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712019 ANNUAL AND CORPORATE RESPONSIBILITY REPORT

The Code of Ethics and Conduct is com- plemented and developed through vari- ous corporate policies that establish the different standards that must be met both by our professionals and by any third party working with us or representing us.

The main policies that make up our inter- nal regulatory framework, some of which can be consulted on our website, are as follows:

Corporate Criminal Risk Prevention Policy.

Third Party Due Diligence Policy.

Conflicts of Interest Policy.

Supplier Code of Ethics.

Anti-Bribery and Corruption (Public Sector) Policy.

Corporate Responsibility Policy.

Policy on Health and Safety, Environ- mental Protection and Quality.

Human and Workers Rights Policy.

Crime Prevention Manual, which ena- bles us to establish the model of or- ganisation, prevention, management and control of criminal risk prevention at Cepsa, describing the basic ele- ments that comprise the company's Crime Prevention Model.

2019 also saw the development of the Data Protection Policy, to enable us to adapt to the new needs and external re- quirements. The purpose of this policy is to establish the guidelines that allow all the companies in the Cepsa Group to protect the fundamental rights to honour and privacy in the personal data process- ing of all individuals with whom we have a relationship, in compliance with the ap- plicable legislation. In the policy we also express the most categorical rejection of any form of violation of the regulation on the personal data processing in relation to any interested party, and we state our commitment to prevent and fight against any breach of this regulation that may deteriorate the value of the entities of the Cepsa Group, their image or reputation.

We are firmly committed to compliance with regulations, our internal rules and the principles set out in our Code of Ethics and Conduct. For this reason we have an Ethics and Compliance Channel through which any employee or third party can report irregular behaviour or behaviour contrary to these rules.

The channel is managed by the Ethics and Compliance Office, which reports to the Compliance, Audit and Ethics Commi- ttee. All the stakeholders with whom we work or establish a contractual or co- mmercial relationship are informed about how the channel operates, either through the corporate website at the general le- vel, or through the contractual documents and training initiatives in the specific case of our suppliers and employees. All re- quests for advice received through this

channel are treated confidentially and anonymously, in accordance with our Code of Ethics and Conduct and the rele- vant data protection regulations; as well as ensuring zero tolerance for retaliation against whistle-blowers.

The Ethics and Compliance Channel Po- licy establishes the procedure by which communications received through this channel are processed.

This channel is available at all times on the website, and we are also finalising the access to the channel by telephone through an external service available 24 hours a day.

Below are the main data on the commu- nications received through the Ethics and Compliance Channel during the year:

CORPORATE POLICIES

ETHICS AND COMPLIANCE CHANNEL

Access our Ethics and Compliance Channel

Access our Corporate Policies