The Management Company for Assets Arising from the Banking Sector Reorganisation (Sareb) has implemented a strict code of conduct for its employees and for all those involved in its operations. It is a document that reflects the corporate culture and particularly the commitments and guidelines that govern the actions of Sareb.
In short, this code sets out the framework allowing the company to satisfactorily undertake the important task with which it has been entrusted, under the watchful eyes of the authorities and wider society in general.
The Code, which entered into force on May 20 and is available on the company's website, establishes a number of obligations for Sareb's employees, which they must subscribe to annually in a signed statement. The breach of the provisions set out in the Code could result in disciplinary action.
The ethical standards which this code is based on are the ten principles of human rights, employment, environment and anti-corruption regulations, as contained in the United Nations Global Compact.
Thus, Sareb commits itself to undertaking its work under the three principles of integrity, transparency and civic duty.
Objectivity and the management of conflicts of interest
Sareb's code of conduct sets out measures to avoid conflicts of interest. In the event that such a situation should occur, the employee is obliged to make a notification in writing and refrain from participating in any decisions that could affect their own interests.
Moreover, employees of Sareb with relevant positions must keep the company informed of those who form part of their immediate circle, and any other persons, or entities, with whom they share economic interests.
In addition, neither managers nor employees with access to non-public, confidential information on Sareb's assets are permitted to rent or buy said assets. The restriction also extends to members of their immediate family.
Another chapter of the Code of Conduct refers to the treatment of such confidential information, which should be safeguarded and protected from improper or unauthorised use. All Sareb employees are required to report any suspicions in this regard.
Additionally, in order to preserve objectivity and impartiality in decision making, Sareb prohibits the acceptance of gifts and entertainment from clients, suppliers, or any other person or entity intending to do business with the company.
The active fight against fraud
The Code of Conduct provides for the adoption of various measures to prevent the company from becoming embroiled in operations or transactions linked to criminal activities such as money laundering, terrorist financing, fraud or any form of corruption.
In addition to meeting all requirements set out in the Law of 10/2010 on the Prevention of Money Laundering, the company will have a internal monitoring system, allowing it to ensure that all regulations and ethical standards are complied with. To ensure this, Sareb has set up a communication channel to facilitate the filing of complaints referring to violations.
Strict corporate regulations
The approved Code of Conduct is another step in the company's commitment to meet the highest ethical principles both nationally and internationally. To this end, since it was founded in November 2012, the company has had internal regulations and rules in place that govern further action involving all stakeholders.
These regulations are based on the current norms guiding listed companies, as well as other relevant regulations. In addition to the Employee Code, there are now also rules with regard to employee relationships with suppliers.
In this respect, the Code outlines the principles and standards of conduct that should govern relations with suppliers and states that Sareb "structures its procurement processes on the principles of transparency, competitive bidding and non-discrimination." Furthermore, it indicates that the company encourages rotation and will avoid concentrating on any single service provider.
The company has also imposed strict regulations to avoid conflicts of interest for the Board of Directors, which goes beyond abstention requirements imposed by the Corporations Act.