Transparency, ethics and integrity

Transparency, ethics and integrity

At Exolum, we promote behaviour based on strict ethical principles, transparency and the fulfilment of our commitments.

The Code of Conduct

This document outlines universally accepted ethical principles and rules of conduct inspired by our Purpose, Mission, Vision and Values. It aims to provide all our professionals, irrespective of their field of work and country, with universal rules of conduct in line with the strictest ethical principles, taking into account the cultural setting in which they work and based on due compliance with

local legislation.


In addition, we are committed to promoting the Code among all our suppliers, contractors and partners in order to establish a bond and behavioural guidelines in keeping with our principles and values.

The compliance policy


The Exolum Group Compliance Policy, approved by the Board of Directors of the parent company, is part of a management system that aims to define the general principles and commitments in terms of compliance that should guide the Group’s conduct and that of each and every company belonging to it.

Through this Policy, which applies to all directors, executives and employees of all the companies belonging to the Group and will be fostered and encouraged among our contractors, suppliers and partners, the Exolum Group will:

  • promote a culture of compliance, and zero tolerance for any breaches of regulations in force, internal procedures and policies or ethical standards.
  • ensure the organisation’s compliance across all of its activities and operations through prevention, detection, supervision, training and response activities, thus avoiding potential penalties, financial losses or damage to our reputation.
  • convey a message of categorical objection to any breach of regulations and a commitment to conduct that is generally based on respect for the law and the promotion and defence of our corporate ethical values to all members of Exolum and to any third parties with which the Group has ties.


To do this, the parent company’s Board of Directors, through its Audit Committee, will adopt the measures needed for implementation and supervision of the development and application of this Compliance Policy.

For its part, the Audit Committee shall ensure that this task is done independently, with support from the Internal Audit and Compliance and Legal Sections of the General Secretary and of the Board.

Senior management shall act as a role model in their behaviour and their degree of compliance with the Compliance Policy, and they shall promote awareness of the policy among all the employees answering to them.

Code of Conduct Mailbox  

This channel facilitates the reporting of any unusual or suspicious conduct or events that come to the attention of our stakeholders and which, in their opinion, could constitute misconduct, including possible situations of criminal risk. Such reports may be anonymous or include the informant’s name and will be received by the Ethics Committee, which will determine the process required in each case based on the nature of the reported events.

Exolum guarantees the confidentiality of the entire process, although it is important to emphasise the need to use this tool responsibly and to consider beforehand the far-reaching consequences of reporting an alleged breach of the Code of Conduct without sufficient and accurate evidence or proof.