Code of Ethics Policy
Contents
3.1 What is the purpose of the Code?
3.2 Who has to comply with the Code?
3.4 Business partners and suppliers
3.5 The Code of Ethics applies to everyone
3.8 Investigation and sanction of any breach
3.9 Respecting dignity at the workplace
3.10 Preventing health and safety risks and respecting employees’ rights
3.13 Market competition and consumers
3.14 Fighting against corruption in GCL
3.15 Patronage, sponsoring and donations to Political Parties
3.16 Veracity and information security
3.18 Integrity in our services
It is a pleasure for us to present the GCL International Group Code of Ethics.
Our Code articulates a framework that seeks to go beyond the mere compliance with the law; its spirit is guided by the integrity and professionalism in our decision-making, establishing a set of general principles, which should guide our everyday behaviour wherever we operate in the world.
We all know the importance of acting with impartiality, integrity and responsibility. The set of values, principles and ethical standards which are established in our Code go beyond protecting the image and reputation of our Company or avoiding legal problems. The integrity allows us to maintain a sustainable environment that we all are proud to belong to and strengthens our professional activity. Our Code of Ethics will help us in decision making and is designed to guide our behaviour in all the business dealings we undertake in the course of the work.
Business growth and maintaining high levels of operational standards in terms of management and compliance with regulations are mutually reinforcing elements. Building trust with the wider public is gradual and requires constant effort. Therefore, it is the responsibility of all of us to protect the company’s reputation, which means acting with honesty and treating our internal and external collaborators, our customers, shareholders, partners and suppliers in a fair and honest manner.
I am sure that I have your full support and commitment to help GCL grow into a company of the future that is built on its core values contained within the group’s Code of Ethics.
I want to encourage you to read this Policy carefully, to become its faithful guardian and I thank you in advance for your contribution to the implementation of the Code of Ethics within the group. With your help, GCL will continue to merit the confidence that we all have.
Chief Executive Officer
The quality of our services and the success of our business depend on many variables among them acting every day in a fair and honest manner as socially responsible persons. In order to achieve this, we have to respect these core Code principles:
There is no doubt that complying with the proposed values might be complicated. In the day-today business of GCL we face multiple ethical problems such as: in considering whether to promote an employee, can I consider the fact that the person is a young woman that could become pregnant in the future? In order to obtain a contract, can I use my close friendship with a public official who is the superior of the person making the decision about this contract? A female colleague might be subject to sexual harassment. Do I have the duty to complain?
This Code of Ethics may not be able to provide an answer to each ethical dilemmas we are presented with in the workplace. It is intended only as a guide, a set of internal rules and provisions to help achieve our proposed values.
Due to the complexity of our business and our activities in different countries with different laws, the Code of Ethics is “interactive” and permits direct access to the provisions that build the framework for our activities.
“The Code of Ethics is our tool to resolve ethical dilemmas in our day-to-day operations, which are in accordance with GCL values. In case of doubt, please contact GCL or the person responsible for Compliance in each division.”
All GCL personnel have the duty to know and comply with the Code. Each candidate accepting employment in our group must expressly acknowledge and accept the Code and will receive specific compliance training accordingly.
The Code governs GCL and all the companies that are directly or indirectly part of our group. In those companies where we do not hold a majority of shares, we will propose the adoption of measures ensuring compliance with the laws and human rights similar to our own.
The obligation to comply strictly with the provisions of the Code is especially important for directors and officers. The success of the Code depends on the commitment of everybody.
A severe breach of the Code implies the loss of one’s job, as determined by the Board of Directors. The special commitment of the senior management deploys the following obligations:
Due to our commitment to the Code’s values we demand that our suppliers and business partners are professional and honest, giving priority to companies that embrace similar compliance standards to our own.
The Code is binding on GCL, but we want to encourage all persons affected by our activities to help us to identify our ethical commitments. Therefore, the Impartiallity Committee welcomes any communications, such as consultations, questions or reports of incidents. They will immediately acknowledge receipt of suggestions and will respond as soon as possible.
Ensuring compliance with the Code seriously requires the establishment of new institutions and functions. The senior Management is in charge of:
In order to ensure that the Impartiallity Committee is an active institution, present in the day-to-day business, Senior Manager will manage specific issues or processes.
The Chief Compliance Officer will work to ensure the Board of Directors, management and employees comply with the rules and regulations of regulatory agencies, that company policies and procedures are being followed, and that behaviour in the organisation meets the company’s Code of Ethics and Anti-Corruption Procedure. Senior Manager will be a member of the GCL Impartiallity Committee.
The Impartiallity Committee is an essential institution within GCL. The Impartiallity Committee performs its tasks in an independent manner, having its functions authority over all personnel. The composition of Impartiality Committee is available on GCL Articles of Association
In our culture, those who report any kind of irregularity within a collective are often stigmatised, and it is considered an act of loyalty to cover up a given infraction and remain silent. GCL maintains an opposite philosophy and encourages any employee, collaborator or any person to make a complaint in good faith in connection with any breach of the Code, especially regarding severe irregularities committed in the exercise of their functions.
Complaints must be reported to a Senior Manager or the divisional compliance officer via the Communication Channel.
In order to grant maximum security and protection of the person reporting the breach, GCL commits itself to:
The Code and its evolving policies are not just a set of “best practices” or recommendations. Compliance with them is mandatory.
The provisions of these policies are comparable to any work instruction received from the Company’s top management. Therefore, any breach supposes the imposition of disciplinary measures up to and including termination of employment.
Disciplinary infractions related to violations of the Code include:
GCL will impose disciplinary sanctions in accordance with the local employment legislation. Disciplinary sanctions are considered the last resourt and are reserved for the most severe cases.
Respect for the Code and commitment to the company values have to be considered in each case of granting promotion within GCL.
No breach of the Code is justified. Employees cannot exclude themselves from the application of any legal provision, which may result in a breach of the Code. Similarly, employees may not rely on the fact the management had knowledge of the breach and that they were given instructions to keep silent. In such cases, GCL personnel must report any facts via the Communication Channel to senior management.
GCL is committed to this code and it would not be credible if it were not reflected in the relationship with the employees based on dignity of every employee. The employment relationship shall be free of any abuse of authority of conduct that might serious offend others.
A healthy work environment, respecting the dignity of the employees also includes respecting employees’ rights.
Our Company will respect the international standards promoted by the International Labour Organization wherever it operates. The GCL Occupational Health and Safety Policies prevent risks and promote Health and Safety in the workplace.
All employees have a duty of care when it comes to health and safety. Therefore, all employees have the obligation to know and comply with the group’s protection policies.
The Company recognizes that all persons within our organization Company have the right to affiliate with trade unions. The company’s management will not oppose the exercise of this right.
Managing any business today requires the protection of personal data gathered within the scope of employment. Although laws related to data protection vary in the different countries where we operate, GCL considers the following elements as fundamental:
GCL will design Data Protection Policies based on the data protection laws applicable in each county and adapted to each legal framework.
In addition to all local laws, all employees or officers must respect these basic rules:
With the exception of Human resources and Legal, no officer or employee may access any personnel file other than their own without express authorization.
Personal data may only be collected and filed to the extent necessary in order to achieve a legitimate business purpose, and such information may only be used for the purpose for which it is collected.
The personal data of the persons to whom the Code applies and who have the purpose to ensure compliance with the Code’s provisions, may be used during investigations, independently of the country where these investigations take place, in accordance with applicable laws.
Personal data that is processed can only be communicated to third parties in order to comply with obligations directly related to the Company’s activities, in all cases only with the permission of the person affected.
Our company will respect all laws related to environmental Protection and is committed to sustainability. We therefore will comply with best practice guidelines
At GCL we believe that innovation and compliance with antitrust laws are the bases for economic growth. Therefore, the following are strictly prohibited:
GCL personnel and other persons operating for the Company have the duty to avoid any corrupt practice. Therefore, it is necessary to accept GCL supervision in order to prove the correctness of their policies and proceedings.
GCL complies with national and international laws relating to the fight against corruption in all countries where we are established.
As a transnational company we know that the perception of what qualifies as corruption or not depends on cultural and legal factors. Nevertheless, GCL will implement a Global Anti-Corruption Policy for all countries where we operate. This policy prohibits the following activities:
As a socially responsible member of society, our Company will bring forward culture, science and arts and will collaborate with social and humanitarian projects. In relation to these projects, the patronage of academics as well as most collaborations with NGOs and public administrations is allowed. In no event shall these contributions be made in relation to electoral propaganda events or as a means of bribing a public official seeking to obtain a personal benefit. In order to guarantee a high level of security, any patronage must be approved by the person responsible ensuring compliance with the Anti-Corruption policy.
GCL maintains impartiality with respect to political parties. Therefore any contribution to a political party anywhere in the world is prohibited.
Information is a basic element of managing a company and for this reason, guaranteeing the integrity and reliability and accuracy of information is everybody’s job.
We shall ensure the veracity of the data that we supply to public bodies such as tax and accounting information.
To this end, all staff must adhere to the company IT policies at all times.
Depending on your position, you may have access to confidential information belonging to the company its clients or its suppliers. Due to our activities, we also have access to third parties sensitive information that we must protect. This includes an obligation not to disclose this information without the consent of the owner of the information.
Our services must be rendered in a professional, independent and impartial manner, according to the methods, procedures, practices and policies of GCL and the laws of each country.
The commitment to comply with applicable laws in our activities is based on our commitment to society, beyond civil, administrative, criminal or any other responsibility that might arise for GCL or our personnel.
The only way to create confidence in our services is to operate with complete independence. Therefore, we must avoid any conflict of interest, especially in the event that GCL renders services to a client that, due to its nature, compromises his or her independent judgement. Internal policies define in a detailed way how to act in these cases.
Recommendations, professional opinions, data, results and generally any asserted facts must be documented in a careful manner, in compliance with internal policies. Reports and certifications have to include results and findings, as well as the corresponding opinion of the relevant professionals.
The above-mentioned conflicts of interest might occur between GCL and its clients, but also may arise within the exercise of our activities. These situations must be avoided and the occurrence of any conflict of interest must be reported immediately to superiors or the Senior Manager in order to obtain further advice regarding how to proceed.
Common examples of conflicts of interest are:
As specified in the IT and related policies, corporate email are the property of the company and therefore not appropriate for private use. PCs, phones and equipment shall only be used for business purposes.
Use of external files and software puts our security at risk, therefore the use of unauthorized software, software downloads of inappropriate content (e.g. pornography) or any action that violates intellectual property rights is prohibited.
The rest of GCL resources may only be used exclusively for developing our activities and in any case never for personal use.
All personnel must take proper care of resources assigned to them and must avoid damage, theft or any improper use of such resources.
GCL operates in various cultures, with different customs that we have to learn about and respect, whilst acting in a respectful manner and according to the different social norms.
Use of illegal narcotic drugs or alcoholic beverages at work is strictly prohibited.