Corporate Compliance Programme

Corporate Compliance Programme

On July 4th, 20218, MAETEL approved a Corporate Compliance Programme.

This Programme describes in a structured way the measures that MAETEL has arranged with the main purpose of creating an environment of prevention, detection and early management of criminal risks, contributing to generate a culture of ethics and respect for the Law.

It adopts an active role in the fight against crime and thereby also adopts the technical, organizational and specific personal measures, as well as surveillance and control measures, and the appropriate penalty system for avoiding the production of infringements or illegal actions.

In this context and, in order to comply with this objective, MAETEL has internally published the following documents:

  • ACS Code of Conduct  
  • ACS Industrial General Protocols
    • Framework Protocol
    • Regulatory Compliance Protocol
    • Corporate Defense Procedure Activation Protocol
    • Protocol on Training of Professionals in Regulatory Compliance Issues
    • Statuta of the Legal Compliance Body-Protocol on de profile, experience and organic location of Legal Compliance Body, Corporate Officer and the Compliance Delegate
    • Protocol for Core Polices
    • Catalogue of Forbidden Conducts and Expected Behaviours
    • Code of Conduct for Business Partners  
    • Protocol for Compliance with Competition Standards 
    • Corporate Due Diligence Protocol regarding Human Rights
    • Information Security Protocol
  • Internal System Regulations
  • MAETEL Crime Prevention Plan and the corresponding attached Policies:
    • Criminal, Anti-Bribery Compliance and Behaviours Against to the Defense fo the Competition Policy
    • Policy on IT Conduct
    • Polcy on Business Courtesies
    • Policy and Prevention of Money Laundering and the Financing of Terrorism
    • Anti-corruption Policy
    • Policy on Intellectual and Industrial Porperty Rights
    • Confidential Treatment and Sensitive Commercial Information Policy
    • Environmentla Protection Policy
    • Policy on Prevention, Detection and Intervention against Workplace Mobbing
    • Personal Data Protection Policy

Anyone who has knowledge or suspects of any type of infraction, illegal action, inappropriate behavior, etc. may use, in addition to the internal report to the hierarchical superior or the Corporate Compliance Officer, the different reporting channels enabled:

Email: canaletico@maetel.com

Voicemail: +34 976 066 669

Ordinary post: to the attention of MATEL Corporate Compliance Officer, Parque Empresarial Plaza, Calle Bari 33, Ed. 3, Planta 3ª, 50197 (Zaragoza), Spain.

These channels are both a way of denouncing the breach of legislation or internal regulations, as well as of resolving a consultation that may arise in the development of the organization’s activity, ensuring always the confidentiality and the absence of retaliation for the filing of a complaint.

In addition, there is an information channel infocompliance@maetel.com that is available to receive any doubts that may arise from the application of the Corporate Compliance Programme.

On March 8th, 2019, in accordance with the UNE 10901:2017 regulation, the certifying entity AENOR awarded MAETEL with the Certificate of Management System of Criminal Compliance, with which a model of crime prevention has been implemented in the company in accordance with our commitment to legality and business ethics. On March 16th 2020, AENOR awarded MAETEL with the Certificate of Anti Bribery Management,  in accordance with ISO 37001:2016 regulation.

 


All the people who have good faith transmit their notifications, protected against any type of discrimination and penalty due to the complaints made. False or defamatory complaints will be subject to disciplinary sanctions in accordance with the applicable internal procedures, conventions and legal norms. This system will confirm that the identity of the complainant is kept confidential. The identiy of the complainant is not disclosed to third parties, neither to the person denounced nor to the executive officers, except that its disclosure is necessary to the relevant persons involved in any subsequent investigation or judicial proceedings initiated as a result of the investigation carried out by the internal complaints system. In accordance with the applicable regulations on the Protection of Personal Data, interested parties are informed of the personal data that are collected through this necessary Ethical Chabbel processed by MAESSA TELECOMUNICACIONES, INSTALACIONES, INGENIERÍA Y SERVICIOS, S.A (hereinafter MAETEL) with the purpose of transmitting the corresponding complaints and inquiries, in accordance with the provisions of the Corporate Compliance Programme, and internal MAETEL regulations. The basis of legimization of this treatment is the consent f the interested party by voluntarily submitting the information. The data will be kept for the duration of the investigation and its deletion is not requested and, in any case, in compliance with the statuory limitation periods that result from the application. Personal data may be tranferred to MAETEL companies if necessary, for th epurpose of the investigation, processing and/or resolution. Likewise, it is informed that, in any case, the interested party may at any time exercise the rights of access, rectification, deletion, portability and limitation or opposition by writing to the address Parque Empresarial Plaza, Calle Bari 33, Ed. 3, Planta 3ª, 50197 (Zaragoza).