Code of Ethics:

At VELLSAM we apply an Integrated Management System in accordance with the standardized ISO 9001:2015 quality standards and the ISO 9001:2015 quality standard.
14001:2015 of Environmental Management.

The Code of Ethics is the fundamental rule of our organization, drawn up for the development and improvement of our culture of ethics, regulatory compliance and good corporate governance.

This Code of Ethics has been prepared for our employees, managers and administrative body, as well as for our business partners (distributors, contractors, customers or collaborators) and aims to make all of them participants in the principles, values and ethical conduct that must govern the relations between them.

This Code of Ethics is mandatory knowledge and compliance for all our employees, regardless of the function of the position they hold or the geographical area where they work.

Our ethical principles are:

– Observance and compliance with this Code and other internal rules.

– Zero tolerance for criminal or illicit acts, and absolute rejection of corrupt or fraudulent practices.

– Innovation as the engine of our growth

– Training our customers in the application of our products.

– Sustainable growth, with absolute respect for the environment.

– Sustainable and efficient production of our products

– Relationships with our partners based on trust, with high ethical standards.

– Respect for free and fair competition.

– Occupational health and safety, guaranteeing the establishment of measures to achieve this goal.

Criminal Compliance Policy:

VELLSAM sets the will to comply with the law and maintain an ethical conduct in the development of its activities, set in our Code of Ethics.

The Criminal Compliance Policy includes the aspects of our Criminal Compliance Model implemented in the company, which accredits the existence of an organization and management model with surveillance and control measures to prevent and detect the risks of illegal activities.
fraudulent and corrupt practices in the organization.

Our Criminal Compliance Policy is aligned with our Code of Ethics, showing the will of the organization to maintain a conduct in accordance with our principles and values to be followed by all our employees in the development of their professional activity, and being one of the strategic objectives zero tolerance towards any irregular conduct that may constitute a crime.

All members of the organization, including members of the governing body and senior management, must comply with this Policy and the rest of the implemented Criminal Compliance Model.

Compliance with this Policy is mandatory for all personnel of the organization, regardless of their functional position and employment relationship.

Likewise, this Policy may be extended to third parties that have a relationship with our organization, when necessary for the fulfillment of our own compliance objectives or maintenance of our ethical and regulatory principles.

The Anti-Corruption Policy:

The recipients of this Anti-Fraud and Anti-Corruption Policy of VELLSAM are the members of its Governing Body, Senior Management and all personnel or workers that make up the company, regardless of the contract that determines the employment relationship with VELLSAM, as well as the function or position they hold, who are obliged to comply with all the rules and guidelines established in the same.

Indirectly, it is also applicable to persons and entities related to VELLSAM as suppliers, customers, consultants, intermediaries, as well as related third parties abroad, who must be familiar with the anti-fraud and anti-corruption regulations contained in this Policy.

VELLSAM adopts a zero tolerance stance towards Fraud, Bribery and Corruption. It therefore implements all necessary measures to combat this behavior, whether it is directly associated with the provision of services, in its relationship with third parties, as well as to prevent and avoid reputational and image damage, as follows:

A) Undertakes to act at all times in accordance with the legal regulations in force, VELLSAM’s internal regulations, Code of Ethics and Criminal Compliance Policy, as well as its related Corporate Policies.

B) Commits to communicate, encourage, promote and strengthen, within the entire organization, an anti-fraud, anti-bribery, anti-corruption and ethical responsibility culture, for all members of the company, regardless of their hierarchical level, and will enable a whistleblower channel in accordance with Directive 1936/2019 to facilitate the prevention, detection and reporting of any dishonest, fraudulent or corrupt conduct.

C) It undertakes to handle any report of fraudulent or corrupt acts in the shortest possible time, establishing a specific procedure for the Complaints Channel, regardless of the subject involved or the economic amount, evaluating
the facts with transparency, confidentiality and objectivity. All potential investigations will be conducted without regard to the offender’s job title, position or relationship with VELLSAM.

D) Finally, VELLSAM imposes on itself the obligation not to continue to maintain ties with members of the organization, as well as third parties related to the company abroad, who have been convicted for activities related to Fraud, Bribery or Corruption.

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