Ensuring that Grupo Velora represents excellence in quality worldwide, in all aspects, is a cornerstone of our strategy. Excellence in management includes diligent, loyal, and ethical conduct by each and every one of us—from the members of the Board of Directors of Velora Investa, S.L. and the Steering Committee to every employee who makes up the Group. This document contains the values and principles upon which Grupo Velora’s activities are based and serves as a guide for their understanding and adherence, insofar as they constitute the foundation of all the Group’s activities.
Loyal and ethical behavior, with full respect for the law and our principles and values, is essential to guarantee the sustainable growth of our business group, as well as to maintain Grupo Velora’s reputation both nationally and internationally.
Velora possesses a strong corporate culture with a powerful sense of belonging among our people; this sets us apart and forms the basis for the trust our clients place in our company every day.
Excellence in what is set forth in this Code of Ethics and Conduct—which must guide all our actions to ensure they are aligned with the behavior expected of the Group—will distinguish us as a company in the future.
This Code of Ethics and Conduct governs the professional actions and relationships of employees, executives, and directors with clients and potential clients, suppliers, colleagues, competitors, public administration bodies, the media, and society at large. Furthermore, it provides guidance so that all such individuals know how to communicate potential conflicts, doubts, or violations thereof.
This code does not intend to cover every situation that may occur, but rather to establish a framework of reference to govern all activity. The honesty, integrity, and sound judgment of these professionals are fundamental to the organization’s reputation and success.
Velora values its corporate culture as a key asset, integrating the principles and values that inform its actions and define the organization’s way of doing things. The Group is committed to compliance with the law, ethics, integrity, occupational health and safety, human and labor rights, the environment, and quality in all its internal and external actions. This affects all members of the organization in their daily activities. To this end, specific rules exist as a result of conducting business with knowledge, common sense, order, and responsibility.
Actions carried out in the exercise of entrusted responsibilities and functions must be guided by professional rigor, strict compliance with applicable regulations, and the principles established in this Code.
Legal Compliance
Ethical behavior necessarily entails a firm commitment to compliance with the law and applicable regulations in the markets where Velora operates. Thus, the Group is firmly committed to complying with current national and international regulations in the development of its business activity, following a zero-tolerance policy regarding conduct aimed at non-compliance with the law. Likewise, the organization will actively collaborate with public administrations and the judiciary upon any requirement.
Occupational Health and Safety
Health and safety in the workplace is a priority for the Group. Management will adopt all preventive measures established by law, and all members of Velora shall comply with health and safety regulations to avoid and minimize occupational risks.
Prevention of Harassment
We have a zero-tolerance policy against any form of violence, harassment, and/or physical, sexual, psychological, or verbal abuse. Any conduct that may create intimidating, offensive, or hostile situations for any person or stakeholder is expressly prohibited.
Non-Discrimination
No member of Velora shall be discriminated against, nor may they discriminate, based on birth, race, sex, religion, opinion, or any other personal or social condition or circumstance. Group members must foster an inclusive culture and guarantee equality.
Human and Labor Rights
We are committed to respecting and promoting human rights in all our activities. We guarantee fair, safe, and equitable working conditions; we reject any form of discrimination, harassment, forced or child labor; and we promote freedom of association and dignified treatment for all people.
Crime Prevention
The administration and senior management will provide an appropriate control environment to evaluate and manage the Group’s criminal risks. They will oversee the prevention of criminal offenses through a management system for compliance with current legislation.
Prevention of Money Laundering and Terrorist Financing
Velora is committed to preventing Group companies from being used to conceal the origin of illegally obtained profits or being linked, directly or indirectly, to terrorist financing activities. For this reason, internal controls are implemented specifically to prevent such conduct.
Environmental Protection
Everyone in the Group must perform their duties in compliance with environmental regulations, ensuring that our business activity has the lowest possible environmental impact.
Financial Information
Members of the organization must follow accounting standards and principles, report on the financial situation with accuracy and integrity, and maintain adequate internal processes and controls. Accounting and financial reports must comply with applicable listing, legal, and regulatory requirements.
Conflicts of Interest
Members of the organization must act with loyalty, honesty, and professionalism, making business decisions based on the best interests of the organization and not on personal considerations or relationships. They must avoid situations where personal interests could conflict, or even appear to conflict, with the interests of the Group.
Gifts and Invitations
The acceptance or offering of gifts may lead to situations of conflict of interest (real, potential, or apparent), as well as situations where objectivity in decision-making is compromised. Therefore, as a general rule, we do not encourage the acceptance or delivery of gifts or invitations; only those that strictly comply with our Anti-Corruption Policy and, of course, the law, may be given or accepted.
Financing of Political Parties
The law prohibits companies from financing political parties. Therefore, the use of Velora funds to make any financial contribution, direct or indirect, to any political party or affiliated entities is not permitted.
Prevention of Corruption and Bribery
Bribery and corruption are completely incompatible with our way of acting. At Velora, we have a zero-tolerance policy toward corruption and bribery in all their forms, regardless of whether they are directed at a public official or a private entrepreneur.
Intellectual Property
Intellectual property created by each employee as a result of their professional performance is transferred and assigned to the Group by law and/or their employment contract or other agreement, with exceptions stipulated in international conventions, local legislation, or specific conditions agreed upon with the employee in question.
Confidentiality
Members of the organization must not access, use, or disseminate unauthorized information. This could cause damage or prejudice to Velora or third parties; therefore, accessing, using, or disclosing information is not permitted unless properly authorized to do so.
Protection of Personal Data
There is a commitment to the proper use of information regarding employees, clients, suppliers, and other stakeholders, respecting their right to privacy. Professionals who, due to their activity, handle such personal data will do so in accordance with personal data protection legislation.
Code Compliance Body
The body responsible for ensuring the compliance, updating, and dissemination of the Code is the Compliance Officer. Any questions or requests for information regarding this Code must be addressed to said body through the Ethics Channel. All members of the Board of Directors of Velora Investa, S.L., Executives, and employees of Velora to whom this Code applies, as well as professionals who join or become part of the organization, expressly accept its full content. Velora will communicate and disseminate the Code of Ethics and Conduct among its recipients.
Ethics Channel
The company analyzes and responds to inquiries and information received as a result of the application and fulfillment of the Code of Ethics and Conduct. Anyone who suspects the commission of an illegal act must report it to the compliance body. In this regard, so that employees can report potential breaches or concerns regarding this Code or other internal policies, they may contact the Compliance Officer via email at compliance@cunext.com or through the Ethics Channel, which is integrated into the Internal Information System and can be accessed through the corporate website (www.velorainvesta.com).
Disciplinary Regime
Failure to comply with this Code may result in sanctions in accordance with current labor regulations, including the termination of the contractual relationship, without prejudice to other administrative or criminal liabilities that may also apply in specific cases. In any event, any disciplinary procedure that takes place will be governed by strict respect for fundamental rights and the guarantees inherent to all disciplinary proceedings.
Validity and Updates
The Code of Ethics and Conduct was approved by the Board of Directors of Velora Investa, S.L. in January 2018, entering into force upon its approval and remaining fully valid as long as no modifications are made. Any modifications made to the Code of Ethics and Conduct shall be approved by the Board of Directors, upon the proposal of the Compliance Officer and following assessment by the Audit Committee, and will be applicable from the day following their communication to all persons affected by it.