3 Saba

Ethical conduct

Ethical conduct

Respect for human rights is one of the main obligations that Saba takes on in the development of its operations and actions. The Group uses as its reference the regulations set forth in the United Nations Guiding Principles on Business and Human Rights and in the Guidelines of the Organisation for Economic Co-operation and Development (OECD). In addition, the main conventions of the International Labour Organization (ILO) in the field of labour rights are strictly followed, as well, in general, as the legal requirements of each country in which Saba operates.

Saba has a Code of Ethics that establishes the moral reference framework that should govern the behaviour of the company and its employees, and which is also available on the corporate website.


The Code of Ethics has been approved by the Management Bodies of the various Saba companies and has been shared with the union representatives of the various existing Company Committees. The document is mandatory for all employees of subsidiaries and investee companies in Spain, Italy, Portugal and Chile, notwithstanding the adjustments that may be made to the regulations in order to respect the specific legislation of each one of the countries where these companies are located. In 2019, work was carried out on extending the Code of Ethics in the newly incorporated territories (the United Kingdom, Germany, Slovakia and the Czech Republic).

As established in Article 5 of the Code of Ethics, Saba undertakes to act at all times in accordance with current legislation and with respect for human rights and the freedom of individuals. Specifically, with respect to human rights, Article 6 of the Code of Ethics establishes that Saba does not accept any conduct when dealing with consumers or third parties that may be interpreted as discrimination based on race, ethnicity, gender, religion, sexual orientation, union affiliation, political ideas, convictions, social origin, family situation or disability, or as intimidating or offensive behaviours.

The internal regulation established in this area is the Protocol for Prevention and Action Against Sexual and/or Workplace Harassment. This protocol is available to all employees on the corporate Intranet for consultation and, if necessary, implementation.

Saba has a Code of Ethics that establishes the moral guidelines that must govern the behaviour of the company and its collaborators. It is available on the corporate website


In the development of the principles of the Code of Ethics, Saba has approved the Regulations for the Prevention of Corruption and for Relations and Correspondence with the Public Administration and Third Parties in order to set the criteria that the companies that make up the Group must meet in dealing with the government authorities and officials, as well as in their relations with other companies. Its main objectives are to:

  • Establish principles of action for employees in their dealings with Public Authorities and private companies.
  • Protect the process of free competition and concurrence in all those public tenders to which Saba companies can apply.
  • Protect free competition and participation in the acquisition and/or delivery of goods and/or services.
  • Implement a Zero Tolerance with anti-corruption policy both in relations with public authorities and with private business.


Since 2011, Saba has approved and implemented various regulations and procedures with the aim of establishing transparency, efficiency, responsibility and sustainability as the basic pillars that guide the company's performance. Similarly, it has implemented a series of crime prevention measures.

  • Crime Prevention Handbook, approved by the Board of Directors in March 2017 and updated in March 2019. The general part of the procedure was revised and renamed as the Handbook on the Prevention of Criminal Risks and the Corruption.
  • Deployment of the Handbook in all the countries where the company operates.
  • Crime Prevention Model control structure:
    • Board of Directors
    • Ethics Committee
    • Crime Prevention Committee
  • Ethical Channel. Through which indications or suspicions of behaviours contrary to the law and/or an infraction of the Code of Ethics can be communicated.
  • Specific training for employees.
  • Belonging to ASCOM (Asociación Española de Compliance).