COMPLIANCE

Because we understand the implicit and necessary obligation to exercise control over how our executives, directors and staff members act, FRANCISCO ARAGÓN has a CRIME PREVENTION POLICY in place, which:

Requires compliance with criminal legislation as it applies to the organisation and its practices.
Is consistent with the organisation’s aims.
Identifies activities where criminal offences could be committed and need to be prevented.
Prohibits committing any unlawful acts.
Minimises the organisation’s exposure to any risks of criminality.
Provides a suitable framework to define, review and achieve our criminal compliance objectives.
Includes a commitment to comply with criminal compliance policy requirements and the criminal compliance management system.
Imposes the obligation to report any events or behaviours that are suspected of having a possible connection to criminal activity, ensuring that no one will face reprisals for reporting any such circumstances.
Includes a commitment to the system’s continual improvement.
Explicitly establishes the authority and independence of the compliance officer.
Sets out the consequences of failing to observe the compliance policy and any requirements resulting from the criminal compliance management system.

This policy forms part of the information documented in the Crime Prevention Strategy, and is provided to all members of the organisation and business partners, and is freely available to all parties concerned.

It also establishes that it is the responsibility of everyone in the organisation to comply with the strategy’s provisions, which include, as a minimum:

1. Identify activities where criminal offences could be committed and need to be prevented.

2. Establish specific protocols or procedures that set out the process for educating individuals to make decisions and carry them out in accordance with said protocols and procedures.

3. Provide suitable financial resource management models to prevent any criminal offences from being committed.

4. Impose the obligation to report any possible risks or failures in compliance to the body entrusted with overseeing proper implementation and observance of the prevention model in place.

5. Establish a disciplinary system that imposes suitable sanctions for any failures to comply with the measures set out in the model.

6. Run regular checks on the model and implement modifications if any relevant breaches of its provisions have been made, or when changes are made to the organisation, managerial structure or the activity carried out that require any such modifications to be made.

INTERNAL REPORTING SYSTEM AND WHISTLEBLOWING CHANNEL

At FRANCISCO ARAGÓN an Internal Reporting System or Whistleblowing Channel is in place pursuant to the provisions of Law 2/2023, of 20 February, on the protection of persons who report regulatory breaches and anti-corruption measures. This channel ensures the confidentiality of the person reporting the issue and guarantees that the facts are investigated with all appropriate guarantees in place.

This Internal Reporting System integrates the organisation’s various internal information channels, and can be used to report any activity that is unlawful or which goes against the ethics and principles of the company and what it stands for.

The Internal Reporting System or Whistleblowing Channel can be accessed through the Internal Reporting System on the company website.