Criminal Risk Prevention Policy – ALDEBARAN SISTEMAS

SCOPE

The provision of this Criminal Risk Prevention Policy applies to all the members of ALDEBARÁN SISTEMAS, SL (hereinafter, ALDEBARÁN).

For these purposes, “members” are considered to members of the Management Body, managers, middle management and staff (self-employed or employed) who provide their services on behalf of ALDEBARÁN, regardless of the type or duration of their employment.

ALDEBARÁN promote the application of the provisions herein, to the extent applicable to its suppliers, service providers, partners, government and other third parties with whom it interacts in the course of its activities.

COMMITMENT OF THE MANAGEMENT BODY OF ALDEBARÁN

The Management Body of ALDEBARÁN is responsible, among others, for formulating the strategy and approving the ALDEBARÁN Criminal Risk Prevention Policy, as well as organizing the internal control systems in order to maintain rigorous control of compliance in the organization.

It is for this reason that, in the exercise of this responsibility and, in line with the corporate culture of risk prevention, through this Policy, the Board of Directors shows the firm commitment of ALDEBARÁN and all its members to:

Know and comply strictly with current legislation in the area of development of its activities, as well as to fully respect the obligations and commitments assumed in its contractual relationships with third parties.
Put in place all necessary means and resources to facilitate, where appropriate, the prevention, control, detection and sanctioning of unlawful or unethical acts and conducts that may be committed within ALDEBARÁN.
Respect the general principles for the prevention of crime contained in the Criminal Risk Management System Manual and compliance with the Code of Conduct.
Maintain an honest and upright behaviour in all its actions, avoiding all forms of fraud, corruption and conflict of interest, as well as respecting at all times the circumstances and needs of all stakeholders in the activities of ALDEBARÁN.

The commitment to zero tolerance and opposition to the commission of any kind of illegal act (civil or criminal), and to maintain at all times a culture of honesty, integrity and ethics promoted by the Management Body, must be observed by all members that make up ALDEBARÁN and by interested parties who are related to ALDEBARÁN.

Consequently, strict compliance with the law, the Code of Conduct, as well as the remaining internal regulations of the Management System for the Prevention of Criminal Risks (SGRP) or Compliance, is mandatory for all members of ALDEBARÁN; so that appropriate disciplinary measures will be taken, case by case, to punish any breach according to the disciplinary regime established in the Criminal Risk Management Manual.

As an example of this firm commitment, ALDEBARÁN Management Body has appointed a Compliance Responsible, with autonomous powers of initiative and control, in charge of the development, supervision and monitoring of the SGRP; having been endowed with the resources, Independence and authority necessary for the development of its functions effectively.

ALDEBARÁN also has a Whistleblower Channel, as a channel of communication, anonymous and completely confidential that is made available to all members of ALDEBARÁN and interested parties, who have the obligation to report any suspicious or knowledge of actions or omissions that constitute breaches of European Union Law, or that may constitute a criminal or serious or very serious administrative offence; these include, specifically, those that may involve a financial loss to the Treasury and Spanish National Health System, as well as conduct contrary to this Policy, the Code of Conduct and other regulations within ALDEBARÁN.

PUBLIC COMMUNICATION

The Criminal Risk Prevention Policy convers ALDEBARÁN’s commitment to zero tolerance and opposition to the commission of any kind of illegal act, as well as to maintaining at all times a business culture based on honesty, integrity and ethics is promoted by the Management Body, and must be observed by all members that make up ALDEBARÁN and interested parties that are related to ALDEBARÁN.

COMMITMENTS OF THE CRIMINAL RISK PREVENTION POLICY

Know and comply strictly with current legislation in the area of development of its activities, as well as fully respect obligations and commitments assumed in its contractual relation with third parties.
Put in place all the means and resources needed to facilitate, where appropriate, the prevention, control, detection, and punishment of unlawful or unethical acts and conducts that may be committed within ALDEBARÁN.
Respect the general principles for the prevention of offences, as set out in the Criminal Risk Management System Manual and compliance with the Code of Conduct.
Maintain honest and upright behaviour in all actions, avoiding all forms of fraud, corruption and conflict of interest, as well as respecting at all times the particular circumstances and needs of all parties involved in the activities of ALDEBARÁN.

As an example of this firm commitment, ALDEBARÁN has configured a Criminal Risk Management System, appointing a Compliance Responsible, with autonomous powers of initiative and control, in charge of the development, supervision and monitoring of the system, having been provided with the resources, independence and authority necessary to carry out its functions effectively.

Strict compliance with the law, the Code of Conduct and other internal regulations is mandatory for all members of ALDEBARÁN, so that appropriate disciplinary measures will be taken on a case-by-case basis, to punish any breach in accordance with the disciplinary regime established in the Penalty Risk Management Manual.

ALDEBARÁN also has a Whistleblower Channel, as a channel of communication, anonymous and completely confidential that is made available to all members of ALDEBARÁN and interested parties, who have the obligation to report any suspicious or knowledge of actions or omissions that constitute breaches of European Union Law, or that may constitute a criminal or serious or very serious administrative offence; these include specifically, those that may involve a financial loss to the Treasury and Spanish National Health System, as well as conduct contrary to this Policy, the Code of Conduct and other regulations within ALDEBARÁN.