COMPLIANCE

The Compliance and Criminal Liability Prevention Model is a strategic part of Aire Networks del Mediterráneo SLU’s corporate culture. Our company is firmly committed to the principles of integrity and compliance in carrying out all our actions.

Our compliance and social responsibility policy does not just reflect the duty to conform with the regulatory framework in force, but also the fact that we have taken a decisive step and we are striving for a compliance approach based on ethical principles aligned with good practice, transparency and integrity that must govern all relations between our company, employees, clients and suppliers.

We believe in responsible management at all levels in our business operations, which is why our Criminal Liability Prevention Plan, as well as our Compliance Action Protocols, Compliance and Criminal Liability Prevention Policies and Code of Ethics have been developed following the guidelines established in ISO 19600 and UNE 19601 standards. This has allowed us to establish a Compliance Management System (CMS), thus helping to improve how we manage our resources and services and offer a greater guarantee of trust and security for our clients and suppliers.

As part of this pledge to integrity and compliance, Aire Networks del Mediterráneo SLU has set up an email reporting channel canaldenuncias@airenetworks.es so that any of our employees, suppliers, clients or third parties unrelated to Aire Networks del Mediterráneo SLU can draw our attention to any ethical questions or concerns, as well as any potentially important wrongdoing, evidence or suspicion of illicit behaviour, or behaviour that may imply the manifestation of criminal liability.

The reports will be received and processed by members of the Aire Networks del Mediterráneo SLU Compliance Unit, who will adopt all the necessary measures to preserve the identity and guarantee the confidentiality of the data of the people affected by the information supplied, especially that of the person who brought the information to light. Notwithstanding the above, those reports made anonymously can also be processed when they are provided with the minimum content required, and in good faith.

The reports made must contain the information required to analyse the reported acts. Therefore, the communications received must comply with the following minimum requirements:

1. A clear and detailed explanation of the reported acts.
2. Identification of the Department and/or Business Unit in which they have supposedly taken place.
3. Name and contact details of the whistleblower and their relationship with Aire Networks.
4. Identification of the people involved in the reported behaviour or with knowledge of it.
5. When the reported act occurred or has been occurring.
6. A quantification, when possible, of the impact of the reported act on financial statements.
7. If deemed necessary, documents, files or other information deemed relevant for the assessment and resolution of the report should be provided.

Aire Networks del Mediterráneo SLU will not retaliate against anyone who, in good faith (i) expresses any ethical question or concern, (ii) makes the company aware of a possible breach of internal regulations, (iii) reports possible illicit behaviour, and/or, where appropriate, behaviour that may imply the manifestation of criminal liability, or (iv) collaborates in its investigation or helps to resolve it. However, this guarantee does not cover those who act in bad faith with the intention of disseminating false information or damaging our clients, suppliers, employees or company.