Code of ethics and conduct
In a complex, globalised and constantly changing environment, Kreab is in daily contact with various stakeholders: companies, employees, citizens, media, associations and political and institutional fields etc…, with who we manage relevant information. The values of Excellence, Commitment, Respect, Integrity and Transparency are the fundamental pillars of our work and they must be placed as Kreab’s first reference point in the decision-making for all these actors.
As Kreab’s management is aware of the need to establish the appropriate measures to allow for the best compliance with the stated values, as well fully observing all national and international regulations, the Kreab Code of Ethics and Conduct has been drawn up.
This Code was born after the intense task of identifying potential risks and developing the most appropriate policies to try to prevent them from arising in our organization and, in any event, try to mitigate them to the greatest extent possible, establishing work guidelines in very different areas.
The Kreab Code of Ethics and Conduct is a living document requiring mandatory compliance by all Kreab staff, regardless of their position. In order to try to guarantee the understanding, the acceptance of the basic norms, principles and values to be followed, as well as to ensure compliance, an internal body called the Compliance Committee has been established. This Committee will refine, update and promote the entire business ethic culture and oversee compliance with the regulations that aim to improve its functioning. This will be reinforced by the Ethics Channel, which ensures that all allegations, queries or concerns raised are addressed as laid down in the Code of Conduct and in each one of the developed policies.
We firmly believe that the success of these policies lies in our capacity to participate and create a dialogue for improving internal management processes. With this in mind, I encourage each and every one of you to be a leader in the field of ethics and transparency in all of the projects in which you participate.
As CEO and Managing Director of Kreab Iberia, I personally promote this project, which positions our values at the heart of our work and our commercial interests.
Eugenio Martínez Bravo
We have established this Code as the framework that will serve as a guide for the whole team that makes up this Company, putting in place the different values and principles that are Kreab’s reference point in decision-making in all circumstances.
The goal we pursue through the Code of Ethics is to provide our professionals and other external agents that interact daily with the Company, independent on their level within the Company, a series of behavioural guidelines to be observed, resulting in actions akin to the spirit of it.
Thus, our professionals will respond to the trust in our surroundings, through performance based on honest, diligent and ethically acceptable conduct, always seeking the satisfaction of all parties involved, our employees, our customers and partners.
At Kreab we provide our services in a manner consistent with these ethical principles. For the effective compliance of the Code, the Company places at the disposal of its professionals a Compliance Committee that will act as an autonomous and independent internal body, guiding them to the proper execution of corporate values.
This Code is aimed at Kreab’s entire professional team, including Company administrators as well as all employees, so that performance at all levels is in tune with the same corporate culture. In addition, we will employ our best efforts so that all our clients, suppliers and other stakeholders are aware of our code giving an effective understanding of Kreab’s nature and essence.
Scope of the Code of Ethics and Conduct
This Code sets out how we behave with:
- Our employees or those who work with us.
- Our clients.
- The environment in which we develop our activity.
- Our partners in the value chain, including our suppliers.
- Our partners in investee companies and other trading partners.
- Our shareholders.
Values that inspire us
Kreab’s values must drive all our activity. We are a diverse team in which each consultant has their own personal work style, with the following values that make up Kreab’s seal on each service and decision made in our professional duties:
- Excellence: We are committed to excelling and always being in our best form in a rapidly changing environment. We seek the highest quality in each project in which we are involved.
- Commitment: Our work must always be consistent with the principles in this Code, rejecting any proposal that opposes what we believe.
- Respect: We strive to understand the environment that surrounds us to develop a behaviour that takes into consideration the different sensitivities of all who are related to our company.
- Integrity: To provide the highest quality in any service that we provide, we work to offer advice that is solid and thoroughly independent, in order to keep up the reputation we have achieved over the years.
- Transparency: We share to the highest extent possible, and provided that confidentiality and competition principles do not discourage it, information with our clients, aiding them to make informed decisions.
Our main objective is the excellence in the provision of our services to clients who have placed their trust in us, through advice that completely satisfies them.
As we are a Company trusted by our clients, we must reward that confidence with excellent service. As employees we promise to do everything possible to:
- Give priority to the attention of the client, caring for the communication with them to understand their concerns and needs.
- Do not work serially, take on each assignment uniquely, and adapt our proposal to the reality and possibilities of each case.
- Be transparent with the client and be their partner in the search for solutions based on realism and honesty.
- Always seek to exceed client expectations as a basis to preserve their confidence.
Our Principles of Behaviour
The business and professional behaviour of our entire team must be subject to the following principles in which we all believe:
- Compliance with the law.
- Be professional whilst carrying out our work, acting with diligence, responsibility, efficiency and always pursuing excellence in results.
- Make honesty and ethics a guide for our actions.
- Adopt a form of action and decision making that is not only ethically and legally acceptable, but is also positive for the environment where we develop our activity.
- Assume the responsibility of each and every one of our acts, as individuals and as a company.
- Respect Human and Labour Rights.
- Respect the Intellectual and Industrial Property.
- Protect and care for the assets and materials provided by the company for work activities.
- Do not discriminate and offer equal opportunities.
- Respect the privacy and confidentiality of the information of employees and clients.
- Contribute to maintaining a safe and healthy work environment.
- In case of any doubt of any judicial, administrative, or criminal procedure of a sanctioning nature related to Kreab, that could harm the image, the interests or the reputation of the Company always consult and inform the corresponding superior.
- Avoid participating in activities or relationships that may cause a conflict of interest.
Conflicts of interest
At Kreab we consider that independence is a capital element for objectivity in the development of our work. Therefore, before any circumstance that involves, or may potentially pose a threat to the independence of the company, in any of the activities it develops, we are committed to work to resolve them and, where appropriate, avoid them.
To do this, we have provided a resolution policy of such conflicts, for a further guarantee of complete impartiality in the decision-making of our employees.
This policy establishes a series of mechanisms and procedures that serve to help our employees identify and resolve any conflicts of interest, real or potential, which constitute a risk to the objectivity of our team. Furthermore, action processes are established in the face of a possible conflicts of interest, from making it known to the Compliance Committee until their resolution.
If you have questions on how to identify or act in the event of conflicts of interest, employees can send queries to the company’s Ethical Channel (to the e-mail address: firstname.lastname@example.org).
Types of conflicts of interest
- Among clients of Kreab and Kreab itself, or any employee, director or administrator of the same: when any of them can obtain a special benefit or avoid a certain loss at the expense of the client.
- Among employees, managers and administrators of KREAB, with respect to clients: use of privileged or confidential information by the subject persons.
- Among the clients of KREAB: in relation to the potential behaviour of giving a client preferential treatment compared to the rest making the service provided unequal, and detrimental to other clients.
- Among KREAB’s own clients: when the advice to clients with conflicting interests could be detrimental to any of them.
- Among different areas of KREAB: situations in which within KREAB, due to the different activity areas, may generate conflicts making a particular area not act objectively.
Confidentiality, privacy and regulation of the use of privileged information
As a Company dedicated to consulting and advising, Kreab understands as a vital part of our daily performance, the respect for confidentiality and privacy of information, both of our clients and our employees,.
The new data protection regulation is applicable from May 25, 2018. The regulation EU 2016/679 harmonises the legislation on data protection throughout the European Union, increasing the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
Kreab declares its firmest commitment to the safeguarding of Privileged Information of which its employees have knowledge of as a result of their position or professional activity, and who, at all times, shall refrain from carrying out any type of operation on the tradeable securities or financial instruments to which the Inside Information refers, or any other security, financial instrument or contract of any kind, whether or not traded on a secondary market, which has as its underlying the negotiable securities or financial instruments to which the Inside Information refer, based on such information.
In this duty of abstention, the obligation also includes not to:
- Communicate Privileged Information to third parties, except in the normal exercise of work, profession or position.
- Recommend to third parties transactions on securities based on such Privileged Information.
In the face of any doubt about how to manage situations related to confidentiality, privacy and regulations of the use of Privileged Information, employees can send queries to the Company’s Ethical Channel (to email address: email@example.com).
Fight against corruption and illegal activities
At Kreab we believe that transparency is the basis of our relationship with our employees, clients and other stakeholders. Through the continuous strengthening of its ethical culture and its control systems, Kreab actively collaborates in the struggle against corruption that, as a civil society, we must fight against, through the implementation of policies oriented towards transparency and integrity that Kreab itself develops, as well as those from the legislative power and social good.
Thus, Kreab employees will do their best to avoid the commission of illegal activities in their field of action, as well as maintaining both internally and externally a strict attitude against all types of actions that undermine coexistence and the legal system.
Human Rights, diversity and non-discrimination
Kreab is a diverse organization, made up from people of different nationalities, ethnic groups, religious beliefs and sexual orientation and identity. We firmly believe that this diversity is not only a value to be respected, but an asset that enriches us and benefits our professional activity.
Therefore, we believe that, as a citizen company, we mustn’t just work every to respect Human Rights and non-discrimination, but promote active policies to raise awareness, both internally and externally, to social agents of the need to observe those Rights, as a common rule that we set ourselves to improve society as much as possible.
Should any of these rights be undermined, Kreab has a “Workplace Harassment Prevention Plan”, aimed at preventing any discrimination from occurring within our sphere of influence, through which we establish a commitment by the Company to avoid any circumstance that prevents a peaceful coexistence which respects the Rights of all, regardless of their origin, sex, ethnicity, sexual orientation or religious belief.
At Kreab, we understand the importance that Environment is not just the problem of a few, or the exclusive responsibility of the Public Administrations or, better put, of the organizations and agents entrusted with the task of its protection. But, on the contrary, we believe that the environment concerns the whole 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, englobing an environmental point of view and ecological conscience in all its activity which translates into a way of doing things whilst always caring for our planet.
Fair labour policies
At Kreab we are aware that our greatest asset is the professionals who work every day to provide the best service for our clients. Therefore, we strive to develop work policies, in terms of recruitment as well as labour relations and work environment, aimed at building a company of which not only is pleasant to work for, but one in which our employees are certain that each and every one of their rights in labour matters are respected not only from a compliance with the standard point of view, but also from the firm belief that a team that works in a pleasant and safe work environment is essential for us to achieve success in the objectives that we set.
At Kreab we believe that, in addition to having a collective responsibility as a consulting company, all of us who form part of the Kreab team have an individual responsibility to observe compliance with this Code. Therefore, all of us who make up Kreab must, regardless of the position we hold, comply with the ethical framework described in this Code.
Thus, all Kreab employees will adhere to it expressly, and their commitment to compliance is reiterated at any time in the event of future updates that may be developed.
Those who occupy management positions in the Company, due to the additional responsibilities entailed by their position, are the main ones in charge of setting an example with their actions and transmitting what it means to apply in practice all the principles and policies of the Code, promoting and helping all professionals in their charge to understand and assimilate what it contains.
Kreab does not receive or grant gifts or attention to clients outside the parameters expressed below.
The value of any gift or entertainment given or received by Kreab’s employees and managers must be less than or equal to 100 euros per client or supplier. Regardless of their value, Kreab workers and managers will not give or receive gifts that could potentially influence the business or be considered as an undue acceptance or bribe.
The managers and workers who give gifts, must obtain them through the current purchasing policy, leaving them duly registered in Kreab’s accounts, without exception.
If you have any questions about how to proceed with regard to Kreab’s gift policy, employees can send their queries to the Company’s Ethical Channel (firstname.lastname@example.org).
Ethical Channel and Compliance Committee
The present Code implies the commitment from the professional team of Kreab in its daily behaviour to adhere to the framework of norms, principles and basic values contained in it.
However, in day to day life, situations of conflict, or ones that generate doubts or uncertainty for the professionals of the Company may take place.
To provide them with a support mechanism that ensures that their behaviour is ethically adequate, Kreab has established a communication channel and an internal body (Ethics Channel and Compliance Committee) to help:
- Resolve any doubts that may arise.
- Communicate any type of incident or warning about potential breaches.
- Contribute opinions or make any kind of suggestion.
Employees wishing to communicate with the Ethical Channel should contact the following email address: email@example.com.
The information received in the above mailbox will only be received by the members of the Compliance Committee. The people who make up this Committee will know the Code perfectly, as well as all applicable regulations related to good business practices and will be responsible for assessing and, if applicable, raising any inappropriate behaviour so that the Company can make decisions in this regard.
Given that in certain cases the information passed to the Ethics Channel could have a negative impact on those who make it known, the members of the Compliance Committee will commit themselves by means of a signed declaration not to reveal the identity of the person providing the said information, guaranteeing at all times the confidentiality of their identity, and treating the case without reporting on it, focusing on the content of the complaint, query or reported incident.
The Compliance Committee is committed to perfecting, updating and promoting the entire ethical culture and regulations (including this Code) of the Company, to ensure that, in future updates, it includes the lessons learned from the consultations and communications received.
Compliance with the Code
As indicated throughout this Code, an undisputable requirement to form part of Kreab is to share its principles and values, as a consequence, every individual of our team is committed to comply with what it establishes and to ensure its correct development through its express acceptance and signature by all of us who make up the Kreab team.