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Criminal Compliance and Anti-Bribery Program

Compliance Updated January 2021

AFR-IX telecom is fully committed to promoting a true ethical business culture that reaffirms its commitment and demand for all members of its Organization to comply with and respect both the law in force in its broadest terms and more specifically at the criminal level, and the provisions of its Compliance Program, implemented as early as 2016.

As a result of the development of the group's companies and the evolution of legislation and compliance policies, as well as the willingness of the company's partners to carry out ethical and compliance management, they have decided to add an Anti-Bribery Program to their Criminal Compliance Program. At the same time, they have decided that both are certifiable and therefore this document has three objectives:

  1. To provide the company AFR-IX telecom, based in Spain, with a Criminal Compliance and Anti-Bribery Program.
  2. Begin implementation at the headquarters and activities in Spain, so that this experience is useful for subsequent implementation in all subsidiaries.
  3. That both programs are certifiable

In order to achieve these three objectives, the Manual of Criminal and Anti-bribery Compliance was prepared to replace the previous Manuals and their annexed protocols and was drawn up in accordance with the international standards ISO 19600:2014 and UNE 19601/2017, as well as UNE-ISO 37001:2017.

AFR-IX Telecom intends to establish at its core ethical principles and codes of conduct which correspond with ethical values prioritizing human dignity and fundamental rights of the individual, as well as those of society as a whole. AFR-IX Telecom believes in fairness and congruence with socially-accepted moral principles, as well as with the rights and duties established by the Spanish Constitution.

These codes of conduct and principles shall be accepted and implemented by all members of the company.

The implementation of the guiding principles of AFR-IX Telecom policy has resulted in the following outline: The ethical climate is that formed as a result of the conduct of members of the company, which in turn is guided and reinforced by the commonly-accepted standards.

AFR-IX Telecom's ethics are reflected in the following areas and principles: This Code of Ethics aims to define the conduct expected of AFR-IX Telecom members and is applicable to all of them. It shall establish the required standards of behavior and the criteria which govern the decisions made by all members. A code of ethics is a standard of behavior, as well as a tool for cohesion, cooperation and loyalty. It promotes job security and the best interests of the organization. AFR-IX Telecom wishes to inspire people associated with the organization to adopt conduct faithful to current legislation, to this Code and to the ethical principles widely accepted in society. As such, it requires commitment from partners and management, and establishes the principles by which every professional within the company should be guided.

The Management of the company wishes that the company act in accordance with good-governance recommendations and widely-accepted principles regarding social responsibility. It also fulfils its criminal-prevention obligations as regards the criminal liability of legal persons. It also requires the commitment of the company to ethics and transparency, and establishes principles and standards intended to guarantee ethical and responsible behavior from all AFR-IX Telecom members while undertaking professional activities.

Our guiding principles

Business Ethics: A set of implicit or explicit codes of conduct that govern decision-making within the organisation.

Dignity of the individual: Every individual has the right to be considered an end in him or herself, without that ever hindering their personal development.


Ethical principles: Guaranteeing the dignity of the individual:

  • Autonomy: Freedom.
  • Equity: Equality of opportunity.
  • Promoting the right of any person or organisation to develop their capabilities.


Ethical standards: Allowing principles to be implemented:

  • Truthfulness: Reporting truthfully.
  • Confidentiality: Respecting the intimacy and privacy of individuals and organizations.
  • Loyalty: Loyal fulfilment of obligations.


Principle of professionalism: Diligence, accountability and efficiency in the course of performing tasks and providing services.

Principle of integrity: Acting loyally, in good faith, honestly, objectively and in a manner coherent with the interests of AFR-IX Telecom, its values and the principles established in the Code of Ethics.