Grupo Binternational’s Code of Ethics

First edition, September 2022.

 

Scope of application and compliance

Grupo Binternational, as part of its governance, has a Code of Ethics that regulates the good practice of our people. Our code is applicable to the entire professional team of Grupo Binternational, S.L., regardless of whether they provide their services in Spain or abroad.

We also apply it to people hired to carry out consultancy and advisory tasks who have a professional relationship with Grupo Binternational, S.L. during the period in which they are linked to us.

In GB we deliver our Code of Ethics electronically to all the persons indicated, and we receive acknowledgement of receipt of its delivery and acceptance by the same means.

We also communicate the existence of our Code of Ethics to all persons and/or entities with which we have dealings, making it available to them at our headquarters and on the GB website.

Our aim is to surround ourselves with people, suppliers, customers, partners and other collaborators who are conscious and responsible with the environment and with human and labour rights. We want to live our purpose and values and pass them on to our stakeholders.

In Grupo Binternational, S.L. we have established a whistleblowing channel whose address is canalcomunicaciones@grupobinternational.com regarding the commitment of the entire professional team (workers, collaborators, partners) in the communication of any knowledge or well-founded suspicion of actions contrary to the company’s values or against the regulations in force, including the regulations on the prevention of money laundering and financing of terrorism.

The management body shall be responsible for ensuring compliance with the Code of Ethics, as well as for taking all appropriate measures to this end and always in accordance with the legislation in force. It shall also ensure that it is updated whenever it deems appropriate in order to adapt to its sector and specialisation.

Any breach of the Code of Ethics, as well as of any internal policy, will be assessed by the management body, which may take the necessary corresponding measures, always in accordance with current regulations applicable to the company’s sector, even deciding on the termination of any type of contract or agreement.

Health, Safety and Work-Life Balance

Grupo Binternational is concerned about everything related to the work-life balance of its employees, who currently combine one day of face-to-face work with four days of teleworking, flexible start and finish times, intensive working hours in July and August, teleworking from 1 July to 15 September and from 26 December to 5 January.

We have a Welcome Plan where GB introduces itself, tells its history and offers the necessary information to successfully face the incorporation of new colleagues.

We promote the GB Experience, a set of actions and benefits for employees that promote a positive experience in the daily life of our colleagues, of great importance to maintain a united team, through the head of People Experience.

We are working to become a safe and violence-free space. In addition, our office is a safe place and when the epidemiological situation requires it, we activate our COVID-19 Contingency Plan. 

Employee handbook

At Grupo Binternational, S.L. we have published our Employee Handbook, “3, 2, 1… Go!”, which aims to centralise in one document the most relevant information about the organisation, such as the raison d’être of the company, examples of how the GB experience is lived, its history, values, practices, policies, rules and procedures.

Environment 

At GB we are concerned about the negative impact that our activity and that of our collaborators generates on the environment and we promote all possible improvements in our facilities, as well as in all those virtual offices from which our team works.

We do this by educating our stakeholders, promoting improvements in energy and water efficiency, encouraging the reduction of waste generation, with waste destruction programmes (including recycling), advocating the use of public transport, shared bicycles or cleaner combustion vehicles. 

We encourage our team to use technology to hold virtual meetings to reduce travel. In addition, we are pursuing the reduction of emissions from digital file storage and email use.

We also advocate the maximum reduction in the use of paper and we expressly state this in the electronic signature of all our professional team and in all those forums in which we can disseminate this objective.

Customer Relationship Decalogue

We have also created a Customer Relationship Decalogue, the aim of which is to always comply with the best practices of the sector in which they operate and with the Values set out in our Code of Ethics.

Customer Defence Policy

We maintain a Customer Defence Policy, as well as a Customer Care Service (CCS), which we apply professionally and rigorously with the aim of defending a transparent and trustworthy relationship with the customer. 

The channel for submitting customer complaints and/or claims to the Customer Care Service (CCS) is sac@grupobinternational.com.

The clients who contract our services can be natural persons and legal entities, such as private companies, public administrations, civil society organisations and universities or training centres.

Conflicts of interest

At Grupo Binternational, S.L. we are aware of the importance of any type of conflict of interest that may arise in the development of our business relationships, so whenever any of the members of our team becomes aware of the existence of a possible conflict of interest, they must inform their immediate manager as soon as possible. 

In these cases, GB must inform the client, prior to the start of the relationship, of the possible existence of a conflict of interest, as well as the measures that will be taken to manage it.

GB’s priority is to maintain transparent relationships with all our customers.

Supplier Relations Decalogue

GB has a Supplier Relations Decalogue whose objective is to always comply with the best practices of the sector in which it operates and with the Values set out in this Code of Ethics.

Community-oriented impact 

GB projects aim to generate a specific benefit for all stakeholders, including partner charities, disadvantaged suppliers and/or the local community.

At GB we promote diversity, equity and inclusion.

We expressly declare our categorical opposition to any practices that suggest conduct or practices of harassment at work, sexual harassment and discrimination also in the digital environment (digital harassment or cyber-bullying).

On the other hand, we inform of the existence of a Priority Channel, created by the Spanish Data Protection Agency (AEPD), to help citizens in urgent and serious cases of digital violence, and to promote good practices to prevent digital violence, which mainly affects girls and women.

Anti-corruption policy and whistleblowing channel

In GB we have implemented our own Anti-Corruption Policy to prevent corruption and bribery, with a corresponding whistleblowing channel to report possible fraudulent or dishonest conduct.

Confidentiality and information security 

Grupo Binternational, S.L. has a Security Measures Document in accordance with the General Data Protection Regulation (EU Regulation 2016/679 -RGPD-) and the Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).

This Document establishes that the protection of the rights and freedoms of natural persons with respect to the processing of personal data requires the adoption of appropriate technical and organisational measures in order to ensure compliance with its requirements. 

In this regard, the principle of integrity and confidentiality, provided for in Article 5(1)(f) of the GDPR, establishes that personal data must be processed in such a way as to ensure appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by implementing such appropriate technical or organisational measures.

All information obtained from customers, employees, suppliers, collaborators or any third party with whom GB has a contractual relationship must be used exclusively for the authorised purpose or specific project. 

Grupo Binternational is responsible for the custody of the information and for allowing access to the data exclusively to the professionals who must access it according to the projects awarded, thus guaranteeing the level of security required for each situation.

The commitment to maintain confidentiality will remain once the project has concluded.

GB will communicate as soon as possible to the affected person (individual or institution) any incident that may occur related to confidentiality, information security and protection of their personal data.

Adherence to the AEPD’s Digital Pact

GB is a member of the Digital Pact for the Protection of People of the Spanish Data Protection Agency (AEPD), a Social Responsibility Framework document, with an Action Plan of 103 initiatives in areas such as education and minors, gender equality, innovation and entrepreneurship, the environment, good governance and transparency, and workers. 

These initiatives are fully aligned with the Sustainable Development Goals (SDGs) of the 2030 Agenda, in particular SDGs 5, 12, 16 and 17:

Combat violence on the internet, especially against women or groups at risk.
Promote innovation in the field of privacy and data protection, so that it is not an obstacle to the development of the digital economy.