’s Code of Ethics and Conduct has been drafted.

This Code is the result of intensive work in order to identify potential risks and develop the most appropriate policies to prevent them from occurring in our organization and, in any case, to try to mitigate them as much as possible by establishing working guidelines in many different areas.

Kreab’s Code of Ethics and Conduct is a living document that must be observed by all Kreab employees, regardless of their position. An internal body, the Compliance Committee, has been set up to ensure understanding and acceptance of the rules, principles, and values to be observed and to ensure compliance. This committee will contribute to perfecting, updating, and promoting the entire culture of business ethics and compliance, which will be reinforced by the Ethics Channel, which will ensure that any complaints, doubts of interpretation or concerns raised are dealt with in accordance with the provisions contained in the Code of Conduct and each of the policies developed.

We firmly believe that the success of this policy lies in our ability to participate and create a dialogue for the internal improvement of management processes. In this sense, I encourage each of you to be a leader in ethics and transparency in each project in which you participate.

As President and CEO of Kreab Iberia, I will personally promote this project, which places our values at the heart of our work and our business interests.

Eugenio Martínez Bravo




We have established this Code as a framework that will serve as a guide for the entire Company, setting out the various values and principles that will be a point of reference for Kreab when making decisions.

The purpose of the Code of Ethics is to provide our professionals and other external agents who interact with the company daily, regardless of the level of responsibility they have in the company, with a set of behavioural guidelines to be followed in order to act in accordance with the spirit of the company.

In this way, our professionals will be able to respond to the trust placed in us by our clients with a performance based on honest, conscientious, and ethically acceptable conduct, always seeking the satisfaction of all parties involved, our employees and our clients and partners.

At Kreab we deliver our services in accordance with these ethical principles. To effectively comply with the Code, the company provides its professionals with a Compliance Committee, which will act as an autonomous and independent internal body, assisting them in the implementation of the corporate values.

This Code is addressed to Kreab’s entire professional team, including both the company’s managers and all employees of the company, so that performance at all levels is in line with the same corporate culture. We will also make every effort to make our Code known to all our customers, suppliers, and other stakeholders, so that they have an effective understanding of the nature and essence of Kreab.

Scope of this Code of Ethics and Conduct

This Code sets out how we should behave towards

– Our employees or those who work with us.

– Our customers.

– The environment in which we operate.

– Our value chain partners, including our suppliers.

– Our joint venture partners and other business associates.

– Our stakeholders.


Values that inspire us

Kreab’s values should inspire everything we do. We are a diverse team in which each consultant has his or her own personal working style, but the following values are the hallmark of Kreab in every service we provide and every decision made in our professional performance:

– Excellence: We are committed to excel and to always be our best version in a rapidly changing environment. We strive for the highest quality in every project we are involved in.

– Commitment: Our work must always be in accordance with the principles set out in this Code, rejecting any proposal that goes against what we believe in.

– Respect: We strive to understand the environment around us in order to develop a behaviour that takes into account the different sensitivities of all those who interact with our company.

– Integrity: In order to offer the highest quality in every service we provide, we are committed to providing sound and rigorously independent advice, and we strive to maintain the reputation we have built over the years.

– Transparency: As far as possible, and provided that confidentiality and professional obligations do not prevent or discourage it, we share information with our clients to help them make informed decisions.


Our objectives

Our main objective is to offer excellent services to the clients who have placed their trust in us, by providing them with advice that achieves their complete satisfaction.

As a company which our clients trust, we must reward this trust with an excellent service.

All employees have to be committed and make their best efforts to:

– Make customer service a priority, taking care to communicate with customers to understand their concerns and needs.

– Not to work in series, treating each assignment as unique and adapting our proposal to the reality and possibilities of each case.

– To be transparent with the client and to be their collaborator in the search for solutions based on an honest and realistic approach.

– Always strive to exceed the client’s expectations to maintain their trust.


Our principles of conduct

The business and professional conduct of our entire team is governed by the following principles in which we all believe:

– Legal compliance

– To carry out our work in a professional manner, acting with diligence, responsibility and efficiency, always striving for excellence.

– To be guided by honesty and ethics.

– To act and make decisions that are not only ethically and legally acceptable, but also positive for the environment in which we operate.

– Respect for human and labour rights.

– Respect for intellectual and industrial property and the use and protection of assets.

– Protection of the assets provided by the company for work performance.

– Non-discrimination and equal opportunities.

– Respect the privacy and confidentiality of employee and customer information.

– Help maintain a safe and healthy working environment.

– In case of any doubt, consult and inform the appropriate manager of any legal, criminal or administrative sanction proceedings related to Kreab that could damage the image, interests or reputation of the Company.

– Avoid engaging in any activity or relationship that could lead to a conflict of interest.


Conflicts of interest

Kreab believes that independence is a key element for objectivity in the development of our work. Therefore, in the event of any circumstance that threatens or could potentially pose a threat to the independence of the Company in any of the activities it undertakes, or present a risk to any of the entities that may be in a situation of conflict of interest, we are committed to working to resolve them and, where appropriate, to avoid them.

To this end, we have established a policy for the resolution of such conflicts. This policy sets out several mechanisms and procedures to help our employees identify any actual or potential conflicts of interest that may constitute a risk to the objectivity of our team, and to help our Company resolve such situations in the most satisfactory manner possible for all parties involved. It also sets out the procedures to be followed in the event of a potential conflict of interest, from reporting it to the Compliance Committee through to its resolution.

If employees are in doubt about how to identify or act in the event of a conflict of interest, they can direct their questions to the Company’s Ethics Channel (


Types of conflicts of interest

– Between Kreab’s clients and Kreab itself or an employee, officer, or director of Kreab: when any of them may gain an extraordinary advantage or avoid a particular loss at the expense of the client.

– Between Kreab’s employees, officers and directors with respect to clients: instances of insider trading or use of confidential information by the persons concerned.

– Among Kreab’s own clients, in relation to potential conduct consisting of allowing a client to receive preferential treatment over other clients, thereby preventing the service from being provided fairly and to the detriment of other clients.

– Between Kreab’s own clients, where advising clients with conflicting interests could result in one of them being disadvantaged.

– Between different business areas of Kreab, conflicts may arise due to the different activities of each area, which may result in a particular area not acting objectively.


Confidentiality, privacy, and insider trading regulations

As a consultancy and advisory firm, we at Kreab understand that respecting the confidentiality of information and the privacy of both our clients and our employees is an essential part of our daily performance.

As of 25 May 2018, the new Data Protection Regulation applies. EU Regulation 2016/679 harmonises data protection legislation across the European Union and increases the protection of individuals regarding the processing of personal data and the free movement of such data. Likewise, since 7 December 2018, Organic Law 3/2018, of 5 December, on the protection of personal data and the guarantee of digital rights, has been applicable.

Therefore, based on the respect for the rights of the subjects indicated in this regulatory framework, we have updated our Privacy Policy to adapt it to the new regulation.

Kreab declares its firm commitment to safeguard Inside Information of which its employees have knowledge by virtue of their position or professional activity, who shall at all times, refrain from carrying out any kind of transaction on the securities or financial instruments to which the Inside Information refers.  Or on any other security, financial instrument or contract of any kind, whether or not traded on a secondary market, underlying the securities or financial instruments to which the Inside Information refers, on the basis of such information.

This duty of confidentiality includes the obligation not to:

– Disclose such inside information to third parties, except in the normal course of their work, profession or position.

– Recommend to a third party any particular transaction on transferable securities based on such inside information.

For any questions on how to handle situations related to confidentiality, privacy and insider trading regulations, employees may direct their inquiries to the Company’s Ethics Channel (


Anti-corruption and illegal activities

At Kreab, we believe that transparency is at the heart of our relationship with our employees, customers, and other stakeholders. By continuously strengthening its ethical culture and control systems, Kreab actively collaborates in the fight that, as a civil society, we must sustain against corruption, through policies oriented towards the implementation of transparency and integrity developed by Kreab itself, as well as by the legislative power and society at large.

In this sense, all of us who work in Kreab will make every effort to prevent the commission of illegal activities within its sphere of activity, as well as to maintain a firm attitude, both internally and externally, against any type of action that undermines coexistence and the legal system.


Human Rights, Diversity and Non-Discrimination

Kreab is a diverse organisation made up of people of different nationalities, ethnicities, religious beliefs, sexual orientations, and identities. We firmly believe that this diversity is not only a value to be respected, but an asset that enriches us and benefits our professional activities.

For this reason, we believe that, as a corporate citizen, we must not only work every day to promote respect for human rights and non-discrimination, but also promote active policies to raise awareness among social actors, both internally and externally, regarding the need to respect these rights as a common rule that we impose on ourselves to improve society as much as possible.

If any of these rights are undermined, Kreab has a “Plan for the Prevention of Workplace Harassment” aimed at preventing any discrimination from occurring within our sphere of influence, through which we establish a commitment of the company to avoid any circumstance that prevents a peaceful and respectful coexistence with the rights of all, regardless of their origin, gender, ethnicity, sexual orientation or religious beliefs.



At Kreab, we believe it is necessary to understand that the environment is not the problem of a few or the exclusive responsibility of public administrations or, if you will, of the organisations and agents entrusted with protecting it. On the contrary, the environment concerns the whole of society. Therefore, Kreab collaborates with these social agents trying to preserve, within its sphere of influence, the environment that sustains us all, in the most appropriate way possible, with an environmental perspective and an ecological conscience that translates into a way of doing things that always respects and cares for our planet.

Fair labour policies

At Kreab we are aware that our greatest assets are the professionals who work every day to provide the best service to our customers. Therefore, we strive to develop work policies, both in terms of recruitment and labour relations and work environment, aimed at building a company where it is not only pleasant to work, but where our employees have the certainty that each and every one of their rights in labour matters are respected, not only as a result of law compliance, but also from our  firm belief that a team working in a pleasant and safe working environment is essential for us to achieve the success of the goals we have set.



At Kreab, we believe that in addition to our collective responsibility as a consulting firm, each of us in the Kreab team has an individual responsibility to comply with this Code. Therefore, all of us at Kreab, regardless of our position, must adhere to the ethical framework described in this Code.

For this reason, all Kreab employees expressly adhere to the Code by signing it and reaffirming their commitment at any time to any future updates,

Those who hold managerial positions in the company, by virtue of the additional responsibilities that their position entails, are primarily responsible for setting an example with their actions and conveying what it means to apply in practice all the principles and guidelines of the Code, encouraging and helping all the professionals under their responsibility to understand and assimilate what it implies.


Gift policy.

Kreab does not accept or give gifts or entertainment to customers outside the parameters set out below.

The value of any gift or entertainment given or received by Kreab employees and officers shall be less than or equal to EUR 100 per customer or supplier. Regardless of the value, Kreab employees and officers may not give or receive gifts that could potentially influence business or be considered an improper acceptance or bribe.

Officers and employees who give gifts must obtain them through the applicable purchasing policy and they must be duly recorded in Kreab’s accounting, without exception.

If in doubt about how to proceed with respect to Kreab’s gift policy, employees may direct their questions to the Company’s Ethics Channel (


Ethics channel and compliance committee

This Code implies a commitment on the part of Kreab’s professional team to conform their daily behaviour to the framework of rules, principles and core values contained therein.

However, situations of conflict or doubt or uncertainty may arise daily for the company’s professionals.

To provide them with a support mechanism to ensure that their behaviour is ethically appropriate, Kreab has set up a communication channel and an internal body (Ethics Channel and Compliance Committee) to help them:

– Resolve any doubts that may arise.

– Communicate any type of incident or warning of potential non-compliance.

– Submit opinions or suggestions of any kind.

Employees wishing to communicate with the Ethics Channel should use the following email address:

The information received in this mailbox will be seen only by the members of the Compliance Committee. The members of the Compliance Committee will be fully aware of the Code and all applicable rules relating to good business practice and will be responsible for assessing and, where appropriate, reporting any inappropriate behaviour so that the Company can take appropriate action in this regard.

Given that in certain cases the information sent to the Ethics Channel could have a negative impact on whoever discloses it, the members of the Compliance Committee undertake, by means of a statement endorsed by their signature, not to disclose the identity of the person providing such information under any circumstances, guaranteeing the confidentiality of their identity at all times and dealing with the case without reporting it, focusing on the content of the complaint, consultation or incident reported.

The Compliance Committee undertakes to improve, update and promote the Company’s entire ethical culture and regulations (including this Code), ensuring that future updates incorporate the lessons learned from the consultations and communications received.


Compliance with the Code

As stated throughout this Code, being a part of Kreab means sharing its principles and values, therefore our entire team is committed to complying with the Code and ensuring its correct development by its express acceptance and signature of all who make up the Kreab team.