Compliance

The Code of Conduct is the internal document that contains the rules of action that must be observed in the development of professional activity at MTorres. The matters contemplated in the Code of Conduct are complemented by the rest of the internal regulations.
The Code of Conduct takes into account the principle of criminal liability of legal persons, being an essential element in the prevention, detection and eradication of illegal and/or irregular conduct, since it obliges recipients to immediately notify through the channel of denunciations of any fact or irregular act of which they are aware.

To whom does the Code of Conduct apply?

The Code is applicable to all the people who make up the group of companies and entities belonging to the MTorres Group, regardless of the function, hierarchy, body to which they belong and the responsibility they hold at all times. In particular, the Code is applicable to members of the administrative bodies, representatives, managers, other employees, including trainees and trainees.

Likewise, the Code extends its application to any natural or legal person contracted by MTorres, directly or indirectly, for the satisfaction of their needs, such as, among others: providers of supply of components, works, and services in the scope of their activities , commercial agents, subcontractors, external collaborators, etc.

This Code applies to its recipients regardless of the place where they carry out their professional activity for MTorres.

Consequences of its non-compliance?

The Code of Conduct has the highest regulatory hierarchy, consequently, the people subject to the Code must comply with its provisions, collaborate in its implementation, as well as report any breach of it.

Non-compliance with the Code by an MTorres employee may lead to the application of sanctions in accordance with labor legislation. Likewise, any supervisor, director, person in charge or administrator who directs, approves or has knowledge of the facts and does not correct them, or does not report them immediately, will also be subject to the application of said sanctions. However, when the facts constitute a conduct classified as an infraction in the Disciplinary Regime of the Crime Prevention Model, the sanctions provided for therein will be imposed.

In the event that the breach is attributable to a client, supplier, representative or collaborator, the measures deemed appropriate will be adopted, leading to the unilateral termination of the contract by MTorres, in addition to the claim for damages caused.

In any case, if the facts constitute an administrative offense or a criminal offence, they will be brought to the attention of the competent authority.

DOWNLOAD CODE OF CONDUCT

It is the autonomous body in charge of supervising and executing the Crime Prevention Model, made up of people who at all times hold the following positions:

What is the Complaints Channel?

It is the communication channel that MTorres makes available to employees, clients, suppliers, and any other interested party, to denounce, confidentially and without fear of reprisals, any irregular act or fact, whether or not it constitutes a crime.

Area of ​​application.

The scope of application of the Complaints Channel includes any breach of the Code of Conduct and the rest of the applicable internal and/or external regulations. Therefore, its application covers any act or conduct of any employee, director, collaborator, client, and/or supplier in the development of their professional activity related to MTorres.
This Channel cannot be used to make labor claims and/or individual requests of any kind, which will follow the ordinary channel through the People Area.

Prohibition of retaliation against the whistleblower and action against false complaints

Prohibition of retaliation against the whistleblower in good faith
One of the essential elements of the Model is the obligation of recipients of the Model to report any irregularity. Consequently, it is prohibited to take any measure against an employee or manager of MTorres that constitutes any type of negative consequence for the mere fact of having made a complaint.
For these purposes, retaliation is understood as; any negative consequences suffered by the complainant for the mere fact of having made a complaint about possible irregular conduct.
If a person understands that he is the object of reprisals, he can implement the internal protocol for the prevention of reprisals.

Action against false complaints
In the same way that the indemnity of the complainant in good faith is guaranteed, MTorres will act firmly against false complaints, imposing the corresponding sanctions. The fact that a member of the organization makes a false complaint with the purpose of harming a colleague, a third party, or the company itself constitutes a very serious infraction.
The foregoing is understood without prejudice to the possible criminal liability associated with the possible commission of a crime of libel or slander, and/or civil liability derived from the injury to the right to honor.

How to make the complaint?

Any interested party may file a complaint through the following channels:

• Directly to the Compliance Officer.
• Through the following email: ethicsline@mtorres.com
• Through the form established on our corporate website.

Process

The procedure begins with the filing of the complaint. Upon receipt of the complaint, the Compliance Officer will send the complainant an acknowledgment of receipt, unless it is done anonymously.

In view of the facts and the evidence provided, the Compliance Officer will carry out a preliminary analysis, drawing up a reasoned record, which will be notified to the complainant with one of the following decisions:

• Inadmissibility of the complaint and immediate filing of the file because it is a matter outside the Complaints Channel, leaving a record in the complaints register of the decision not to initiate an investigation.
• Admission and subsequent filing of the file by; lack of evidence, lack of credibility, being a false complaint or in bad faith, leaving a record in the register of complaints. The absence of evidence, if any, will not prevent the subsequent initiation of a new investigation if additional information is received.
• Admission and initiation of investigation of the reported facts, immediately notifying the Administration body and the Compliance Committee. Within 5 days from the admission of the complaint, the Compliance Officer will open an internal investigation, in the processing of which, acting autonomously and impartially, may collect all the information and documentation it deems appropriate, with the help of internal staff and/or or external for technical and/or evidentiary issues.

Within 15 days from the end of the investigation phase, the Compliance Officer will prepare a Report describing the facts, the evidence collected, the proposed measures, together with the conclusions. This Report will be forwarded and submitted to the Compliance Committee for analysis. Within 30 days of receipt, the Committee´s assessments will be reflected in a Resolution that will contain, at least: the qualification of the facts, determining their veracity or not, their consequences, and, if applicable to the case, will determine the corresponding sanctions. the offender, in addition to defining the need for preventive and/or corrective actions aimed at avoiding the same events again.

If the offender is an employee, the Person Responsible for the People Area is in charge of imposing corrective and/or disciplinary measures in accordance with applicable labor legislation, based on the Resolution adopted by the Compliance Committee. The Term for the imposition of the sanction will be that established in the applicable collective agreement, or in its case in the Workers´ Statute, for the imposition of the appropriate sanction based on its qualification.

In the event that the Compliance Officer verifies the existence of criminal offenses, she will inform the competent authority of the facts, in addition to initiating the specific procedure related to the Crime Prevention Model.

Confidentiality and Protection of Personal Data

The Complaints Channel is managed exclusively by the Mtorres Compliance Officer. In this way, the company guarantees that the information received through the Complaint Channel is completely confidential, and is used exclusively for the purpose of clarifying the object of the complaint. All the information provided throughout the processing of the complaint file will be eliminated within a maximum period of three months from the closing of the complaint, unless ordered by the competent authority. Likewise, the necessary technical and organizational measures are established to guarantee compliance with the Personal Data Protection regulations.

Through this channel, any interested party can raise any questions, queries or suggestions related to our Code of Conduct and the Corporate Compliance Model. Being able to do it at the following email address compliance@mtorres.com.