Compliance is now a central issue for any company. Globally, companies face an unprecedented challenge in the face of increasingly intense regulatory control. That’s why our procedures have to be permanently in line with the legislation in force, highlighting the strictness and transparency. To underline our commitment to legal compliance, we have adopted as a Company Principle that “We comply with current legislation and internal rules”. Compliance is therefore an essential component of our corporate culture.
EST maintains a Compliance Management System that allows you, as our client, business partner or company employee, to deal with an organization that is structured, uniform and committed to its standards and procedures.
Compliance rules of conduct
To ensure the implementation of our Company Principle “We comply with current legislation and internal regulations” we apply the following Rules of Conduct and Compliance: 1. We do not allow ourselves to be influenced by conflicts of interest or bribes and we reject corruption and fraud as a means of achieving our goals. 2. We protect the personal data of our employees, customers and business partners and only process this data on the basis of legal authorization or consent. 3. We respect fair and undistorted competition. 4. We ensure the safety and compliance of the provision of our services, thereby protecting all stakeholders, in particular against harm to health. 5. We respect the company’s assets and trade secrets. 6. We keep proper accounts and comply with our tax and customs obligations. 7. We take all the necessary measures to prevent money laundering and not to make financial resources available to sanctioned business partners in our area of influence. 8. We respect human rights. 9. We carry out our business activities in harmony with the environment. 10. We also expect our business partners and those involved in our entire supply chain to behave responsibly and in accordance with the law.
Code of conduct
EST Group attaches great importance to social and ecological sustainability in cooperation with its business partners, as well as throughout the service and supply chain. The Code of Conduct for business partners describes the fundamental principles of cooperation with them.
The principles set out here represent the minimum standards that must be observed in our business relations.This Code of Conduct is based on the following principles and international conventions:
- Universal Declaration of Human Rights
- United Nations Global Compact – UNGC
- United Nations Guiding Principles on Business and Human Rights
- United Nations Convention on the Rights of the Child
- United Nations Convention on the Elimination of All Forms of Discrimination Against Women
- OECD Guidelines for Multinational Enterprises
- ILO Declaration on Fundamental Principles and Rights at Work
- Paris Agreement on climate change
The laws and regulations, whether national or applicable in the countries where the company does business, and the principles set out in this Code of Conduct must be complied with. Of all the applicable rules, the one that proves to be best suited to protecting the respective purposes must always be chosen. In addition, an internal procedure must be adopted to ensure correct implementation and monitoring of these standards.
Active, passive, and other types of corruption are prohibited. The business partner must diligently comply with all professional norms and standards applicable to its sector of activity. The masculine form is used for reading convenience only and does not reflect any gender discrimination.
1.1. Principle of non-discrimination The trading partner refrains from any form of discrimination. In particular, no one may be disadvantaged because of their age, gender, sexual orientation, pregnancy, disability, nationality, ethnic origin, skin color, religion or belief, political conviction, social origin, or marital status. Discrimination exists when a person is disadvantaged because of the above-mentioned characteristics or other factually unjustified circumstances. Equal opportunities for women and men are ensured in all aspects of personal and professional training and development.
1.2. Fair treatmentAs a matter of principle, the trading partner does not use forced labor or involuntary prison labor. It ensures that there is no harsh or inhumane treatment in the workplace. This includes sexual harassment, physical punishment, moral or physical coercion of employees. Employees may not be coerced into such conduct either.
1.3. Wages and working hours The business partner complies with all laws, regulations and relevant standards to the respective sector of activity with regard to wages and working hours. Wages and other allowances must at least correspond to local legal regulations and economic standards. They must be clearly defined and must be paid and made available regularly and in full. The aim is to pay wages and other allowances that make it possible to meet the cost of living if the legal minimum wages prove insufficient to do so. Deductions for benefits in kind are allowed to a limited extent and only in proportion to the value of the benefit in kind. The business partner pays the compulsory social benefits and benefits to which employees are entitled under national law (e.g. insurance, overtime supplements and paid leave). In addition, the composition of remuneration must be communicated regularly and in an intelligible manner to employees. The duties arising from the employment relationship must be recorded in writing and made available to the employee in the form of an employment contract. As a matter of principle, the business partner should not withhold amounts related to work resources or tools. Employees do not work more than the legally permitted working hours. The rest days established by law are observed. In addition, employees may not be required to regularly work more than 48 hours per week and, including overtime, no more than 60 hours per week. Such overtime work must be paid separately or compensated with time off in accordance with national legislation. Each employee is entitled to at least one day off after six consecutive working days.
1.4. Freedom of association The business partner guarantees the right to freedom of association. In accordance with applicable laws, employees have the right to meet, found or join trade unions and employee representations. In addition, employees have the right to collective bargaining to resolve wage and other employment-related issues. The exercise of these rights may in no way be punished by reprisals.
1.5. Safety and health The business partner ensures a safe working environment. Workplaces and facilities must comply with applicable laws and regulations. Any violation of fundamental human rights in the workplace and operational facilities is prohibited. In addition, fire and emergency prevention and protection requirements must be complied with in particular. Adolescents (young people), in particular, must not be exposed to dangerous, unsafe or harmful environments that compromise their health or development. Employees must receive regular training on health and safety in the workplace. It is also necessary to ensure adequate cleanliness in the workplace. The same requirements apply if the business partner provides accommodation for employees. An employee health and safety officer must be appointed from among the directors or managers, who is responsible for implementing and complying with health and safety standards in the workplace.
1.6. Disciplinary measures Disciplinary measures must be applied in accordance with national legislation and internationally recognized human rights. Any unjustified disciplinary sanction should be avoided, such as withholding wages, social benefits or documents (e.g. identification documents) or prohibition from leaving the workplace. In addition, the business partner respects its employees’ right to terminate their employment.
1.7. Child labor and protection of minors The trading partner does not use child labor and complies with child protection regulations. The minimum age for admission to employment may not be lower than the age at which compulsory schooling ends. Under no circumstances may employees be under the age of 15 (or 14, if permitted by national legislation in accordance with ILO Convention 138). National regulations and international standards regarding the protection of minors must be complied with. In addition, adolescents (young people) may not work at night.
2.1. Environmental protection legislation
The business partner complies with the relevant laws and regulations on environmental protection.
The business partner’s activity complies with legal and regulatory requirements regarding waste, as well as emissions prevention and water protection. All regulations concerning hazardous substances are complied with by the trading partner. This applies in particular to the storage, handling and disposal of hazardous substances. Employees must be instructed in the handling of hazardous substances and materials.
2.2. Resources and environmental impacts
Environmental impacts must be avoided or reduced by appropriate means. Protecting the environment and the climate, as well as promoting biodiversity, is an ongoing task that can only be achieved by continuously improving the level of protection, by permanently reducing the consumption of resources and reducing waste. To this end, the trading partner shall make the necessary and reasonable efforts within the scope of its commercial activity.
3.1. SubcontractorsSubcontractors used by the business partner to provide its services must comply with standards equivalent to those set out in this Code of Conduct. The business partner must inform subcontractors of the provisions of this Code of Conduct and demand compliance with the requirements and standards set out.
3.2. Reporting infringements and duty to cooperateIf the business partner becomes aware of evidence of an infringement of this Code of Conduct, it must report it immediately. The business partner is obliged to provide written information about infringements on request. The information must contain a detailed description of the infringement, the persons involved and the actual or potential consequences of the infringement (e.g. measures by the authorities). The trading partner participates in the investigation and clarification of infringements. The communication is made with respect for the legitimate interests of the business partner, as well as the rights of employees, in particular the protection of personal data and the protection of business secrets. The same applies to breaches at subcontractors of the business partner. In addition, an internal system for recording breaches of these standards must be established. Employees who blow the whistle must not be discriminated against or disciplined.
3.3. AuditsThe business partner makes it possible to verify compliance with the Code of Conduct. To this end, it provides the information requested in writing and allows on-site audits at its premises. The business partner must provide all the necessary and relevant documentation for the audits carried out. Audits may be entrusted to third parties (e.g. auditors). Whenever requested, the business partner shall ask the subcontractors it uses to grant equivalent audit rights.
3.4. TerminationIn the event of a breach of the principles contained in this Code of Conduct, the business partner may be given a reasonable period of time to resolve the breach or, if this is not possible due to the nature of the breach, may receive a warning. If the business partner fails to remedy the breach within the stipulated period, or if repeated breaches occur, the contractual relationship may be terminated unilaterally without notice. In the event of repeated serious infringements, the contractual relationship may also be terminated immediately and without notice or warning. This is without prejudice to other rights, in particular possible rights to damages or compensation.
If, despite the measures taken, a compliance violation occurs or there is a risk in this regard, we offer employees and third parties the opportunity to inform us through our whistleblowing channels. Possible compliance violations or risks in this context include, but are not limited to:
- Acts and omissions contrary to the law that are punishable by penalties or fines (crimes or administrative offenses);
- Environmental and human rights risks, as well as breaches of environmental and human rights obligations;
- Violations of internal rules with compliance relevance.
Information on possible compliance violations or risks in this area can be submitted through the following reporting channels:Form Submission
If you have any questions about this or would like to make a complaint, please contact our manager.
EST, S.A.Legal DepartmentFilipa Soares Gomesfilipa.email@example.com
A lawyer of trust is bound by confidentiality and professional secrecy.
Filipa Soares Gomes
+351 919 891 489(Local call cost)