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Compliance

Contents

 

1.1.   Policy

1.2.   Mission, Vision and Values.

2.    Scope.

3.    Conduct guidelines.

3.1.   Fundamental Rights.

3.2.   Respect for people.

3.3.   Equal opportunities and non-discrimination.

3.4.   Health and Safety.

3.5.   Protection and care of the corporate brand, image and reputation.

3.6.   Respect for the environment.

3.7.   Drug and alcohol use.

3.8.   Housekeeping in the workplace.

3.9.   Money Laundering and payment irregularities.

3.10.        Bribery, Gifts and Hospitality.

3.11.        Use of company assets.

3.12.        Conflict of interest.

3.13.        Relations with customers.

3.14.        Relations with suppliers.

3.15.        Relations with authorities and government officials.

3.16.        Confidentiality of information and protection of personal data.

3.17.        Protection of intellectual and industrial property rights.

3.18.        Compliance with the standard.

3.19.        Effect.

3.20.        Frequently asked questions

 

 

 

 

  1. Introduction

 

This document establishes the guidelines, values and principles by which those within the Organisation are to be governed in relations with interested parties. It is based on our Policy, Mission, Vision and Values and represents a guide of action to ensure proper behaviour in our professional performance.

To achieve this, the Code:

 

  • Provides knowledge about our business culture and its application, based on fulfilment of human and social rights and the integration of all employees, with respect for their diversity.
  • Establishes the principle of due diligence for the prevention, detection and eradication of irregular conduct, whatever its nature, by performing: risk analysis, assigning responsibilities, training both employees and third parties directly related to Naipes Heraclio Fournier, S.A. (hereinafter NHF) and creating procedures for the reporting and immediate elimination of irregular conduct.
  • Considers the principle of criminal liability of legal persons covered under the law of the various jurisdictions where we operate, as well as preventing and eradicating the existence of conduct that may find NHF accountable among its legal representatives, administrators, employees or any other person who is subject to the authority of the company’s personnel

 

  • Policy

 

Naipes Heraclio Fournier, S.A. has established an integrated policy that has been communicated and published in the AMIG II document within the IMS.

 

  • Mission, Vision and Values

Our mission, vision and values ​​are defined in the integrated management manual. IMM

 

We work in a friendly atmosphere  with modern, clean, bright facilities that are run efficiently and that are environmentally friendly.
The General Management encourages management to be participatory and transparent, leading change with a strategic vision and favouring creativity, initiatives and personal development, all of this based on continuous improvement.
Our “Passion for Fournier” translates into a team spirit, being aware of the threats and opportunities in order to take full advantage of them and being able to respond to the needs and expectations of interested parties.
We are an international company. Leader in quality and innovation, boasting advanced manufacturing and management technology systems,  and committed to the Environment and responsible behaviour and “zero tolerance” towards the commission of unlawful acts. We form a work team with a professional attitude, fully aware of the risks and doing everything we can to make them disappear or to minimize them.

 

  1. Scope

 

This Code of Ethics and Professional Conduct is aimed at all personnel, regardless of the position they occupy or the place where they perform their work.

Adoption of conduct guidelines consistent with this document shall be promoted and encouraged among all interested parties. To this effect, the Management shall communicate the Policy, Mission, Vision and Values and make it available to whomsoever requests such.

The standards of conduct included in this document are intended to establish conduct guidelines for the way to do things during the course of professional activity.

All employees and, should the nature of their relationship so require, any person who represents them shall be personally notified of the Code, and who shall duly provide commitment to comply in writing. Likewise, this document shall be provided within the reception plan to newly recruited staff members, who shall sign acceptance of such.

Any doubts arising from the interpretation of the conduct guidelines may be discussed with an immediate superior, Criminal Compliance Officer or the Ethics Committee.

 

  1. Conduct guidelines

 

  • Fundamental Rights

 

NHF complies with current legislation regarding recruitment procedures. Furthermore, it respects the freedom of association and effective recognition of the right to collective bargaining, as well as the elimination of all forms of forced or coerced labour.

NHF shall advocate that its suppliers and external companies with which it conducts business also respect these principles.

All employees shall:

  • Undertake to respect the fundamental rights of people and the public liberties recognised by national and international agreements in all of their activities and to perform all of their activities with full respect for human dignity.
  • Avoid any conduct that, even without violating the law, may damage the reputation of the Organisation in the eyes of the community or other entities and adversely affect its interests.
  • Know the laws that affect their work, requesting, when applicable, precise information from their superior or relevant authorities.
  • No employee shall knowingly collaborate with third parties to violate any law, nor participate in any action that undermines respect for the principle of legality or that may harm the reputation of the company.

In situations of doubt or having observed instances that lack respect for legality, human rights or ethical values, employees shall inform the company through their direct superior, Criminal Compliance Officer or the Ethics Committee.

 

  • Respect for people

 

NHF rejects any form of physical, psychological, sexual or moral harassment or abuse of authority, as well as any other conduct that may generate an intimidating or hostile environment with regard to the rights of people. All employees shall be treated with respect, promoting cordial relationships and a pleasant, healthy, safe working environment. All employees have a duty to treat their colleagues, superiors and subordinates fairly and respectfully.

Relationships between the employees and those of external companies or collaborating entities shall be based on professional respect and mutual cooperation.

The Management undertakes to investigate any complaints regarding harassment, establishing a conflict resolution procedure for the aforementioned conflicts. This procedure guarantees the objectivity, right to privacy and confidentiality of any issues addressed and of the people involved.

 

  • Equal opportunities and non-discrimination

 

NHF strives to ensure that the principle of equal treatment and opportunities at work is fulfilled. We are committed to combat discrimination in any of its forms, whether direct or indirect, viewing discrimination based on sex, marital status, age, race, social standing, religious or political ideas, affiliation or not to a union, etc. as wholly unacceptable.

NHF is committed to the professional and personal development of its employees, guaranteeing equal opportunities.

The selection and promotion of employees shall be based on performance of professional functions and on the criteria of merit and skill defined for each work post.

These principles of fair recruitment shall apply to all aspects of the labour relationship, including remuneration, promotions and transfers.

NHF actively works to promote corporate social responsibility.

 

  • Health and Safety

 

Within its culture and management system NHF has integrated the prevention of work related accidents and occupational diseases, as well as the improvement of Occupational Health and Safety.

All internal or external workers who undertake work for NHF are required to comply with the established Occupational Risk Prevention regulations.

Furthermore, they shall actively collaborate in the integration of Occupational Risk Prevention in all activities developed in the company in accordance with the functions and responsibilities assigned to them.

All personnel shall promote compliance with good Health and Safety practices and participate in encouraging a preventive OHS culture by reporting any irregularities or situations of risk.

Likewise, they shall make responsible,  appropriate  use of any protective equipment assigned to them in the course of their activities.

 

  • Protection and care of the corporate brand, image and reputation

 

The NHF corporate image and reputation is one of the company’s  most valuable assets for maintaining the trust of all interested parties.  NHF establishes responsible public relations within the development environment of its business activities. All employees shall consider the interests of local communities during the course of their work.

All employees shall strive to maintain the image and reputation of the company in all of their actions.

NHF protects the corporate brand, image and reputation.

 

  • Respect for the environment

 

NHF is committed to respecting the environment during the course of its business activities, consequently the company upholds ISO 14001:2015 certification

All employees shall actively and responsibly commit themselves to environmental conservation, duly complying with the legal requirements and procedures stipulated for each work post; engaging in any environmental programmes that may be implemented and acting with maximum diligence.

Likewise, employees aware of the environmental impact that their activities may cause, shall endeavour to minimise such and make efficient use of the means placed at their disposal.

 

  • Drug and alcohol use

 

The Organisation expressly prohibits the possession, consumption or trade of drugs and alcoholic beverages, as well as working under the effects of such, regardless of circumstances.

This is ensure that the individual avoids endangering themself, their colleagues, other people, or the company’s assets and equipment.

 

  • Housekeeping in the workplace

 

When working in shared environments, respect towards colleagues is essential, consequently the work place shall be kept clean and tidy, using facilities and common areas hygienically and appropriately. Installations shall be held to the same cleaning criteria, with each employee cooperating in the recycling of the materials according to procedures.

 

  • Money Laundering and payment irregularities

 

NHF follows the procedures stated in current law to prevent irregular payments or the laundering of money derived from illegal or criminal activities.

Employees shall pay special attention to those cases where persons or companies with which NHF maintains relations might display a lack of integrity, immediately reporting any payment that may be considered dubious. Special attention shall be paid to extraordinary payments, unforeseen in agreements or contracts.

Under no circumstances shall collaboration be provided for conducting activities that might serve as a cover for terrorist or criminal activities.

 

  • Bribery, Gifts and Hospitality

 

Practices or situations that lead, as a result of performing a function of work, to any person within the company making profit or personal gain, whether monetary or not, or allowing others to profit or gain.

Offering or accepting gifts incommensurate with uses or customs, whether within the company or business environment, is forbidden. If in doubt, discuss the matter with the General Manager, who shall decide how to proceed.

In any case, the offer or acceptance of gifts exceeding €40.00 in value shall be reported to the General Manager.

Any contributions or gifts that are made to support a charitable society, foundation or a social event within the community, shall have to be consistent with the Organisation’s policies and way of acting in matters of CSR.

 

  • Use of company assets

 

The Management encourages its staff to make good use of the means placed at their disposal, consequently any misuse or improper use of company assets shall not be permitted.

With regard to computer resources, the confidentiality clause stated in Data Protection Regulations regarding users with access to personal data shall be applicable, as detailed in the document “Information on the processing of workers’ data, confidentiality and policies on the appropriate use of company resources”.

Employees should be aware that the documents and data contained in the Organisation’s systems and equipment may be subject to review by relevant units within the company, or by third parties appointed by the latter, when deemed necessary and permitted by current legislation.

 

  • Conflict of interest

 

Conflict of interest may be understood as any circumstance where an employee’s personal interests interfere, directly or indirectly, with the responsible, ethical fulfilment of their duties and responsibilities or where they are personally involved in any business transaction or financial operation conducted by the company, their customers or their suppliers.

The relationship between NHF and its employees shall be based on loyalty and trust, therefore any situation in which the employee’s personal interests may conflict, directly or indirectly, with those of the company should be avoided.

 

Situations where an employee becomes, whether directly or indirectly, a customer or supplier of NHF shall be reported to the Ethics Committee. If in doubt, it is advisable to raise the issue with the Committee in writing.

 

  • Relations with customers

 

NHF is committed to quality in its relations with its customers, a characteristic that sets us apart from the competition, establishing measures to ensure that the quality policy is practised by all employees with regard to service to the customer.

All employees shall behave with integrity towards the customer, with the goal of achieving the highest levels of quality and excellence in the development of relations based on trust and mutual respect.

All customers shall be treated respectfully, fairly, honestly and in accordance with the principles and core values ​​of the company.

Relations with customers shall be based on efficiency, professionalism, service mentality and cooperation, endeavouring to satisfy their needs and providing them with competitive, high quality solutions.

 

  • Relations with suppliers

 

In the demand for the highest quality, transparency, continuous improvement and mutual benefit, NHF shall promote the establishment of stable relations with its suppliers and partner companies based on trust, bolstering innovation and development. To achieve this, treatment shall be on a like-for-like basis and always within the framework of the law.

NHF shall encourage suppliers to develop their activity according to the criteria of Corporate Social Responsibility: respect for Human Rights, the non-use of forced or coerced labour, the eradication of child labour, respect for the Environment and the eradication of discrimination.

The selection of suppliers shall be made in accordance with the   Purchase Process, procedures PO-03 and PO-20 of the IMS.

All employees involved in contracting services or purchasing goods shall act with total independence, impartiality and objectivity, applying criteria of quality, cost, ethical, social and environmental standards and ensuring that personal interests do not conflict with those of the company.

Procurement practices that result in personal profit or gain for anyone within the company, the supplier or third parties shall not be permitted.

 

  • Relations with authorities and government officials

 

NHF employees shall interact with public authorities and institutions in those countries where they carry out their activities, in a lawful, ethical, respectful manner and in line with international regulations concerning the prevention of corruption and bribery. Those employees who maintain relations with representatives of government authorities shall be specifically authorized by the company to do so.

No employee within the Organisation shall offer, grant, request or accept, directly or indirectly, gifts or donations, favours or gratuities, regardless of their nature, or from any public authority or official.

The only exception to the previous rule are gifts and acts of hospitality of limited value that are proportionate and reasonable according to local practice, transparent and made based on legitimate, socially acceptable and sporadic interests, ensuring that their content or regularity does not lead to third party to doubt the good faith of the employee or the company. Gifts of cash are expressly prohibited.

Each employee shall be responsible for knowing and accurately assessing local practices, taking the interest and good reputation of the company into account. If in doubt, raise the issue with the Ethics Committee.

 

  • Confidentiality of information and protection of personal data

 

NHF complies with current Regulation EU 2016/679 on the protection of personal data.

NHF personnel are obliged to protect any information and/or knowledge generated within the Organisation, being its property or in its care.

Employees shall maintain confidentiality and respect their obligation of professional secrecy. Any information to which they have access shall be considered confidential and may only be used for the purposes for which it was obtained.

This duty of confidentiality shall remain in force after relations with NHF have concluded and shall include the obligation to return any material related to the company and/or documents that may contain confidential information.

Employees shall inform the person responsible for their area or the data protection officer of any incident that they detect related to confidentiality of information and protection of personal data.

 

  • Protection of intellectual and industrial property rights

 

NHF encourages creativity among people within the Organisation, and considers knowledge and experience acquired in relation to systems, products and innovative production processes to be  a competitive advantage. Consequently, the company shall protect the rights that may be vested in patentable inventions of industrial application, distinguishing signs such as trademarks, commercial names or processes.

The Organisation is committed to protecting intellectual and industrial property rights of its own and of others. This includes, copyrights, patents, trademarks, domain names, reproduction rights, design and database extraction rights and rights associated with specialised technical skills.

NHF is answerable for the originality of its own designs and shall ensure that its suppliers guarantee the originality of the designs that are made available to the company. Staff members are expressly prohibited from using works, creations or distinguishing signs subject to intellectual or industrial property rights of third parties without proof that the company holds the corresponding rights and/or licenses.

Staff shall take all necessary measures to protect intellectual and industrial property rights. Processes and decisions shall be documented and be justifiable and verifiable, especially through the titles of the works themselves, creations or distinguishing signs and the application of contractual clauses that guarantee the originality and agreed use of those from third parties.

Intellectual and industrial property rights resulting from work done by employees during their time at the Company, and which is related to the present and future business interests of NHF, shall be held by Naipes Fournier. Only those brands, images and texts duly authorised by the Marketing Department shall be used for marketing and advertising purposes.

 

  • Compliance with the standard

 

This document establishes the ethical principles and commitments for business that NHF and its people shall respect and fulfil in the course of their activities. It shall, therefore, be communicated to all employees. All persons who are recruited into the Organisation shall expressly accept these ethical principles.

To ensure compliance with this Code, resolve incidents or settle doubts regarding its interpretation and adopt appropriate measures for compliance, the Ethics Committee has been created. The mission of the said committee is to promote the dissemination and application of ethical principles in all activities carried out by the company, guaranteeing confidentiality.

It shall be composed of the General Manager, Head of Compliance and Head of Human Resources.

Should an individual detect a situation or behaviour that may involve a breach of the Code of Ethics and Professional Conduct, they shall consult or inform of such immediately, whether directly involved or not.

The consultation and information channels established to ensure compliance with this Code are:

 

  • Verbally to any member of the Ethics Committee and by completing DOC 27-01
  • Verbally to a direct superior and by completing DOC 27-01

 

Having duly completed DOC 27-01, it shall be sent to the Head of  Compliance, by mail or delivered by hand.

Failure to comply with the principles established in this Code shall be analysed in accordance with internal procedures, legal regulations and current agreements. Any doubt that may arise from the interpretation and/or application of this Code should be brought to the attention of a direct superior or the members of the Ethics Committee.

Nobody, regardless of their position within the company, shall request an employee to breach the Code of Ethics and Professional Conduct. No employee may justify the said breach due to an order from a superior or ignorance of the Code of Ethics and Professional Conduct.

All employees have a duty to inform their direct superior or any member of the Ethics Committee of any breach or misconduct that is observed during the course of their activities.

The company guarantees that any type of complaint regarding such conduct, presented in good faith through the channels established for this purpose, shall not result in reprisals against the complainant. Likewise, all persons are entitled to presumption of innocence and to their right to honour and reputation, consequently false accusations intended to cause harm to another person shall not be tolerated.

 

  • Effect

 

This Code has been approved by the NHF Board of Directors, 30th May 30, 2018.

The Code of Ethics and Professional Conduct comes into effect on the day of its publication and internal dissemination among all company employees and shall be remain in effect until such time that modification or derogation is communicated.

This Code shall be revised and updated by motion of the Ethics Committee and, in any case, annually.

 

 

  • Frequently asked questions
Where can I obtain the NHF Code of Conduct and the complaint form?

F:/SGISO/MPA Procesos de Apoyo/Compliance

Through the Fournier website, www.fournier.es

If you do not have access to the Internet, request it from the Human Resources department or the Head of Compliance.
For whom is the Code of Conduct intended? All NHF personnel, including the Management, shall adhere to the Code of Ethics and Professional Conduct. There is no exception.
What happens if I accidentally break the company’s Code of Ethics and Professional Conduct?

We should all guarantee that our actions comply with the Code of Ethics and Professional Conduct.

If your actions are contrary to the conduct described, stating that you had good intentions or that you were unaware that your actions were inappropriate, this may not protect you from disciplinary action or legal consequences.

My Manager or Superior told me to do something that I think might contravene the Code of Ethics and Professional Conduct. What  should I do?

Never do anything that might contravene the Code of Ethics and Professional Conduct.

Report this fact to any member of the Ethics Committee.

Where can I go to receive information on matters  of compliance and settle my doubts related to ethics? Contact any member of the Ethics Committee.
Is the Code confidential? No, the Code of Ethics and Professional Conduct is public and available to anyone who requests it
Will I face problems by reporting a breach? No. You will not be subject to any disciplinary action for reporting a possible breach in good faith.
What happens if an anonymous complaint is lodged? Anonymous complaints will not be processed, nevertheless, the company guarantees the confidentiality of the complainant and no acts of reprisal.
3.21 SUMMARY  CODE OF ETHICS AND PROFESSIONAL CONDUCT
Respect for people

·         As employees of NHF we should appreciate that respect is the basis of all actions we perform within the Organisation, and that it is always required, in any circumstance and activity.

We are responsible for ensuring that our professional relations are based on respect for the dignity of others, cooperation, fairness and communication, to create a good professional environment.

Equal opportunities and non-discrimination

·         We provide the equal opportunities in access to work and career advancement, ensuring at all times freedom from discrimination.

Our actions and decisions shall be guided objectively, with an open attitude to diversity, promoting equal opportunities.

Health and Safety

·         Respecting applicable preventive measures in matters of occupational health and safety.

Using the resources established by the Organisation and ensuring that members of our work teams carry out their activities under safe conditions

We promote compliance with good health and safety practices.

Protection and care of the corporate brand, image and reputation

·         We are responsible for ensuring that our actions and decisions are in the best interests of the Organisation and those of our customers and not motivated by personal or third party concerns or interests.

·         We should refrain from using the NHF image, name or brands to open internet accounts or register in forums and networks. The creation, membership, participation or collaboration in social networks, forums or blogs and the opinions or statements we make in such, shall be done in a way that makes our personal identity clear.

All employees shall endeavour to maintain the image and reputation of the company.

Respect for the environment

·         We are responsible for making proper use of resources during the course of our activity, minimising any environmental impact.

We are committed to the Environment and endeavour to use resources efficiently.

Drug and alcohol use ·         Possession, consumption or trade of drugs and alcoholic beverages is expressly prohibited.
Housekeeping in the workplace

·         We endeavour to keep our work posts tidy and clean, using facilities and common areas appropriately.

All NHF personnel respect the workplace and keep it tidy and clean.

Money Laundering and payment irregularities

·         We have to avoid situations in commercial relationships that lack integrity, as well as irregular situations of payment or money laundering.

We should be aware of upright, legal behaviour in all of our economic transactions.

Bribery, Gifts and Hospitality

·         We shall refrain from accepting or offering gifts, invitations, hospitality and, in general, any type of compensation disproportionate or incommensurate with uses and customs.

Gifts and hospitality may be occasional and of limited value.

 
Use of assets

·         We should use the means provided by the company to perform assigned tasks and functions

NHF personnel shall respect the resources put at their disposal and make appropriate use of systems for assigned tasks and functions. 

Conflict of interest

·         We shall avoid, identify and report any situations where a real or potential conflict of interest exists, under no circumstances putting any personal interests before those of the customer or the COMPANY and its shareholders, including those arising from family relationships or similar ilk.

NHF’s relationship with its employees is based on loyalty and trust, so there should be no situations of conflict of interest.

Relations with customers

·         The customer is our raison d’être; therefore, we shall be professional and respectful.

We shall treat our customers respectfully, fairly, honestly and in accordance with the principles and core values ​​of the company.

Relations with suppliers

·         We shall ensure that all relations are conducted in an equitable manner and in accordance with the established internal rules.

·         Should we have to intervene in the selection and/or decision process regarding the contracting of supplies or services, or the negotiation of rates or other conditions, we shall avoid any kind of interference that may affect the transparency and objectivity of the process.

·         During the processes for approving, selecting and contracting suppliers for the acquisition of goods and services, we shall ensure the concurrence and diversification of offers.

We build relationships with suppliers in the context of mutual cooperation and corporate social responsibility.

Relations with authorities and government officials

·         We shall maintain a respectful and cooperative attitude with representatives of official authorities within the framework of their powers.

·         As a general rule, we do not offer, solicit or accept anything from any authority or official in exchange for favourable treatment.

NHF employees shall refrain from making payments to receive favourable treatment from public administration.

Confidentiality of information and protection of personal data

·         Information shall be used exclusively to perform our professional activity, and we shall not be able to provide it to anyone other than those NAIPES HERACLIO FOURNIER professionals who need to know it for the self same purpose, and who are bound by their obligation of professional secrecy.

·         Information related to personal data shall be handled in a reserved manner to ensure its confidentiality, in accordance with the laws and detailed standards that regulate such issues.

·         Information shall never be used for personal gain or that of a third party.

This duty of confidentiality shall remain in force, even after the relationship with NAIPES HERACLIO FOURNIER has ended.

NHF personnel are committed to using personal information properly and comply with current regulations.

 

Protection of intellectual and industrial property rights We shall respect the intellectual property rights of NAIPES HERACLIO FOURNIER and those of third parties. With regards to manuals, courses, software and computer systems and, in general, the works and projects created or acquired by them
Compliance with the standard All Fournier employees shall adhere to the Code of Ethics.

 

If you wish to make a claim, you can download the DOC 27-01 CLAIM FORM CODE OF ETHICS AND CONDUCTS and send it to fournier@nhfournier.es

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