Corporate Governance
DOVALUE SPAIN SERVICING SA (hereinafter, "doValue Spain"), in the exercise of its activity, has as its fundamental principles objectivity, integrity and transparency. The commitment to follow these principles and to comply with its desire for strict compliance with regulations (legal, regulatory and ethical standards) leads doValue Spain to promote a corporate culture of compliance with regulations at all levels of the organisation, which, in addition, allows for an adequate management of the reputational risk to which the company may be exposed.
The implementation of the aforementioned commitments and the implementation of the corporate culture of regulatory compliance are materialised, among other issues, with the establishment of a Code of Ethics, Policies, Procedures and Internal Controls whose effectiveness is reviewed on a recurring basis to enable their constant adaptation to the reality of each moment.
The Code of Ethics is the central element of the programme that has been defined in doValue Spain to implement the culture of compliance and the internal regulations that must govern the activity of doValue Spain employees. as such, the Code of Ethics includes:
- a catalogue of ethical principles and norms of conduct;
- the roles and responsibilities of the Governing Bodies and Senior Management in the implementation of the compliance programme;
- a reference to the rules governing the consequences of non-compliance with the Code of Ethics itself; and,
- the procedure for the formulation and processing of communications of suspected unlawful acts.
doValue Spain has an Internal Information System, whose communication channel, which guarantees anonymity and confidentiality, is available to employees and third parties for the formulation of complaints or communication of actions allegedly contrary to the Code of Ethics itself and which may be related to non-compliance with current legislation and internal regulations, especially those constituting breaches of European Union Law or serious or very serious administrative or criminal offences.
Some of the principles set out in the Code of Ethics are developed in specific internal regulations where necessary. In this regard, it should be noted that there are more specific internal regulations in relation to:
- Criminal compliance policy.
- Conflicts of interest.
- Gift policy.
- Internal Information System Policy.
Similarly, there are internal regulations which, without developing the principles contained in the Code of Ethics in greater detail, establish principles that are equally relevant and enforceable in other matters and which are of mandatory application in the development of doValue Spain's activity. Examples of these internal regulations are as follows:
- The Money Laundering and Terrorist Financing Prevention Manual.
- Data Protection Policies and Procedures.
Finally, it should be noted that doValue Spain has developed a Criminal Risk Prevention system, aimed at the prevention, mitigation and/or appropriate management of criminal risks identified in the company, and which details the principles of correct management in relation to the Organic Law 1/2015, of 30 March, which amends the Organic Law 10/1995, of 23 November, of the Criminal Code published in the Official State Gazette on 31 March 2015, and which came into force on 1 July 2015.
Code of Ethics
Policy Criminal Enforcement
Non-financial statement
Whistleblowing platform
