SABA - 2018 Annual Report - Saba

02 | Saba

Ethical conduct

Saba has a Code of Ethics that establishes the ethical guidelines that must govern the behaviour of the company and its employees. This is also available on the corporate website:
http://saba.eu/en/corporate-information/code-of-ethics

Saba encourages its subsidiaries and investee companies to follow the standards of conduct and values established in the Code of Ethics, notwithstanding the adjustments that may be made in order to respect the specific legislation of each one of the countries in which the company operates.

The Code of Ethics, which is considered binding, has been approved by the Management Bodies of the different Saba companies and has been delivered to all Group employees.

As established in Article 5 of the Code of Ethics, Saba undertakes to act at all times in accordance with current legislation and with respect for human rights and the freedom of individuals. Specifically, with respect to human rights, Article 6 of the Code of Ethics establishes that Saba does not accept any conduct when dealing with consumers or third parties that may be interpreted as discrimination based on race, ethnicity, gender, religion, sexual orientation, union affiliation, political ideas, convictions, social origin, family situation or disability.

Saba encourages its subsidiaries and investee companies to follow the standards of conduct and values established in the Code of Ethics

SABA’S MAIN 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.

A) Crime Prevention Handbook, approved by the Board of Directors in March 2017:

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 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 Handbook, whether as a result of organizational 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.

B) Deployment of the Crime Prevention Handbook in all countries where the company operates

C) Crime Prevention Handbook control structure
The pillars of Saba’s Crime Prevention Handbook control structure are:

The Board of Directors, as the highest decision-making body.
The Ethics Committee, as the body responsible for overseeing the functioning, effectiveness and compliance of the Crime Prevention Model, for promoting a preventive culture based on the principle of “zero tolerance” towards the commission of illegal acts and for periodically monitoring the Prevention Model.
The Crime Prevention Committee, which gives support to the Ethics Committee and has controllers in the different areas of the company.

D) Ethical Channel

E) Specific training. In 2018, training sessions were imparted on the Crime Prevention Handbook aimed at the people designated as Controllers.

F) ASCOM (Spanish Compliance Association). Saba became a member of ASCOM in 2018.