Code of Conduct
Introduction
At SedanoMartínez, we fervently believe in the need to act ethically and professionally in order to contribute to the success of our employees, collaborators, customers, business partners and social groups with which we interact.
SedanoMartínez has founded its actions on the values of Integrity, Respect, and Commitment, both internally, with our employees, and abroad, with all the people with whom we interact, always striving to be an example to follow as professionals in the different areas and spheres in which we operate.
This Code of Conduct represents a guide on our ethical and professional values and ideology, which every member of the SedanoMartínez family must live daily, addressing in a general way what is expected of each one of us and how to act in case of facing situations that They can compromise our values such as conflicts of interest, non-compliance with regulations or even anti-corruption acts.
At SedanoMartínez we are proud to have you and we believe that our success depends to a large extent on your professional and personal development, firmly grounded in our values. At SedanoMartínez, how we achieve our goals and objectives is just as important as those goals and objectives.
Values
The following values are essential elements in the actions of every member of SedanoMartínez and are the factors that drive us and distinguish us from our competitors:
• We have Ethics when we are honest and consistent, doing what we say and saying what we think. We do not allow people or situations to modify or influence our actions. We always act in strict adherence to the laws and professional ethics.
• We have Respect when we value the people with whom we interact in an inclusive, educated, professional and ethical way, leaving aside their gender, language and position to appreciate them as people.
• We have Responsibility when we are diligent in carrying out any task entrusted to us, doing it in an Integral way and Respecting others. When we are responsible for our actions and assume the consequences of these, we commit our actions to build a better place where we can compete and succeed fairly.
Use of firm resources
At SedanoMartínez we are all part of a family and as such, we take care of ourselves by respecting our collaborators, spaces and tools that have been provided to us to carry out our activities.
We make appropriate and legitimate use of the resources and tools that are assigned to us, using them only for the specific purposes for which CIIJA has provided them to us, respecting the intellectual property rights and confidentiality intrinsic to them.
The resources of SedanoMartínez must be used mainly in the activities of SedanoMartínez and may only be used for personal use when such use is not in conflict with the laws, this Code of Conduct, the Policies and purposes of SedanoMartínez.
Any activity carried out through SedanoMartínez tools (e.g., email, computer equipment or cell phones) can be considered a statement by SedanoMartínez regardless of whether or not said statement is consistent with our values, for such reason, the appropriate use and professional of the same is indispensable.
If we become aware that someone is misusing SedanoMartínez resources, we are obligated to ask them to stop doing so and inform the SedanoMartínez Compliance Officer of such situation so that the corresponding measures can be taken.
Conflicts of interest
Those situations where the personal interests and those of SedanoMartínez or one of its collaborators or clients may come into conflict, and I know that said situation generates, directly or indirectly, a benefit for us, a family member or a third party, is considered a Conflict. of interest.
SedanoMartínez, nor its collaborators obtain undue benefits and any conduct that may generate or is perceived to generate, an undue benefit is and will be considered a violation of this Code of Conduct and SedanoMartínez Policies and will not be tolerated for any reason.
Sometimes it is possible that a Conflict of Interest may legitimately arise (e.g., the hiring of a family member’s company after carrying out a legitimate bidding process), in which case CIIJA collaborators are obliged to report said situation. to the Compliance Officer of SedanoMartínez, in order to document said situation appropriately and, where appropriate, verify that said Conflict of Interest does not originate from a breach of the provisions of the law, this Code of Conduct and the policies from Sedano Martinez.
SedanoMartínez is committed to having an activity free of Conflicts of Interest, and for this reason, it urges all its collaborators to report the existence of these, whether personal or those of other collaborators, to the SedanoMartínez Compliance Officer so that they can be taken into account. the corresponding measures.
Confidentiality of information
As part of SedanoMartínez’s activities, it is very likely that we have access to an endless number of documents and information from the people with whom we interact (e.g., collaborators, social groups, clients, counterparties, etc.).
Regardless of the purpose for which this information and/or documentation is provided to SedanoMartínez, said information can only be used for the specific purposes for which it was delivered to us and at all times, said information and/or documentation must be handled with character. confidential.
Likewise, we understand that the disclosure of confidential information may entail irreparable consequences for SedanoMartínez, its collaborators, clients, counterparties and any other person who has or may have a legitimate interest in said information. For this reason, all members of SedanoMartínez are obliged to ensure that said information is not disclosed inappropriately and we must urge our collaborators to take care of said information and/or documentation in the same way that they would take care of confidential information and/or documentation. of your property.
If we are aware that someone is using and/or disclosing confidential information and/or documentation improperly, we are obliged to ask them to stop doing so and inform the SedanoMartínez Compliance Officer of such situation in order to take the corresponding measures. .
Interactions with third parties
At SedanoMartínez, we understand that interactions with third parties, whether social groups, contractors, clients and authorities, are necessary to carry out our activities.
SedanoMartínez defines Third Parties as any person, whether physical or moral, over which SedanoMartínez has no control or influence and there is an interaction of any kind.
In this sense, Sedano-Martínez pays special attention to the relationships that its collaborators maintain or may have with Public Officials, these being any person who, regardless of their function, works for any government agency, who may or may not have interference, influence, decision, control or any other participation in any procedure or process of SedanoMartínez, its clients and collaborators.
All interaction of SedanoMartínez and/or its collaborators with Public Officials and/or Third Parties must be based on the principles of respect, impartiality and objectivity.
Consequently, Sedano-Martínez and/or his collaborators may not at any time offer Bribes, understanding as such, any benefit or advantage to any person, either Public Officials and/or Third Parties, so that they do or stop doing any activity that benefits improperly or that is perceived to unduly benefit Sedano-Martínez and/or its collaborators and/or its clients.
Any interaction with Public Officials and/or Third Parties in which SedanoMartínez or any collaborator of SedanoMartínez is requested or has knowledge that SedanoMartínez and/or its collaborators and/or its clients have been requested, a Bribe must be immediately reported to the Compliance Officer of Sedano-Martínez in order to take the corresponding measures.
Our obligations
As part of the SedanoMartínez family, we are obliged to maintain high ethical and professional standards in all the work we do. We always do the right thing even when no one is watching.
Likewise, we are obliged to interact with anyone with respect and kindness. In the same way, we are obliged to respect the environment and spaces where we carry out any activity, whether personal or professional, always promoting a spirit of sustainability and support for the creation of a better future for all.
We must always collaborate in a timely, diligent manner and in accordance with the instructions we receive from our superiors, without being afraid to raise our voices when any instruction or activity is contrary to applicable legislation or values, the Code of Conduct or Policies of SedanoMartínez .
We are obliged to periodically consult the existence of updates to this Code of Conduct or SedanoMartínez Policies and to attend the training that is given for such purposes.
In this sense, all members of the SedanoMartínez family are obliged to:
In those cases where the Code of Conduct, the Policies and the law may conflict, the provision that will prevail will be the most restrictive.
In the event of having any doubt regarding whether an activity or action is or may violate the aforementioned provisions, we have the obligation to consult with our superiors or with the Compliance Officer of SedanoMartínez.
As part of the foregoing, we are also obliged not to tolerate any violation of the aforementioned provisions and, in any case, to report any breach to these immediately to the Compliance Officer of SedanoMartínez in order for the corresponding measures to be taken.
Report violations
As part of our commitment to our employees to support them in living and spreading the values of SedanoMartínez, we have implemented tools to facilitate the reporting of violations of this Code of Conduct, SedanoMartínez Policies and applicable legislation.
All reporting of violations must be impartial and objective and must be based on real facts.
The tools that we put at your disposal are:
Higher Hierarchical Complaint
In those cases in which as collaborators of SedanoMartínez we become aware of the existence of a violation of this Code of Conduct, the Policies of SedanoMartínez or the applicable legislation, we must immediately report it to our hierarchical superior providing all the information regarding the manner, time and place that is within our reach in order to facilitate the reaction of Sedano-Martínez.
These complaints may initially be made orally, but must be documented in writing as soon as possible. At all times the identity of the complainant must be kept anonymous.
Once our hierarchical superior has been informed of a complaint, he is obliged to maintain its confidentiality and only proceed to compile any relevant information to later deliver it physically or via email ([email protected]) to Compliance Officer of SedanoMartínez and that the latter carry out, if appropriate, the corresponding investigation.
Complaint via Official Compliance Channel
In those cases in which as collaborators of SedanoMartínez we become aware of the existence of a violation of this Code of Conduct, the Policies of SedanoMartínez or the applicable legislation that is carried out by our hierarchical superior or by any member of SedanoMartínez who may or we consider to have the possibility of generating retaliation against us, we must immediately report it to the SedanoMartínez Compliance Officer at [email protected], providing all the information regarding the manner, time and place that is within our reach in order to facilitate SedanoMartínez’s reaction .
These complaints may initially be made orally, but must be documented in writing as soon as possible. At all times the identity of the complainant must be kept anonymous.
The Sedano-Martínez Compliance Officer will analyze the documentation provided by the complainant and determine whether or not there is a violation and will carry out the corresponding investigation, if appropriate.
Complaint Via Anonymous Mailbox
In those cases in which as collaborators of SedanoMartínez we become aware of the existence of a violation of this Code of Conduct, the SedanoMartínez Policies or the applicable legislation that is carried out by any member of SedanoMartínez and that we consider that they generate or may generate retaliation against from us, may be reported anonymously in writing that contains all the information regarding the manner, time and place of said violation that is within our reach in order to facilitate the reaction of Sedano-Martínez.
This document must be deposited, at the time that the complainant deems appropriate, in the Compliance Mailbox located at the CIIJA facilities.
Investigation Procedure
Once the Compliance Officer of SedanoMartínez has received a complaint of a violation of this Code of Conduct, SedanoMartínez Policies or applicable legislation, and has determined that it is a valid, objective and impartial violation, the Compliance Officer of SedanoMartínez will proceed to open an investigation file which will be confidential.
The Sedano-Martínez Compliance Officer must carry out, if necessary, personal interviews with the complainant, witnesses, offender and any other person who may have knowledge of the violation in order to gather as much information as possible about it and assess its impact, consequence and corresponding sanction.
The result of the investigation will be shared confidentially in writing with the hierarchical superior of the offender and the human resources area of SedanoMartínez, in order to determine the sanctions and corrective measures that should be implemented if applicable.
Once the aforementioned parties agree with the corresponding sanctions and corrective measures, the offender(s) will be personally summoned to inform them of the violation(s) committed and the measures to be taken.
Complainants may be informed by the Compliance Officer of SedanoMartínez, about the result of the investigation once it has concluded and the corresponding sanctions have been applied.
Sanctions
Violations committed by members of SedanoMartínez to this Code of Conduct, the Policies of SedanoMartínez or the applicable legislation may be sanctioned through:
Any sanction must be informed to the offender, clearly providing all the information on the manner, time and place of this to facilitate the understanding of the offender and promote that it does not occur again.
Recidivism on more than 2 (two) occasions in a period of 3 (three) months of Violations Level 1 and 2, may lead to the termination of the employment relationship with the repeat offender.
Last Update: 04/27/23