Ethics and compliance
Our commitment is reflected in policies, procedures and tools that ensure integrity in our decisions and relationships.
Code of conduct
This document outlines the ethical principles and standards of behaviour that guide all Exolum professionals.
It establishes the values upon which we build our relationships with customers, suppliers and employees, promoting responsible, transparent and lawful conduct in all the countries where we operate.
Our policies
At Exolum, we believe in doing things right; with transparency, responsibility and respect for people and the environment.
Our policies reflect the principles that guide every decision and every project we undertake.
Corporate crime prevention
Managing Conflicts of Interest
The purpose of this Conflicts of Interest Management Policy is to establish the rules and guidelines to be followed by Members of the Organisation and Business Partners when faced with potential conflicts of interest.
As set out in Exolum’s Code of Conduct, in the performance of their professional duties and responsibilities, members of the Organisation shall act with loyalty to the Group, avoiding conflicts between personal interests and those of the Group.
Data Protection
The EXOLUM Group’s Data Protection Policy sets out the general framework for ensuring the privacy and protection of personal data in all jurisdictions where it operates. In addition, it defines a governance model to ensure effective interaction among all stakeholders and continuous training for employees in this area. This policy also includes principles of integrity, confidentiality and proactive accountability.
Anti-Corruption, Anti-Bribery and Anti-Fraud
Use of the Code of Conduct Channel
This channel enables Exolum’s stakeholders to report any suspicious or unusual events or conduct of which stakeholders become aware and which, in their opinion, could constitute a potential irregular act. This includes, in particular, situations that may give rise to criminal risks. Reports may be submitted either on a named basis, with the identity of the reporting individual disclosed, or anonymously and will be received by the Compliance Department, which shall assess and manage each case in accordance with the nature and characteristics of the matters reported.
The Policy Governing the Use of the Code of Conduct Mailbox, approved by the Board of Directors, aims to define the criteria governing the use of the various reporting channels available within Exolum. Through these channels, Members of the Organisation, Business Partners and Third Parties may submit enquiries and/or reports concerning potential breaches or non-compliance that may arise within the Organisation in the course of its business activities.
Code of Conduct Channel
This channel allows for the reporting of any suspicious or unusual fact or conduct of which our stakeholders become aware and which, in their opinion, could constitute a potential irregularity, including possible situations of criminal risk.
These reports may be submitted identifiably or anonymously and will be received by the Compliance Department, which will determine the processing required in each case based on the nature of the reported facts.
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