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News / November 30, 2017

This document gathers the Regulatory Compliance, Ethics and Good Practices Policy of AFR-IX telecom. It details the principles, criteria and codes of conduct that must govern all staff members in the undertaking of their professional responsibilities, therefore it constitutes a basic pillar of the Group’s Compliance Programme and reflects corporate culture.

AFR-IX telecom is committed to ethical business principles and transparency, promoting among all staff members a professional, ethical, responsible attitude aimed at satisfying the client by offering quality service, both technically and ethically.

Compliance with the policy, standards and conducts set out in this document is mandatory for all staff members, irrespective of the responsibilities or position they hold within the company. Likewise, it is applicable to external advisers, freelance workers and temporary employees providing services to AFR-IX telecom.

The company will promote the adoption of behaviours coherent with this Compliance Policy document among its collaborators and suppliers.

Principles and ethical values.
The following principles and values provide the bases to our activity:
– Integrity.
– Respect for legality, human rights and ethical values accepted in our society.
– Respect for all people, regardless of their sexual orientation, race, religion or beliefs.
– Rejectionofanytypeofharassment,intimidation,abuseorlack of respect.
– Search for and promotion of a positive working environment.
– Responsibility in professional actions.
– Transparency and impartiality.
– Equal opportunities, professional development and no discrimination.
– Teamwork and positive collaboration.
– Promotion of innovation and efficiency.
– Basing growth on quality and good service.

Compliance with current legislation and regulations we have implemented internally.
The people at AFR-IX telecom are committed to complying with current legislation in Spain and the countries in which we work, as well as international agreements, conventions and sectorial codes that affect our activity. This is in addition to internal regulations, and including the values and principles set forth in this document, therefore avoiding any conduct that may harm our reputation or negatively affect our interests.

We will use our ethical channel to communicate any issue or any incident of non-compliance we may detect.

Under no circumstances will we consciously collaborate with third parties in the violation of any law or in any activity that infringes on the principle of legality. To ensure this, we will hold two annual training events and we will commit to the suitable use of the complaint channel.

Internal relations.
Staff at AFR-IX telecom is an important asset, for which reason Management will promote professional development and a positive working environment that motivates the performance of employees. In this regard, any type of occupational promotion will respond to the merit and capacity shown.

Respectful, fair treatment will govern relations between our members.

Hiring will be carried out under the principles of skill and ability to develop the duties of the post to be filled in the most satisfactory manner possible. In order to guarantee this, fair decisions will be taken, with no form of favouritism being shown.

If a family member of another employee or manager at the Group were to be hired, his or her skills suiting the vacant post must be justified and under no circumstances may the hired family member directly depend hierarchically on his or her family member.

Scenarios that involve a conflict of personal interests with the interests of the company will be avoided. No person who forms a part of AFR-IX telecom may use his or her position to obtain particular advantages or opportunities, nor may he or she provide services to competitor companies or groups.

Use of company property must be based on efficiency and responsible use.

Management will strive to maintain a safe working environment, demanding that third parties comply with current regulations in all cases that affect its employees or collaborators, as well as those of third parties.

Consumption, possession, purchase, sale or attempt to do so, as well as the distribution and manufacture of drugs in the workplace is prohibited; consumption of alcohol and undue use of medicines while undertaking activities related to work are also prohibited.

External relations.
All members of AFR-IX telecom are committed to complying with regulations on fair competition, avoiding any practice that limits or restricts it.

All information that is facilitated via any means will be truthful and information received in violation of confidentiality regulations will be rejected.

Likewise, the data entered by any member of the company on its computing systems will be reliable and rigorous, and the person who enters the information will be responsible for checking it.

AFR-IX telecom is committed to the security of payment methods, the protection of personal data, and the prevention of fraud.

Ethics and respect will be the principles that inspire relations with clients and suppliers. The latter will be selected in consideration of objective, transparent criteria.

Internal procedures, detailed in the protocols that form a part of the Compliance Programme, will be scrupulously observed, justifying decisions and keeping documentation for internal inspection, if necessary.

Accepting, offering, and directly or indirectly requesting gifts, favours or any form of compensation that may influence decision making is expressly prohibited. Internal ethical regulations will be considered in the acceptance or delivery of gifts.

With regard to relations with institutions, authorities or civil servants of the Public Administration, international regulations for the prevention of bribery and corruption will be obeyed. Any decision taken in this context will be documented for internal or external inspection, if necessary.

Data protection.
Confidentiality and diligence in using the data to which employees have access will be the bases of company members’ conduct with regard to said data, and they must show respect for the personal and familial privacy of the people whose data may be accessed.

AFR-IX telecom and all its staff members are committed to protecting proprietary rights, industrial property rights, patents and brands, whether they belong to the company or not.

Environmental commitment.
AFR-IX telecom respects the environment and is committed to minimising the environmental impact of all its activities. It will convey this to its collaborators and suppliers.