Grupo Binternational’s Anti-corruption Policy
First edition, September 2022.
In accordance with our policy of maintaining the highest standards of conduct and ethics, at Binternational Group we have implemented an Anti-corruption Policy that is known by all the company’s staff, employees, professionals or external collaborators, members of the management body and shareholders.
At GB we firmly protect our Mission through our Anti-Corruption Policy, which includes all those situations that may represent possible causes of corruption in order to help prevent it.
GB will maintain absolute transparency in all its relations with Public Authorities and Institutions, always defending ethics and respect for corruption and bribery prevention laws before any interlocutor.
Furthermore, we support transparency and the management body rejects all types of corruption, applying a zero tolerance criterion with respect to any breach of this Anti-Corruption Policy.
In order to prevent corruption, we are committed to complying with current legislation in all our actions and in all the countries in which we operate and, therefore, to:
- Not to influence the will or objectivity of persons outside the company to obtain any benefit through the use of unethical practices and/or contrary to applicable law.
- Not to give, promise or offer, directly or indirectly, any thing of value to any natural or legal person in order to obtain undue advantage by bribery.
- Do not bribe an authority or public official by offering a gift in exchange for performing or omitting to perform an act inherent to their position, thereby committing bribery.
- Do not finance or otherwise support, directly or indirectly, any political party, its representatives or candidates.
- Do not use donations to cover up improper payments.
- Not to force a person, through the use of violence or intimidation, to perform or omit to perform a legal act or business for profit and with the intention of causing damage to the assets of the passive subject or of a third party, thereby committing extortion.
- Do not make facilitation payments, which consist of making a small payment to a public official to facilitate the management of an administrative procedure.
At GB we maintain supervisory actions to prevent money laundering and the financing of terrorism, complying at all times with the regulations in force.
GB will avoid any situation in which conflicts of interest may arise, by directly excluding consultants who may have a personal link or interest in any of its clients from projects and other professional services.
The company will organise training actions (e.g. courses, seminars, webinars, etc.) so that our entire team can learn about corruption prevention.
The company’s team may only receive gifts of token value.
Scope of application and compliance
This Policy applies to all the professional team of Grupo Binternational, S.L.
GB delivers the Anti-Corruption Policy electronically to all members of its team and collects acknowledgement of receipt of its delivery by the same means.
We also inform all persons and/or entities with whom we have dealings of the existence of our Anti-Corruption Policy, which is made available to them upon request.
Our aim is to always work with collaborators, suppliers, customers and third parties who are responsible.
The management body shall be responsible for ensuring compliance with the Anti-Corruption Policy and for taking all appropriate measures to this end, always in accordance with the legislation in force. It shall also ensure that it is updated whenever it deems appropriate in order to adapt it to its sector and specialisation.
Any breach of the Anti-Corruption Policy, as well as of any internal policy, will be assessed by the management body, which may take the necessary corresponding measures based on its analysis and objectivity, even deciding on the termination of any type of contract or agreement.
We also have a communications channel so that any actions of the professional team that may involve unauthorised conduct, financial, accounting or commercial malpractice or non-compliance with regulations can be reported in complete confidentiality.
Any employee or professional of the team, as well as those who maintain a contractual relationship with us and any other stakeholder, can report breaches related to the company’s principles and values set out in the Code of Ethics.
The communications channel for reporting any incident is firstname.lastname@example.org, with access restricted to the person in charge of the Complaints Channel.
Any complaint may also be received in writing by letter addressed to the postal address of the registered office of the company: C/ Diego de León, 57 2ºCD 28006 Madrid.
Content of the complaint
The complaint must contain the following:
- Name and surname
- Relationship with the company
- Contact details
- Detailed description of the irregularity
- Person(s) responsible for the irregularity
- Time at which it occurred and indicate whether it is still occurring at present
- Quantification of the impact if possible
- Other important information to understand the situation
This whistleblowing channel must guarantee the exercise of the rights conferred by current data protection legislation, especially, with regard to the data subject, his or her rights of access, rectification, cancellation and opposition.
In no case shall the complainant be identified as a consequence of the exercise of the right of access by the data subject. If the nature of the internal reporting system makes it foreseeable that specially protected data could be processed, this would entail the need to implement high-level security measures.
In the report, it is mandatory for the complainant to provide his/her name and surname and, on a voluntary basis, other identification data, as well as a contact e-mail address.
Anonymous complaints will not be processed.