On September 11, 2020, SUMINISTROS, IMPORTACIONES Y MANTENIMIENTOS ELECTRÓNICOS S.A.U. (SERMICRO) approved a new Corporate Compliance Program. This Program is intended to promote a true ethical business culture and reaffirms the Group’s culture of respect for the Law.
An active role has been adopted in the fight against crimes in business activities and, for this reason, specific technical, organizational and personnel measures have been adopted, as well as surveillance and control measures, and the appropriate sanctioning regime to prevent the occurrence of any type of infraction or illicit action.
On December 16, 2021, the SERMICRO Group has adapted and modified its policies regarding the Defense of Competition, thus complying with the current requirements contained in the European regulations ISO 37001 and UNE 19601.
In this context and to meet this objective, the SERMICRO Group has internally published the following documents:
• Information Security Protocol
• Crime Prevention Plan of the organization with its attached Policies:
• Crime Prevention Plan
• Code of Conduct of the SERMICRO Group
• Computer Conduct Policy
• Policy on Professional Courtesies (included in the Anti-Corruption Policy)
• Policy on Prevention of Money Laundering and Financing of Terrorism
• Anti-corruption Policy
• Industrial and Intellectual Property Rights Protection Policy
• Confidential Information Treatment Policy
• Personal Data Protection Policy
• Environmental Protection Policy
• Regulatory Compliance, Anti-Bribery and Conduct Contrary to the Right to Defense of Competition Policy.
• Policy for the prevention, detection and action against Workplace Harassment
The design of the Corporate Compliance Program includes and applies good practices for the prevention of criminal risks and the promotion of ethical business behavior, in line with the requirements of the Penal Code.
Any person who has knowledge or well-founded suspicion of any type of infraction or illegal action must report it through the following email address: firstname.lastname@example.org or to the postal address, Canal Etico Grupo Sermicro, C/ Pradillo, 48-50. 28002 Madrid, Spain, or by leaving a voice message on the following telephone number: 911775278.
This channel is both a way to report non-compliance with the rules contained in the Code of Conduct, and a means to resolve any doubts that may arise from its application.