Saba maintains the will to reinforce transparency, efficiency, responsibility and sustainability as the basic pillars guiding the actions of the company which are channelled to the whole organisation via its governing bodies. In this sense, since Saba was created in 2011, its governing bodies have maintained management and supervisory monitoring of the company as main lines of action, its CEO taking on the responsibility for its daily operations. Everything has one common denominator: the belief that companies must be managed properly and be an active part of the different locations where they operate, of their growth and ultimately, their progress.

The company works constantly to implement the Good Corporate Governance practices with a two-pronged approach. Firstly, it ensures strict compliance with guidelines and, secondly, it provides an integrated security and value system for the entire structure of the organisation and, just in the same way, its stakeholders.

Saba gets the entire organization involved with the best practices of Good Corporate Governance, and has set up communication channels with the Mission, Values, Code of Ethics and the business and development strategy. We are strengthening interaction with stakeholders, enabling us to obtain constant feedback and align the performance of Saba’s activity with expectations in areas such as quality, information and transparency. Saba has joined ASCOM, the Spanish Compliance Association, a non-profit body created in 2014 with the aim of professionalising this function and establishing a channel of dialogue with public institutions.

SABA ACTIONS IN ETHICAL CONDUCT

Since 2011, Saba has approved and implemented different regulations and procedures with the aim of establishing transparency, efficiency, responsibility and sustainability as the basic pillars that guide the company’s performance. Likewise, it has implemented a series of crime prevention measures:

• Approval of the Code of Ethics and its extension to the Group’s subsidiaries
• Distribution of the Code of Ethics to the entire staff of Saba
• Creation of the Ethical Channel (complaints channel)
• Constitution of the Ethics Committee
• Crime Prevention Model
• Constitution of the Crime Prevention and Criminal Justice Commission

Code of Ethics

Today’s social climate requires that companies behave as socially responsible entities, with a commitment to values such as the environment, mutual respect, cooperation and dialogue, but also an overriding obligation to comply with the law, ethical principles and respect for human rights. In this sense, Saba’s Code of Ethics, approved in 2013, has as its mission to ensure our duty with the law and the most positive values of our society.

The Code of Ethics is applicable to Saba and the companies it controls, both in Spain and in the other countries in which it is present, notwithstanding the adjustments that may be made in order to respect the specific legislation of each one of the countries where these companies are located. It is binding for the members of Saba’s Management Bodies, its directors and all its employees.

Crime Prevention Model

The Crime Prevention Handbook, approved in 2017, addresses the latest legislative changes in criminal matters, based on existing control systems and those that, as a result of the revision carried out due to article 31 of the Criminal Code, have been reinforced or introduced in Saba with the aim of preventing crimes being committed within the Group. Saba will now ensure that it establishes the appropriate means of coordination to distribute and ensure awareness of the Handbook in countries where it operates, thus providing homogenisation and coherence to the dissemination of good practices in Saba. As well as in Spain, it has currently been implemented in Portugal.

The main objectives of the Crime Prevention Model are:

• To establish a system of prevention and control aimed at reducing the risk of crime.
• To provide an explicit and public record of Saba’s unequivocal condemnation of any type of behaviour which is illegal and/or contrary to the ethical principles that are considered key values of the Saba group.
• To establish adequate control measures that allow Saba to prevent crimes being committed.
• To supervise the controls implemented in order to verify their adequacy.
• To periodically update the Model, whether due to organisational changes within Saba or as a consequence of changes in current legislation.
• To raise awareness, among the Governing Body, Saba executives and all employees, of the importance of complying with the Crime Prevention Model and of the ethical principles contained in the Saba Code of Ethics.
• To provide appropriate training to disseminate the Prevention Model.