Compliance System
Since the laying of the foundations of IDOM by Rafael Escolá in 1957, the bases of its operations have been built on trust, commitment and the maximum personal and professional development of the people who make it up, in a framework of freedom and respect, with impeccable personal comportment, propagating a policy of zero tolerance for crime or illicit acts, behaving in an exemplary manner with people, clients, suppliers and, in general, all Organizations and Institutions with which personal and professional relationships are maintained.
The first words on the company’s principles were put to paper in 1965, when a series of documents were drawn up. A set of values was laid out for IDOM, and it was mandatory that they be abided by. This set of values were the foundation stones of our current Compliance System.
Subsequently, as the company grew, the IDOM Board of Directors collated these documents on the style and governance of the company, and in 1978 the first version of the company's Philosophy was issued.
Over the years, these documents underwent small revisions, until 2005, when the Board approved a new version of the two documents, Philosophy and Personal Comportment. These documents describe the values of the company and offer basic guidelines on how IDOM people should behave while carrying out their professional activity.
In 2010, as a result of the reform of the Spanish Penal Code, IDOM implemented a specific regulatory Compliance System with the objective of preventing, detecting and reacting to the risks of possible inappropriate behavior and illegal acts of any kind. This new system was added seamlessly to the system of values and comportment that had been instilled in the company since its foundation.
Finally, in 2021, with the strong determination to further expand our culture of compliance and adapt our Compliance System to include existing best practices, such as the Compliance Guides of the Spanish National Commission of Markets and Competition (CNMC) and Transparency International Spain and the UNE standards ISO 19601 and 37001, the Board carried out the latest revision and updated the Compliance System. The system is always revised and updated when internal circumstances (e.g., new business lines) or external factors (e.g., regulatory changes) make this necessary. The main elements include:
The Compliance Policy has been established by the IDOM Board to ensure that its Compliance system is living, effective and always up to date and that it evaluates, prevents and minimizes the risks that our activities may generate, while controlling and managing them appropriately.
Our Compliance System has all the necessary personal, material and financial resources, including external legal advice, when necessary, to comply with the law and any type of regulations to maintain impeccable ethical conduct, as well as to be extremely diligent in the prevention, detection, and punishment, if necessary, of possible inappropriate and/or illegal conduct.
Likewise, the Compliance Policy reinforces IDOM's commitment to using the best practices of Good Corporate Governance and Corporate Social Responsibility, with equality, diversity, with respect for human rights, the environment, health and the occupational safety and another series of values that have guided its way of acting since its foundation.
This Compliance Policy applies to the Board of Directors itself, to its Management and to all the people of the entire group of companies that make up IDOM, collaborators, clients and suppliers. It also applies to the business partners and professionals of IDOM.
This is the basic standard of the IDOM Compliance Policy.
The Code of Conduct, in addition to highlighting our high principles and values and further strengthening the culture of responsibility and compliance that exists in IDOM, includes specific instructions, behavioral guidelines and mandatory rules covering various matters and areas, to guarantee that we carry out, and will continue to carry out, our daily activities in accordance with ethics and legality.
It is really the cornerstone of the Compliance System, implemented to prevent, avoid and detect the commission of any illegal act and/or breach of IDOM's own principles.
Corruption constitutes a threat to the primacy of law, democracy and human rights, undermining the principles of good administration, equity and social justice, distorting competition, hindering economic development and endangering the stability of democratic institutions and the moral foundations of society.
It is one of the main problems that exist today in our society, for which there is great concern at national and international level, and against which it is necessary to actively combat by implementing all the necessary mechanisms for its detection and elimination. IDOM has developed a specific policy, which sets out the different forms of corruption that exist, as well as the appropriate procedures for their detection and complete elimination.
Money laundering is a strictly illegal activity in Spain, in the European Union and in most countries of the world, which, in simple terms, consists of performing (intentionally or through gross negligence) any act or transaction that helps to conceal or disguise the criminal or illegal origin of funds, helping them to enter the financial system or commercial or legal transactions with an appearance of legality.
Due diligence implies a series of requirements for the parties obliged to cooperate in the prevention of money laundering. Although IDOM is not an obligated party according to the current regulations on money laundering, it has the firm determination to adopt a series of measures to avoid the risk of committing a criminal offense, even if it is due to imprudence.
For this purpose, this Code sets out certain identification rules that will also contribute to avoiding or minimizing the risks of other possible crimes related to corruption, punishable insolvency, crimes against the public treasury or social security, among others. In addition, they will protect our own interests, especially from becoming victims of certain types of fraud.
IDOM is committed to maintaining work environments that are totally free from harassment or violence of any kind, in which dignity and diversity are fully respected and the professional and personal development of all people is facilitated, as reflected in the documents of Philosophy and Personal Comportment.
IDOM does not tolerate violence in any shape or form, that is, moral harassment, discriminatory harassment and sexual harassment, or harassment involving violence at work, both physical and psychological, whether carried out with a discriminatory motive or not.
The purpose of the Code for the Prevention of Harassment and acts of violence at work is to establish measures to prevent and avoid any conduct of harassment or acts of violence.
The Competition Policy of IDOM contains the essential guidelines that all IDOM people must consider, each day, when carrying out their professional functions and activities, in order to comply with antitrust regulations and ensure that business conduct is not contrary to free competition and the public interest.
The figure of the Compliance Officer is an important component in any compliance system that seeks to be effective. At IDOM, we have an Ethics and Regulatory Compliance Committee (Comité de Ética y Cumplimiento Normativo - CECN), a collegiate compliance body with the necessary resources, autonomy and independence to carry out its functions. The regulation of the functions and powers of the Ethics and Regulatory Compliance Committee are contained in its articles of association, in line with the best standards of compliance.
Among other activities, on an annual basis, the CECN will carry out random controls to test the effectiveness of the System, verifying its application in certain areas or matters.
IDOM has set up and made available to everyone in the organization, as well as to third parties, a confidential Whistleblowing Channel. If desired, it can be used with anonymity and offers the highest safeguards for both the person making the complaint and the person denounced.
The Whistleblowing Channel is the tool that allows the communication of activities and behaviors that may imply a breach of the principles and standards described in the Code of Conduct. These may also be a breach of the protocols and procedures that make up the Compliance System, as well as behavior contrary to the Philosophy and Personal Comportment of IDOM.
IDOM also has a Channel for Queries and Suggestions that offers the same guarantees to its users.
The Queries and Suggestions Channel is the tool that allows questions to be raised in relation to the Ethics and Regulatory Compliance Committee about, for example, how to act in a situation that may entail a risk of non-compliance, the content of the Code of Conduct, policies and/or of the applicable regulations in IDOM. Suggestions not only contribute to the continuous improvement of the organization, but also serve as a vehicle for the active participation of everyone.