Ethics Code of for Suppliers
CONTENTS Ethics 01. Fighting corruption and fraud in all its forms 02. Gifts, presents and invitations 03. Fighting money laundering and the funding of terrorism 04. Conflicts of interest 05. The protection of intellectual and industrial property 06. Competition 07. Quality and excellence in service 08. Personal data protection and confidentiality Social Responsibility 01. Fair working conditions and safe spaces 02. Human Rights Environmental Responsibility Compliance and communication resources PAGE 04 PAGE 06 PAGE 07 PAGE 08 PRIM CODE OF ETHICS FOR PRIM SUPPLIERS 2
This Code of Ethics for PRIM suppliers aims to promote and disseminate the principles, general values and ethical and responsible commitments that should govern the behaviour of PRIM, as a company, and of its suppliers of products and services, contractors and other external collaborators (hereinafter referred to as “suppliers”). PRIM’s Sustainability Policy sets out, among other things, the organisation’s commitment to articulate a business model that contributes to the progress of its surroundings, the development of local communities, the promotion of equal opportunities and the protection of the environment. In addition, since 2023, PRIM has been a member of the United Nations Global Compact, the world’s largest sustainable development initiative, publicly committing to align its strategic operations with ten universally accepted principles in the areas of human rights, labour standards, environment and the fight against corruption. PRIM is also committed to actively contributing to the achievement of the United Nations Sustainable Development Goals. Suppliers play a key role in fulfilling the organisation’s economic, social and environmental commitments. For this reason, PRIM expects its suppliers to share and respect the organisation’s values and extend them to their own supply chain: commitment to customer satisfaction, the quality of the products it offers to its consumers and users, transparency in the financial and non-financial information provided to stakeholders, respect for laws and ethical principles, compliance with commitments made, integrity in decision-making and ethical and responsible behaviour in the social, environmental and governance spheres. CODE OF ETHICS FOR PRIM SUPPLIERS PRIM CODE OF ETHICS FOR PRIM SUPPLIERS 3
PRIM respects and asks its suppliers to respect the legitimate intellectual and industrial property rights of third parties and prohibits the use of illegal software, the downloading of pirated files, and the use or dissemination of photographs, drawings, videos, sketches, etc., without the appropriate consent of their legitimate owners. PRIM will not manufacture, import, possess or use for industrial or commercial purposes any goods covered by a patent or utility model without the consent of the legitimate owner, and expects the same conduct from its suppliers. The protection of intellectual and industrial property Suppliers should avoid situations where personal interests or activities influence or may influence their decision-making in relation to the best interests of PRIM. PRIM expects its suppliers to follow a policy of transparency in regard to the disclosure of any potential or actual conflicts of interest that may arise. Conflicts of interest PRIM suppliers will never knowingly acquire, possess, use or transfer any property derived from illegal activity, nor take any action to conceal or disguise its illegal origin for the benefit of the person who has engaged in said illegal activity. Similarly, suppliers will not accept payment from a customer or other debtor in the knowledge that the money is of illicit origin, nor will they accept payments in cash, cheques payable to bearer or foreign currency on terms that suggest it may be derived from illegal activity. Ethics 4 PRIM strives to be recognised in the market for its ethical behaviour, quality products and excellent service. To this end, the company employs internal procedures and control mechanisms to monitor compliance. As strategic partners helping PRIM to achieve its goals, PRIM extends its ethical, regulatory and quality standards to all the organisations in its supply chain. PRIM has a zero-tolerance policy, which it extends to its suppliers, towards any corrupt practices, including fraud, extortion, corruption and bribery, and is committed to complying with all the laws that apply to its activities. PRIM demands that its suppliers prohibit and abstain from any form of unlawful payment, monetary or otherwise, made for the purpose of obtaining any form of illegal or unethical advantage in dealings with its stakeholders, including favourable treatment or the promise of any undue benefit. Our organisation will never, and we demand that our suppliers will never, exert any kind of direct or indirect illicit pressure or make offers intended to obtain an unlawful advantage for a person or institution, be it of material or moral value, financial or non-financial, and which is considered relevant in accordance with customs and practices, nor will it finance political parties, their representatives or candidates, nor will it sponsor in any way any event exclusively intended as political propaganda. Fighting corruption and fraud in all its forms PRIM ETHICS Gifts, presents and invitations to PRIM’s internal collaborators are not necessary and are not advisable. PRIM collaborators may, on exceptional occasions, accept modest gifts or business courtesies in the course of a commercial relationship in accordance with the customs and practices of the country, as long as they are not intended to influence the objectivity of their decision-making. Gifts, presents and invitations Fighting money laundering and the funding of terrorism 01 02 03 04 05
5 PRIM CODE OF ETHICS FOR PRIM SUPPLIERS PRIM’s suppliers must be committed, like PRIM, to respecting free competition in the markets in which they operate and, therefore, will never enter into or be involved in any illegal agreement between competitors or between suppliers and customers, which could deprive its customers of the benefits of free and fair competition in the market. Competition The quality of the products marketed and the efficient and prompt provision of services ensure the satisfaction of PRIM’s clients and patients and constitute two of the pillars on which the organisation bases its competitive advantage. PRIM does not market products or provide services that do not comply with current legislation. Therefore, its suppliers must ensure compliance with any regulations that may affect the safety and quality of the products and services provided, as well as with any other regulations or quality standards required by PRIM. PRIM suppliers must not engage in any advertising or provide any technical information in relation to their products or services that is inaccurate, false or misleading. Quality and excellence in service PRIM is obliged to maintain the security of all personal and non-personal information to which it has access and to comply with applicable confidentiality and data protection regulations, establishing the necessary technical measures to ensure its confidentiality and integrity. Consequently, PRIM expects all its internal collaborators, and also its suppliers, to act responsibly with respect to third-party information, to protect it, to prevent unauthorised disclosure and to report any unauthorised or inappropriate use or disclosure. Personal data protection and confidentiality 06 07 08 5
SOCIAL RESPONSIBILITY 6 PRIM PRIM strives to contribute to the sustainable progress of its surroundings and provides control mechanisms for the protection of human rights, fair pay, health and safety, and equal opportunities. Furthermore, as a Family Responsible Company, it believes in diversity as a source of wealth and in the balanced development of the professional and personal lives of its collaborators. This commitment applies to all its activities as an organisation, and consequently, it expects the same commitment to social responsibility from its suppliers. Fair working conditions and safe spaces PRIM expects its suppliers to be committed to consistently providing quality employment, with fair remuneration, carried out in safe and healthy environments that promote the richness of diversity and pursue equal opportunities. Similarly, PRIM expects its suppliers to respect, as provided for in local laws, the right to union membership and freedom of association, as well as the recognition of the right to collective bargaining. PRIM rejects and prohibits any form of forced or coerced labour, child labour or any discriminatory practice on the grounds of race, colour, religion, nationality, social origin, age, sexual orientation, gender, marital status, ideology, political opinion, or any other physical, personal or social trait or condition unrelated to the work they undertake. PRIM suppliers must categorically reject and eradicate any manifestation of physical, sexual, psychological or moral harassment, abuse of authority, or any other type of conduct that may create an intimidating, hostile, humiliating or offensive environment or one that is detrimental to the rights or dignity of individuals. Suppliers must also have adequate measures in place to ensure health and safety in the workplace and protect their workers from chemical, biological and physical hazards, identifying and mitigating risks to prevent occupational accidents and diseases. They also undertake to comply with current health and safety legislation and provide the protective measures appropriate to the nature of their jobs, in addition to establishing controls to ensure compliance with these measures. Any health and safety hazards that may affect PRIM and any work practices that contravene the contents of the Code should be reported to PRIM. 01 Social Responsibility 6 Human Rights Like PRIM, suppliers must have scrupulous respect for people’s rights, taking the United Nations declarations on human rights, labour, environment and anti-corruption as a reference and adopting the Ten Principles of the Global Compact and the UN International Bill of Human Rights as their own. Furthermore, PRIM supports the Tripartite Declaration of Principles concerning Multinational Enterprises, the Social Policy of the International Labour Office and the Guiding Principles on Business and Human Rights (“Protect, Respect and Remedy”) and takes into consideration the OECD Guidelines for Multinational Enterprises and the principles and rights set out in the ILO Declaration on Fundamental Principles and Rights at Work and its conventions, and expects the same from its suppliers. 02
7 PRIM ENVIRONMENTAL RESPONSIBILITY Compliance with the environmental laws applicable to them Environmental Responsibility PRIM is committed to respecting the environment in the course of its activities. The organisation works to meet the needs of its customers and incorporates, whenever possible, sustainable criteria in the manufacture and/or distribution of its products and the provision of its services in a process of continuous improvement, and expects the same from its suppliers. Action against climate change or adaptation to its current consequences, the progressive incorporation of the circular economy, energy efficiency, proper waste management and the protection of natural resources and biodiversity are particularly relevant aspects for both the organisation and its internal collaborators, and this commitment is also expected from its suppliers. The reduction and progressive elimination of greenhouse gas emissions derived from their activity Optimisation of water use in manufacturing processes Optimisation of energy efficiency Appropriate waste management Promotion of the circular economy in internal manufacturing processes and the distribution of products and services Monitoring of environmental risks and progressive reduction of the environmental impacts derived from their activity Prohibition of unauthorised dumping Specifically, PRIM expects its suppliers to accept the following commitments: PRIM expects its suppliers to apply a policy of transparency based on the contractual relationship, establishing the obligation to report serious environmental incidents that could be linked to the products and/or services supplied to PRIM.
The company publishes, on its corporate website, its internal Code of Ethics, this Suppliers’ Code of Ethics and its corporate policies, as the pillars on which its business model is based. PRIM has a confidential Internal Reporting System for reporting breaches of EU law and serious or very serious criminal or administrative offences, as well as breaches of its Code of Ethics, the Code of Ethics for Suppliers, and policies and other internal rules and procedures, the general principles and management procedure of which are detailed in the Policy and Management Procedure for the Internal Reporting System, which can be accessed through the Company’s website: www.prim.es. PRIM’s Internal Reporting System has an Ethics Channel through which anyone, including PRIM suppliers, can make a report or complaint without fear of reprisal, confidentially or even anonymously, providing the communication is made in good faith. The Ethics Channel may be used in writing or verbally. A direct link to PRIM’s Ethics Channel is available on the corporate website (www.prim.es). Compliance and Communication Resources Avd. del Llano Castellano, 43 Planta 3 28034 Madrid C/ Yolanda González, 15 Pol. Ind. Nº. 1 28938 Móstoles - Madrid e-mail: info@prim.es Tel. : (+34) 913 342 400 www.prim.es PRIM Head Office PRIM Operational Office CONTACT DETAILS FOR COMPLIANCE AND ESG cumplimientoyesg@prim.es company/grupoprim/ @grupoprim Approved by the Board of Directors of Prim, S.A. at its meeting of 26 October 2023.
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