Corporate Compliance Program
Dated March 30, 2017, Cobra Group has approved a Corporate Compliance Program. That Program has the purpose of promoting a real company ethical culture and reaffirms the respect to legislation Group’s culture.
An active role for the fight against crimes in company activities has been adopted and, for that reason, the technical, organizational and personal concrete measures, as well as the surveillance and control measures, and the appropriate penalty system to avoid the production of any infringement or illegal actions have been adopted.
In this context and, to comply with this objective, Cobra Group has published internally the following documents:
- ACS Code of Conduct. (pdf)
- ACS Industrial General Protocols:
- ACS lndustrial Corporate Compliance Program frame Protocol.
- Normative Compliance Protocol.
- Alleged Irregular Facts Communication Protocol.
- Corporate Defense Procedure Activation Protocol.
- Professionals Training Protocol in matters of Corporate Compliance.
- Protocol about the profile, experience and organic location of the Corporate Compliance Supervisor.
- Internal Operating Instructions.
- COBRA Crime Prevention Plan with their appended documents:
- IT Code of Conduct.
- Professional Courtesies Manual.
- Protocol on Prevention of Money Laundering and Terrorism Financing.
- Anticorruption Protocol.
- Protocol on Industrial and Intellectual Property Rights.
- Protocol Confidential Information Treatment.
- Protocol Private Data Protection.
- Protocol on Environmental Protection.
The design of the Corporate Compliance Program includes and applies good practices on criminal risks prevention and promotion of an ethical company behavior, aligned with the exigencies of the Criminal Code.
Any Professional having knowledge or with a suspect of any kind of infraction or illegal actions have to be communicated to the following email: firstname.lastname@example.org or to the postal address, Canal de Formulación de Denuncias, Grupo Cobra, Calle Cardenal Marcelo Spínola, 10, 28016 Madrid, Spain.
Any doubts concerning about Corporate Compliance Program should also be addressed to the aforementioned email.