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1- Zero tolerance plan with corruption: Kavelin Commitments


Based on the analysis of the activities most exposed to the risk of corruption and following the stipulations in its Management Code, KAVELIN assumes the following commitments in the performance of its functions:

1.1.- Bribes

Kavelin prohibits the use of any form of illegal payment, with pecuniary means or any other kind provided that it represents an advantage for a person of material or moral value, financial or non-financial, and considered relevant according to the customs, with the objective of obtaining any advantage in relations with interested parties, understanding that the concept of "advantage" includes the favor treatment or the guarantee of obtaining benefits. Naturally, the prohibition also applies to employees who, by virtue of their functions and activities in Kavelin, intend to accept and / or offer bribes for their own benefit or that of family members, associates or acquaintances.

In the event that bribes are promised, offered or solicited, Kavelin employees must inform their direct superior and the Ethics Committee through the channel provided for the reception of notices.

1.2.- Donations to political parties

Kavelin refrains from exerting any kind of unlawful pressure, directly or indirectly, on politicians; does not finance political parties, nor its representatives or candidates, neither in Spain nor abroad, nor does it sponsor any event whose exclusive purpose is political propaganda.

Any critical situations in the observance of such provisions and always in accordance with the legislation in force, must be submitted to the previous examination of the Ethics Committee of Kavelin.

1.3.- Donations to charities and sponsorship

Kavelin states in its Corporate Social Responsibility Policy an strong social commitment, therefore, it collaborates with various NGOs, non-profit always, as a mean to facilitate volunteer activities of its employees.


2.- Zero tolerance plan with corruption: Application

Respect for Kavelin's commitments to the fight against corruption requires the involvement of all stakeholders in the implementation of the Plan.

2.1- Relations with third parties

2.1.1.- Agents, consultants and intermediaries


Any person acting on behalf of Kavelin is obliged to sign a declaration committing to comply with the provisions of the Code of Conduct and Zero Tolerance Plan with Corruption.

2.1.2.- Procurement procedures

Kavelin conducts its procurement procedures for buying and selling correctly and transparently.

Internal procedures include adequate controls to ensure the transparency and correctness of the supplier selection process, and the management and implementation of the corresponding contract.

During the process of selection of potential suppliers, the commitment is assessed to comply with the principles of the Code of Conduct and Zero Tolerance Plan Corruption of Kavelin.

In the event is detected a conduct who violate the Zero Tolerance Plan with Corruption by suppliers and contractors, Kavelin, within the limits established by law, will apply the measures it deems appropriate, including contractual termination.

2.2.- Human resources

During the recruitment process, the selected candidates are asked to sign a declaration that they undertake to respect the provisions of the Code of Conduct and the Zero Tolerance Plan with Corruption.

All internal documents related to personnel management, will refer to the provisions of the Zero Tolerance Plan with Corruption.

No one shall be penalized for refusing the payment of bribes.

2.3.- Training

Para garantizar la difusión del Plan de Tolerancia Cero con la Corrupción y su correcto entendimiento, se llevan a cabo actividades de formación para todo el personal.

Los principios, compromisos y procedimientos de aplicación son parte integrante de sesiones formativas de profundización específicas para cada grupo profesional.

2.4 Avisos

Employees and managers of Kavelin are required to give notice of any breach or suspected infringement of the Zero Tolerance Plan with Corruption and, more generally, of the Kavelin Code of Conduct.

In all cases, Kavelin guarantees the confidentiality of the identity of the informant, without prejudice to the legal obligations envisaged and the defense of the rights of the Company or persons involved in the testimony.

2.5. Communication

Staff is informed of the existence of the Zero Tolerance Plan with Corruption, through the internal communication tools.

All employees receive a copy of the Zero Tolerance Plan with Corruption.

In all contracts signed by Kavelin, an information note on the adoption of the Zero Tolerance Plan with Corruption of Kavelin is included.
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