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 Cooperation 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, approved in 2013, that establishes the moral reference framework that must govern the behaviour of the company and its employees, which is also available on the corporate website.
The Code of Ethics has been approved by the administrative bodies of the various Saba companies and has been made available to all Saba employees in Spain, Portugal, Italy and Chile for their knowledge, with this Code of Ethics being binding on all employees. In 2021, the adoption and dissemination of the Code of Ethics for companies in Germany and Andorra and the mechanisms for dissemination to employees in the United Kingdom, the Czech Republic and Slovakia will be analysed. The behaviour of all employees must fully respect the legal provisions in force in any part of the world in which Saba is active.
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.
In the development of the principles of the Code of Ethics, Saba has approved a Policy for Prevention of Corruption and for Relations and Correspondence with the Public Authorities and Third Parties, as well as internal standards developing that policy, in order to set the criteria that the companies that make up the Group must meet in dealing with Public Authorities and both domestic and foreign officials and authorities, 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 for Corruption policy both in relations with public authorities and with private business.
The Code of Ethics and Anti-corruption Policy are applicable to Saba and the companies it controls, both in Spain and in the other countries where it is present, notwithstanding the adjustments that may be made in order to respect the specific legislation of each of the countries where these companies are located. It is binding on the members of Saba’s Management Bodies, its directors and all its employees.
Saba’s main actions in ethical conduct
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. Updating of Saba’s Criminal Risk Matrix and existing controls and the Crime Prevention Manual – and actions to satisfy the anti-corruption ISO standard. Deployment of the Handbook in all the countries where the company operates.
Crime Prevention Model control structure
- Board of Directors
- Ethics Committee
- Criminal Risks Prevention Commission
- 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 (Spanish Compliance Association).