Compliance

Compliance system
We have a compliance system that consists of a set of procedures and best practices aimed at preventing, detecting and reacting to the risks of possible inappropriate conduct and illegal acts of any kind.

The main elements of this system are:

Criminal compliance

Prevention of crimes that could have criminal consequences for the company.
Regulates financial resource management policies and the whistleblower channel.
For the management of financial resources, our crime prevention model provides for the control and supervision of each of the protocols or internal policies created and implemented by Litoclean, S.L.

As an alert system that allows us to identify and report irregularities, bad practices or mismanagement by the company, we have a whistleblower channel.

It prevents and resolves corruption activities in the corporate administration through a series of specific policies, where the different existing forms of corruption, the adequate procedures for their detection and complete elimination by the Compliance Committee are exposed.

These include anti-fraud and anti-corruption policies, control of grants and donations, intellectual property, purchasing, expenses and contracting, confidentiality commitments and the code of conduct.

The Compliance Committee manages the crime prevention model.
It is an autonomous and independent body composed of three compliance officers that meets every six months to perform the functions of their position.

Anti-fraud and anti-corruption policy refers to all acts of fraud, suspected fraud, attempted fraud, and corrupt practices committed against Litoclean, its employees, officers and members of Litoclean’s Board of Directors, customers, external collaborators, contractors, suppliers of goods and services, related entities, and other parties.
To this end, we implement a series of measures to prevent and avoid the commission of crimes related to fraud, fraud and corruption, regardless of the liability of the legal entity for such crimes.

Grants and donations control policy applies to the receipt and granting of cash or product donations that may be given to Litoclean, as well as to the receipt of grants.
Identification rules and obligations are established for the receipt of grants and donations, which help to avoid or minimize risks of other possible crimes related to the misappropriation of funds, donations and/or grants that may harbor a conflict of interest.

Intellectual property policy addressed to all staff, trainees and third parties with access to the company’s information, given that intellectual property is a priceless asset, which we protect and respect internally and externally.

They include copyrights, reproduction or designs, trademarks, inventions, trade secrets, rights over knowledge and their transmission or reproduction.

Purchasing, expenses and contracting policy regulates purchases, expenses and contracting in which the persons linked to the company incur for the performance of their professional activity.

Commitment to confidentiality All our staff is committed to maintain absolute confidentiality about the facts and data obtained, both in the scope of any consultation, document, as in the scope of a complaint, to any person outside the procedure, unless the disclosure of such information is required by law, labor or judicial authority.

Code of Conduct regulates compliance with the company’s ethical standards and legal codes at its different sites or branches.
It contains the
rules, procedures, protocols that will affect all departments.

Regulates corporate tax behavior and prevents crimes and their consequent legal sanctions.
Regulates tax decision-making policy.

Tax decision making policy ensures compliance with the applicable tax regulations
and seeks an adequate coordination of the tax policy
within the framework of achieving the social interest and supporting the long-term corporate strategy
avoiding risks and tax inefficiencies in the execution
of business decisions.

Establishes the assessment and prevention of risks, vulnerabilities and virtual attacks
.
Applies control and compliance measures for the protection of sensitive digital information
and includes the ICT policy.

ICT policy referring to the tools made available to personnel
for the development of their work activities, with the aim of creating a corporate culture
of acting in accordance with the law and thus avoiding any type
of criminal conduct that may occur in relation to such means.
Establishes in advance the rules for the use of work tools and defines
a system of use and control of all information technologies that
are used by the members of the company.

Comprehensive fraud prevention and protection of Litoclean’s multiple
financial and tax procedures.
It includes the policy of
prevention of money laundering.

Money laundering policy: theintroduction into the market of
of money or goods from illegal activities as if they were legal tender.
Litoclean is committed to adopting measures to avoid the risk of
incurring in a criminal offence, even if it is due to imprudence.