Corporate Social Responsibility Policy, Sustainability and Environment of The Group La Zagaleta.
La Zagaleta Group, is aware of the impact of its business activity in its environment and the local, regional, national and international environment where it carries out its work. It is aligned with this Corporate Social Responsibility Policy (CSR from now on), approved by the Board of Directors of La Zagaleta, S.L., the highest responsible body of the company, with the firm commitment to attend all the parties involved in its business management -the members of the Organization and the Business Partners- as well as the Interest Groups and to ensure the respect and protection of Human Rights and compliance with regulations on the one hand and on the other, the workers and the environment are the guidelines that guide their daily work, for which they formally declare their involvement in the maintenance of these principles and values as well as in the awareness and diffusion of them.
LZ will consider the recommendations proposed by institutions such as the United Nations, OECD, European Union, ILO, ISO, etc.), all of which reflect the concerns of society in order to take into account in business activity not only those that strictly generate economic returns but also to analyse the interests of stakeholders and shareholders in the fairest way.
In order to carry out its CSR strategy, LZ affirms its uncompromising willingness to ensure that the following values and principles are applied within the entire Organization and its business partners in three spheres of action:
I. Human Rights and Compliance.
1. Human Rights.
On 10/12/18 the 70th anniversary of the Universal Declaration of Human Rights was commemorated, which established the essential framework necessary for the dignity of persons, individual rights that must be recognized by any institution, entity or natural or juridical person to any human being constituting the base, the essential base for both humanity and communities to survive and prosper.
Any personal or collective action that individually denies, nullifies, undermines or individually deteriorates these rights entails the denial of the dignity of the person performing it and that of humanity as a whole, which may also be the object of such a conduct.
Companies and, also LZ, must defend Human Rights and avoid the threats that business activity can cause to people and the environment in which they carry out their activities.
Only with people’s dignity can we build a future that is good for the environment, the economy and the society at the same time, a healthy planet that is home to prosperous communities and an inclusive economy that does not allow negative impacts to be borne by people and communities that are disadvantaged due to geography, poverty, gender, age, disability, cultural or ethnic origin, among other factors. The active integration of such interconnected considerations into decision-making and corporate strategy will be essential for the long-term health of the planet, which is ultimately good for both society and business.
The challenge for LZ is to create the momentum to put universal human rights principles at the centre of its business strategies to ensure sustainability, the sustainability of the physical and social environment in which LZ is embedded.
2.- Regulatory compliance.
A.- It is a primary objective to achieve the highest level of transparency in the Governance of the Organization and the corporate system, both in the structure and in the management of the Organization (risk analysis, fraud prevention, fair competition, relations with Public Administrations, etc.).
B.- Strict compliance with both legal and regulatory standards and with the minimum levels of legal requirements voluntarily established internally by LZ through the Comprehensive Regulatory Compliance System is defined as the only responsible, sustainable, transparent and integral way of acting for each and every one of those who form part of the Organisation. Knowledge of these standards and your ability to comply with and enforce them are the foundation of LZ’s business activity.
C.- Code of Ethics or Conduct, any business action will be carried out in a legal, fair, truthful and honest manner and any infringement thereof may be communicated confidentially through the use of the ethical channel for the provision of suggestions, request for information or communication of suitable actions, establishing an investigation procedure with guarantees and the application of a disciplinary regime to correct the infringing actions.
D.- Strict compliance with the law on Data Protection, ensuring and safeguarding customer data, privacy and their recognized rights.
II. Workers, Business Partners and Interest Groups.
Through the scrupulous respect and protection of labour rights, LZ contributes to the quality of life of workers through the equitable distribution of increases in the value of the services and products that constitute the business activity. Working conditions to achieve health, physical and emotional well-being of workers, together with the necessary health, safety and risk prevention actions, contribute to the achievement of business objectives through quality employment and development of professional relations based on respect for the working age, equality, non-discrimination, respect for diversity, equal treatment and salary remuneration and, as far as possible parity and always with respect for the participation and representation of workers in business management.
2.Business Partners and Interest Groups.
A.- LZ’s loyal compliance with the rules and contracts with collaborators and business partners is the other way of involving them in the creation of the value chain that business activity entails. We are committed to Quality in our relations with business partners, promoting social responsibility in this value chain (compliance with contracts, ethical criteria, etc.).
B.- The objective of LZ is to obtain the highest levels of quality both in the products and services offered by the business activity of the LZ to meet the expectations of customers and in the investment in lines of research, development and implementation of projects and work related to such products and services that revert to the benefit of the Organization, the Community and Society.
C.- It is a rule of LZ the transparent, responsible and truthful Management of Information and Communication, both internal and external, with prevention of reputational risks through the responsible use of all social networks and the media.
D.- Quality of the information (accountability and veracity of the data collected in the annual accounts) and Transparency in the information (collected in the report or in other media) is a strategic value in LZ.
E.- Active participation in the Community and social investment of part of the business profits through sponsorship and promotion of activities that symbolize and embody the values that LZ represents as well as the proactive participation of Interest Groups and Social Partners in the business activity is valued for decision making and in the corporate strategy of LZ.
Environmental management through the sustainable, efficient and reasonable use of natural resources and scrupulous care of the environment, preserving its biodiversity through constant concern and integration into business activity of environmental criteria for the decision and management of processes for creating products or services using the most effective (eco-efficiency) for environmental conservation, pollution prevention, promoting energy efficiency and minimizing climate change, are configured as the necessary means for preserving the sustainability and endurance of the physical environment in which LZ is embedded.
La Zagaleta, as a business Group, aspires to lead with its commitment and involvement the creation of profit for its shareholders and those who participate or collaborate in its activity as well as sustainable development and progress, its willingness to serve the community as an accreditation of the responsibility it understands is responsible for and will promote internal and external communication of this policy through the training of the members of the Organisation and the provision of information and improvement concerning it through the participation channels (channel of suggestions, doubts or complaints, located on the website) set up for this purpose.
Transparency Policy of The Group La Zagaleta
Since La ZAGALETA (hereinafter LZ) began its work, it has defended an ethical behaviour and a commitment to comply with the law in the exercise of its business activity.
On December 18, 2017, LZ’s Board of Directors agreed to deepen these values and promote the company’s strategic policies with the establishment of a General Regulatory Compliance Program through an Integral System of Corporate Governance and Enterprise Risk Control and Management designed through the GRC (Governance, Risk & Compliance) technique, as a clear expression of its leadership, commitment and involvement in the stated objectives.
Regulatory Compliance is the basic and fundamental support to ensure the observance, obedience and compliance of both current regulations and the Group’s internal policies and regulations -which begin with the Code of Ethics and end with each and every one of the processes and controls established to verify the activity-, by the different companies, their Governing and Administrative Bodies, departments or areas, people responsible for them, employees and collaborators or people who are related to LZ’s business activity.
One of the essential actions of the Comprehensive CRM System designed specifically and uniquely for the specific situation and operations of the LZ is transparency.
What is Transparency?
It is that attitude voluntarily assumed and methodology in the daily task of the entities that allows, on the one hand, to show and explain, both to the Organization itself and to external subjects, what they do, why they do it, how they do it, and whether their action is aligned with their mission and values and, on the other hand, it admits the supervision and assessment of such performance in a manner consistent with them and its repercussion on the people in the organization and the social environment in which it carries out its activity.
Thus, transparency requires that LZ first clearly define its mission and values; then create the channels, means and procedures by which it aspires to achieve those goals; then establish the means to showcase its activity; and in all of this it must be truthful and must be exercised with responsibility.
Therefore, transparency is linked to ethics, public morals, honesty, integrity, loyalty and trust of its members and in the reliability of their actions for customers and the community.
In companies, transparency must be a value, a commitment and a permanent attitude of the work teams that carry out the activity, which provides security in the daily work and allows for greater levels of personal involvement by each of the members of the Organization, which in the end results in greater business achievements and benefits for shareholders, workers and the community in general.
The transparency thus considered, as one of the actions of the CRM System led by the Board of Directors of LZ, implies a great business commitment and implies a change in the operational management of the Company not only in the design and development of strategies but also in decision making and in each of the execution tasks of the same as well as in their supervision and assessment of the results obtained.
The actual and accredited compliance with regulations and the transparency of the Organisation communicated to it, its Business Partners and the Stakeholders determine the degree of integrity achieved by LZ; this means highlighting its Good Corporate Governance and Business Risk Control and Management practices.
On the other hand, these parameters or guidelines for action are absolutely and totally incompatible with the existence of inappropriate practices or breaches of the Code of Ethics approved and spread in the Organisation – and communicated to its business partners – or of actions that cloud or call into question the system itself, such as those related to conflicts of interest or the most radical corruption, for which reason the Senior Management of the LA ZAGALETA Group, in addition to formally and reliably declaring its commitment to zero tolerance with corruption and bribery through the implementation of a business culture of compliance, to monitor this commitment, LZ has designed, approved and implemented a Regulatory Compliance Unit responsible for the Regulatory Compliance Function, which is defined as the independent activity it detects through appropriate policies, processes and procedures, evaluates and manages the risk of non-compliance with regulatory obligations, both external and internal, arising from LZ’s business activity, developing the tasks of promotion, implementation, information, advice, coordination, communication and reporting, necessary to ensure and accredit effective compliance with the rules, for the benefit of the Company’s objectives as well as the detection of potentially infringing actions with the promotion of the obligation to use the Complaints Channel as an effective instrument of investigation and clarification of the same and purification of responsibilities and assessment of the same for improvement of the system with the firmness and security that LZ will pursue violations of the Code of Ethics since such violations can have serious consequences for LZ, its members and partners and they will be held accountable if they commit them.
LZ aspires that the members of the Organisation and the Business Partners adapt their activity to the strictest regulatory compliance and the LZ Code of Conduct with the utmost respect for others, but without tolerating violations of the same, as LZ wants them to collaborate freely and voluntarily in its distribution and effective application. In the case of Senior Management and managers, they are expected to set an example to the rest of the Organization in their knowledge, diffusion and compliance and finally to anyone who interacts with LZ to prevent their violation.
The members of the Organisation receiving this Code of Ethics shall refrain from promoting, facilitating, participating in or concealing any type of money laundering operation, and shall in any case report any money laundering operation of which they are aware to their immediate superior or to the Compliance Officer,
Therefore, one of the goals of the LZ Group is to implement protocols that allow it to show its level of transparency in the economic, labour, environmental, social, safety, etc. areas that make up its business activity.
All this is reaffirmed not only through these tools of will and internal organisation, but also extends to all members of the Organisation and its business partners thanks to a clear and concise training on the duties and obligations to ensure the success of the Group’s business.
There are many international and national institutions that, by means of mandatory rules or recommendations, highlight the convenience of being able to evaluate both qualitatively and quantitatively the degree of transparency and observance of regulatory compliance programs; for this reason, the LZ Group has created a list with all those commitments that refer to its policy of transparency, integrity and anti-corruption-antibribery in its Organization, namely:
1. A firm commitment by Senior Management and the entire Organization to bring transparency to its ultimate consequences in its processes and procedures, through an ORGANIZATIONAL TRANSPARENCY PROGRAMME.
Organisational transparency is the deliberate attempt by LZ to create an environment of trust in which to promote access to information, open communication, and the participation of all professionals in decision-making.
Thus considered, the transparency of LZ plays a fundamental role in the commitment of workers and business partners and has a direct and significant impact on obtaining business profit and economic results as it contributes to the quality of professional and working life of the company in which employees rely on Management and all have a common project. And this is impossible if there is opacity regarding the information, intentions or results of the company.
The organizational transparency of LZ will be enhanced through a program that allows:
A.- The integration of human resources management with access for all to team calendars to ensure objectives and allow the organization of tasks despite scheduled or unscheduled absences of workers because the value of the responsibility of the teams trusting that each will manage their holidays or events without harming the rest of the team makes them share and participate in common objectives and each knows where each person is at all times and can give a quick response to customers and suppliers.
B.- The use of centralized management tools that allow good management of the information needed to achieve the objectives by teams working simultaneously on a project and admit to put the information in common and that is easily accessible to the whole team, especially if there are remote workers or flexible hours, avoiding duplication of work and documents or transfer by various unreliable means (email, WhatsApp, Hangouts, Skype, etc.). ) with creation of secure communication channels by themes, projects or work areas that allow to open individual or group conversions, create documents, make calls, link with Drive… Even having an artificial intelligence bot.
C.- The clarity of the company’s financial information, its accounting results and their communication to the teams in charge of achieving the objectives and benefits allows us to share the efforts for their achievement or a responsible and conscious action of all so that the results are possible and achieve the highest levels of participation of each one in such benefits.
D.- Participation through regular meetings, forums or open spaces in which all employees can participate or debate with the other members of the team or the Organization and where they can present the issues that concern them, but which are not normally addressed due to other priorities of the day to day: what can be improved, if there is a problem, or if it is necessary to join efforts to achieve the objectives, Facilitating communication and participation improves individual and group confort.
3. Elaboration of a STRATEGIC COMMUNICATION PLAN that must provide information in a serious, orderly and committed manner, with strengthening of the company’s communicative system both internally and externally.
In internal communication it is necessary to be informed of the relevant decisions and events, whether positive or not, since communication is the remedy against uncertainty and if it is offered seriously and truthfully, it helps to dispel misgivings and distrust, helping to create a comfortable working climate that will benefit the company. It is not a question of telling everything at all times, but of informing.The external communication must opt for the truthfulness and honesty of the information, with a connection between the internal and the external that will remove suspicions and conjectures and the risk that information potentially harmful to the company or its reputation determines a catastrophic impact. Nothing hurts companies more than giving the feeling of having two faces and that the honest person uses externally a certain information against the company he knows or in which he has carried out his profession.
- Strict and scrupulous fulfillment of financial, accounting and fiscal duties and obligations, which will at least, take into account:
- Objectivity and transparency in the preparation and request for bids and concession of contracts, based on clear, concrete and accessible criteria to avoid conflicts of interest and without personal room for manoeuvre by any of the parties to obtain any prebend or benefit either directly or indirectly.
- Any transaction between any member of the Organization and business partners will be governed by ethical rules with scrupulous compliance of these for the execution of a contract with strict payment of the items reflected therein.
- Any payment will be made through the usual channels of financial transactions, excluding cash.
- Any economic transaction between the Organization and the business partners will be recorded in the accounting books.
- The accounting books of LZ shall faithfully and orderly state the transactions carried out in the activity of the same.
- Senior management will monitor both spending decisions and their execution, which in any case are the responsibility of different Departments by means of the segregation of these functions, favouring the financial control of economic resources.
4. LZ shall prepare and approve a PREVENTION AND COMBATING CORRUPTION AND BRIBERY PLAN which shall be clear, detailed, available and endorsed by Senior Management for precaution and proscription of actions potentially involved in such practices which shall include the management of such risk from a broader perspective than that of the Crime Prevention Plan and shall include provisions for gifts and hospitality, donations and sponsorship and facilitation payments.LZ shall also ensure adequate documentation of the essential protocols and procedures for regulating, avoiding or proscribing CONFLICTS OF INTEREST, CONCURRENT ACTIVITIES OF WORKERS AND COLLABORATORS, AND RELATED OPERATIONS,
5. LZ will deliver a WELCOME MANUAL illustrating the principles, values and mission of LZ as well as the internal compliance commitments that will allow it to carry out its work, profession or service, which will include the possibility of carrying out random audits in terms of Regulatory Compliance.
6. LZ shall encourage the ethical development of the activity at all levels of the Organisation and in its commercial relations with its business partners, placing at their disposal the advice of the Head of Regulatory Compliance and an ETHICAL CHANNEL that allows the reporting of any infraction that involves or could potentially involve a danger to the Organisation, which will have confidential character and with full guarantees of protection of the complainant against possible reprisals for its use, and procedural with respect to the verification and investigation of the facts, the rights of the investigated one, the handled data, with facilitation of periodic reports on the same one,
7. LZ will deal with evidence of violations and complaints in accordance with its protocol approved by the Board of Directors and will periodically review and update its transparency and anti-corruption protocol as well as the DISCIPLINARY SYSTEM AND SANCTIONING SYSTEM for the correction of acts performed by the company’s employees and executives, or their business partners that may be considered regulatory breaches or ethical malpractices.
8. LZ will develop a TRAINING PLAN that allows for accreditation of notification, individual knowledge and training at all levels of the Organization by members of the same and business partners to bring their activity to the strictest regulatory compliance, corporate integrity and the Code of Conduct of LZ.