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Annual Report 2021

Annual Report
2021

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ESG: Sustainability

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ESG: Sustainability

Corporate
governance

Respect for human rights is one of the main obligations assumed by Saba in the performance of its operations and procedures. The Group is taking as a reference the regulations set forth in the United Nations Guiding Principles on Business and Human Rights in the Guidelines of the Organisation for Economic Co-operation and Development (OECD). Likewise, the main conventions of the International Labour Organization (ILO) are adhered to in the area of occupational rights and, in general, the legal requirements of each country in which Saba operates are strictly followed.

Saba has a Code of Ethics, approved in 2013, which established the benchmark ethical system that must govern the performance of the company and its employees and which, furthermore, is available on the corporate web page.

saba.eu/en/corporate-information/code-of-ethics

The conduct of all employees must comply fully with the legal provisions in force in any part of world in which Saba deploys its activities

The Code of Ethicswas approved by the governing bodies of the different Saba companies, which has been provided to all Saba employees in Spain, Portugal, Italy and Chile for their knowledge, and are binding for all employees. In 2021, the approval and publication of the Code of Ethics has continued to be analysed in the remaining countries in which the Group operates. In this regard, the Code of Ethics has been provided to employees in the United Kingdom, the Czech Republic and Slovakia, and is in the process of being extended to Germany and has been published at the investee Geever. The conduct of all employees must comply fully with the legal provisions in force in any part of world in which Saba deploys its activities.

As stipulated in article 5 of the Code of Ethics, Saba assumes the commitment to act at all times in accordance with the prevailing legislation, respecting human rights and the freedom of people. Specifically, with regard to respect for human rights, article 6 of the Code of Ethics stipulates that Saba does not accept any conduct in its dealings with consumers or third parties that may be interpreted as discrimination due to race, ethnic group, gender, religion, sexual orientation, trade union membership, political ideas, convictions, social origin, family situation or disability or intimidating or offensive conduct.

Saba also has a Procedural and Prevention Protocol regarding Employment and/or Sexual Harassment available to all employees.

To implement the principles of its Code of Ethics, Saba has approved a Policy to prevent corruption and for relationships and dealings with the public administrations and with third parties, and internal regulations to implement such policy, to set the criteria that must be met by Group companies to comply with dealings with public administrations and both national and foreign civil servants and authorities and in their relationships with other companies. The aforementioned regulations have the main objectives:

  • Establish the procedural principles for employees in their dealings with public authorities and private companies
  • Protect the process of free competition and participation in all public tenders in which Saba companies can submit a bid
  • Protect free competition and involvement in the acquisition and/or delivery of goods and/or services
  • Establish Zero Tolerance to Corruption, both in relationships with the authorities and in relationships with private businesses

The Code of Ethics and Anti-corruption Policy apply at Saba and at companies that control, both in Spain and in the other countries in which it is present, all of the foregoing without affecting the adaptations that may be implemented to comply with the specific legislation of each of the countries in which these companies are based. It is binding for the members of Saba’s Governing Bodies, its executives and all its employees.

Saba’s main procedures in ethical conduct

Since 2011, Saba approved and implemented different regulations and procedures to consolidate transparency, efficiency, responsibility and sustainability as the basic pillars to guide company procedures. It has also implemented a series of crime prevention measures.

  • Crime Prevention Manual, approved in its initial version by the Board of Directors of Saba Infrastructures in March 2017 and subsequently updated in 2019 and 2021.
  • Update of Saba’s Criminal Risk Matrix and of the existing controls and the Crime Prevention Manual. Extension of the latter in all countries in which the company carries out its activities.
  • Prevention Model control structure.
    ‐ Board of Directors
    ‐ Ethical Committee
    ‐ Criminal Risk Prevention Committee
  • Ethical Channel. Through which signs or suspicions of conduct that breaches the law and/or the Code of Ethics can be reported.
  • Specific training for employees, in person and telematically through the Saba Campus.
  • Membership of ASCOM (Spanish Compliance Association).
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