At Ultranav and its subsidiaries, we firmly believe that ethics and integrity are fundamental pillars of the way of doing business. Our commitment to these values not only guides our daily decisions but also bolsters the trust that our customers, partners and employees have in us.
To ensure that everybody at Ultranav acts with the highest ethical standards, we have developed a series of fundamental documents that reflect our principles and expectations:
• Code of Conduct: our code provides clear guidelines on the behaviour expected of all the members of the organisation, fostering a respectful, fair and transparent workplace.
• Crime Prevention Manual: this manual outlines the policies and procedures designed to prevent inappropriate conduct and guarantee compliance with the legal and regulatory regulations applicable.
The General Business Principles of Ultranav and subsidiaries are the commitment that Ultranav has undertaken with its stakeholders on how to conduct its business at all times, based on our business principles and corporate culture.
Our business principles are:
ECONOMIC SUSTAINABILITY AND FREE COMPETITION
Long-term profitability is essential to achieve our business goals and sustainable growth. It provides the resources needed for the investment required to renew and develop our fleet and services, in order to meet or exceed our customers’ expectations.
Without a strong financial base, it would not be possible to fulfil our commitments with our stakeholders. Ultranav and its subsidiaries support and strictly comply with the regulations on free competition.
We strive to compete fairly and ethically within the current regulatory framework.
BUSINESS INTEGRITY
The Group is adamant about honesty, integrity and fairness in all aspects of our business and we expect the same in our relations with all those with whom we do business. At Ultranav and its subsidiaries we comply with all current laws and regulations.
PLEASANT AND SAFE WORKPLACE
ENVIRONMENTAL PROTECTION
Ultranav and its subsidiaries are committed to protecting the environment and support the precautionary principle, avoiding the use of materials and methods posing environmental and health risks, as far as reasonably practical. We run our business operations in accordance with renowned international environmental management standards and strive for the continuous improvement of our environmental awareness.
CRIME PREVENTION
Ultranav and its subsidiaries are committed to strictly complying with Law Nº20.393 and its subsequent amendments. To prevent the crimes indicated therein from being committed, the company has put in place a series of protocols, standards and procedures to prevent and detect unlawful conduct in the activities it undertakes (“Crime Prevention Model”), which establishes the obligations and prohibitions for its executives, managers, employees, contractors and suppliers.
The Code of Conduct of Ultranav establishes the internal conduct guidelines which drive and guide the behaviour expected of all employees in all the companies of Ultranav in the performance of their daily work and activities, and in the relations and commitment with stakeholders (public and private). This is to comply with the commitments undertaken by Ultranav in its General Business Principles and conduct business activities with honesty, integrity and fully complying with the laws and regulations established in the jurisdictions in which the company operates. Ultranav has identified the following areas of focus:
1. Respect for people
2. Safety and environmental responsibility
3. Protection of the Group’s assets
4. Confidential information, privacy and data protection
5. Compliance with laws
6. Anti-corruption practices
The Group does not accept or foster immoral or corrupt practices or permit extortion or bribery.
7. Conflicts of interest
8. Free competition
The Group and its employees must comply with all the laws and regulations that protect free competition.
9. Trade sanctions
The Group and its employees must comply with the applicable trade sanction laws and regulations, including those managed by the United Nations, the European Union,
the United Kingdom, the United States of America, and by other competent authorities and states.
10. Prevention of money laundering and financing of terrorism
It is the policy of Ultranav and its subsidiaries to comply with all applicable laws and regulations on prevention of money laundering and financing of terrorism.
11. Accounting books and records
The accounting books and records of Ultranav and its subsidiaries shall accurately and timely reflect all the transactions of the companies of the Group.
12. Gifts and entertainment
Ultranav and its subsidiaries
discourage employees from receiving gifts or entertainment from external parties and discourage employees from giving gifts or entertainment on behalf of the Group to people outside the organisation.
13. Influence on auditors
Any internal or external audit shall be conducted free of any undue influence on the auditors.
14. Obligation of reporting
Adhering to the standards of Ultranav and its subsidiaries protects all employees, the value of the resources and operation of the organisation, and its reputation of acting correctly. The identification
of issues or infringements helps to solve them quickly and suitably or prevent them from escalating or being repeated, benefitting and enhancing the workplace.
The Crime Prevention Model entails establishing an organisational structure, resources, roles and responsibilities, processes and policies, whose purpose is to foster a culture of integrity and good business practices, along with preventing the crimes laid down in the Law on the Criminal Liability of Bodies Corporate from being committed, in accordance with the area of action of Ultranav and subsidiaries. The Crime Prevention Model is underpinned by 6 pillars of compliance, which are the tools with which the Ultranav Group responds to and manages its exposure when any crime is committed. The chart of the pillars is shown below:
1.
CORPORATE
GOVERNANCE
This pillar comprises the management and supervision body of the CPM and the set of standards, principles and procedures regulating the action of all those who are part of Ultranav and its subsidiaries, and related third parties. This pillar establishes the relations between the board of directors, management, employees and the rest of the interested parties, besides stipulating the rules and standards governing the compliance decision-making process of the Group.
2.
RISK ASSESSMENT
AND MANAGEMENT
This is the risk identification and mapping process and review of controls, involving the leaders of all the business areas, allowing for accurate quantification of the risks by means of analysing the impact and probability of the crime occurring, along with the identification of mitigation controls related to the Crime Prevention Model. This enables the Group to allocate the resources needed to monitor, follow up on and respond when a crime is committed.
3.
TRAINING
AND COMMUNICATION
For the efficient implementation of the Prevention Model, it is essential that all employees and business partners know the scopes of the Law, along with the content and scope of the CPM, its controls and regulatory framework.
To assure the correct training and dissemination of the model, there is an annual training plan for employees that entails in-person and remote training, and e-learning.
4.
WHISTLEBLOWING
CHANNEL
This is a means of communication with which all interested parties (employees, customers, suppliers, etc.) have a way of alerting and/or informing management about issues concerning irregularities, breaches and/or infringements of the General Business Principles, Code of Conduct, Internal Regulation (RIOHS, according to the Spanish acronym), and the Crime Prevention Model.
5.
MONITORING
ACTIVITIES
The Crime Prevention Committee has the responsibility and role of making sure the Model operates, reaches the entire organisation and is effective. For this, the CPO must assure the applicability of the Model by means of internal reviews, self-evaluation questionnaires and the reporting schemes of the support areas with delegated controls.
6.
ANNUAL
ASSESSMENT AND
CONTINUOUS IMPROVEMENT
To comply with the law, once a year the Prevention Model must be reviewed by an independent third party to ensure, bolster and improve all the components of the Crime Prevention Model.
The WHISTLEBLOWING CHANNEL is a means of communication with which all interested parties (employees, customers, suppliers, among others) have a way of alerting and/or informing management about issues concerning irregularities, breaches and/or infringements of the General Business Principles, Code of Conduct, Internal Regulation (RIOHS, according to the Spanish acronym), and the Crime Prevention Model. Our whistleblowing site is operated in collaboration with an external supplier, that guarantees the privacy and anonymity of whistleblowing reports and any information transmitted by means of the website. All the information communicated will be treated confidentially. Ultranav’s Prevention Committee will critically assess all the whistleblowing reports received and will handle issues in accordance with our principles.
