Governance model for ethics

EDPR has a global Code of Ethics, adopted by all company employees, and to which they must comply with.

EDPR Code of Ethics was announced and published on the Company’s intranet and sent by e-mail by the General Secretary of EDPR. For all new hires, the Code of Ethics is included in the welcome pack that each employee receives when entering the Company and needs to be signed by all of them.

Additionally, two complementary documents are also available to define the ethics governance model – Code of Ethics Regulation and Ethics Committee Regulation –, both approved in 2011.

Code of Ethics Regulation

The Code of Ethics regulation, adopted by the Board of Directors, aims to regulate the application within EDPR of the Code of Ethics. Particularly, it defines the procedures for the reception, registration and processing of information received by the Company concerning violations of the Code in matters of legislation, ethics, conduct
in the work environment, human rights, equal opportunities, integrity, relations with customers and suppliers, environment and sustainability. The Regulation of the Code of Ethics features aspects such as:

  • Job description and responsibilities;
  • Procedures;
  • Confirmation, investigation and corrective measures;
  • Confidentially and anonymity; Management supervision and revision.

Ethics Committee Regulation

The Ethics Committee will receive, register, process and report to the Board of Directors all reports regarding violations of the Code in matters of legislation and ethics, establishing, if appropriate, corrective actions.

The Ethics Committee is composed of three members: the presidents of the Audit and Control Committee, the Related Parties Transactions Committee, and the Appointments and Remuneration Committee.

The Committee’s main functions include:

  • Proposing corporate ethics instruments, policies, goals and targets;
  • Monitoring application of the Code of Ethics, laying down guidelines for its regulation and overseeing its proper application by the Company and its subsidiaries;
  • Analyzing reported violations of the Code of Ethics, deciding on their relevance and admissibility;
  • Deciding if there is any need for a more in-depth investigation to ascertain the implications and persons involved;
  • Appointing the Ethics Ombudsman.

Ethics Ombudsman

In the first meeting of the Ethics Committee held in 2011, EDPR’s Ethics Ombudsman was nominated.

The Ethics Ombudsmen plays an essential role in the ethics process. He guarantees impartiality and objectivity in registering and documenting all complaints of ethical nature submitted to him. He monitors their progress and ensures that the identity of the complainants remains confidential, while entering into contact with them whenever appropriate, until the case is closed.

The full description of the Ethics governance model can be found in the Corporate Governance Report.