Code of Ethics
Our conduct guidelines
Respect for legality, human rights and ethical values
Respect for people
Professional development and equal opportunities
Cooperation and dedication
Workplace health and safety
Use and protection of assets
Corruption and bribery
Corruption and bribery occur when employees make use of unethical practices to obtain any benefit for the company or for themselves. Corruption and bribery are categories of fraud.
Our company is against influencing the will of people outside the company to obtain any benefit through the use of unethical practices. Neither does it permit other people or entities to use these practice with its own employees.
Irregular payments and money laudering
Corporate image and reputation
Loyality to the company and conflicts of interest
Conflicts of interest appear in circumstances where the personal interests of employees, directly or indirectly, are contrary to or conflict with the company’s interests, interfere in the compliance of their professional rights and responsibilities or involve them personally in any of the company’s transactions or economic operations.
We consider that the relationship with our employees must be based on loyalty arising from common interests.
Treatment of information and knowledge
We consider information and knowledge as one of our primary and essential assets for corporate management, and as such it is object of special protection.
The accuracy of information is a basic principle of our actions, whereby employees must accurately convey all the information they have to communicate, internally and externally, and shall in no case provide, to the best of their knowledge, incorrect or inaccurate information that may mislead its recipients.
Costumer relations
We undertake, lead and drive a commitment to quality, providing the resources required to achieve excellence and establishing the appropriate resources for guaranteeing that the quality policy is practised by all employees in accordance with these principles.
Shareholder relations
Our aim is to create value for our shareholders constantly, which is why we are committed to providing objective, transparent, appropriate and timely information about the company’s evolution equally to all our shareholders. Likewise, we are committed to building the foundation necessary for our shareholders to participate in the decisions that are theirs to decide.
Relations with collaborating companies and suppliers
We consider our suppliers and collaborating companies as an essential part of achieving of our objectives for growth and improving service quality, seeking to establish relationships with them based on trust and mutual benefit.
Respect for the environment
Preserving the environment is one of our basic principles. Consequently, we have defined a policy and implemented an environmental management system.
Compliance Policy
The Compliance Policy, which develops the Code of Ethics of the Naturgy Group and is included in the Compliance management system, is intended to define the general principles that inform this system, as well as the company’s main commitments regarding compliance, which should guide its behaviour in all its fields of activity and in achieving its business objectives.
The Compliance Policy was approved by the Naturgy Energy Group, S.A. board of directors on 29 January 2019, and it should be acknowledged and applied by all the managers, directors and employees of Naturgy Energy Group, S.A. and all the companies and entities within the Naturgy Group, including any investees over which the Group has effective control or responsibility for its operation and/or management.
Anti-corruption Policy
Naturgy’s Anti-Corruption Policy is understood as an extension of Chapter 4.7. “Corruption and Bribery” from the Group’s Code of Ethics.
On 23 December 2010, the reform of Organic Law 10/1995 of the Criminal Code entered into force, through which the criminal responsibility of legal persons was established in such a way that a company may be deemed responsible for the crimes set out in Organic Law 10/1995 and its subsequent modifications (hereinafter, “the crimes”), whether they are committed in its name and by its legal and administrative representatives, or by people under its authority, and due control has not been exercised.
Furthermore, this Law stipulates some measures through which legal persons may mitigate or absolve their responsibility, including the establishment of effective measures to prevent and discover the crimes that may be committed in the organisation.
In that regard, Naturgy has implemented a Criminal Prevention Model that establishes the control measures required to avoid crimes being committed by its managers and employees under it supervision.
In order to comply with the requirements regarding crime prevention, and specifically cover the main legal, reputational and economic risks that the group is exposed to, it has been deemed necessary to establish the basic principles of an anti-corruption model, which are reflected in the Policy.
The document is intended to establish the principles that should guide the conduct of all employees and managers in the companies of the group regarding the prevention, detection, investigation and redressing of any corrupt practice within the organisation.
The current Anti-corruption Policy has been approved by the Board of Directors of Naturgy Energy Group, S.A., on July 23, 2019, and is applicable to all Naturgy employees.