Social Responsibility and Sustainability Report 2016 | PRISA PRISA, a global group 51 trusted not only with the supervision of the company’s crime prevention model, but also with promoting ethical behavior among employees, and with monitoring compliance with applicable laws and the internal regulations governing all the Group’s activities. This new unit –made up of the Secretary General, the Director of Internal Audit and the Director of Human Resour- ces– is an independent body that reports to the Audit Committee and has its own Operating Regulations that have also been approved by PRISA’s Board of Directors. In addition, other compliance units have been created in sub-holding companies of the major business units, and which oversee the companies making up their respective business units. In 2015, the company has embarked on the process of reviewing the Crime Prevention Model, a process that is expected to be finalized in 2016. Among the more noteworthy actions initiated by the company in this area are the adoption, in December 2015, of a new Code of Ethics for PRISA, which replaces the Code of Conduct that had been in force since December 2011. New Code of Ethics In December 2015, the Board of Directors of PRISA, acting on a request from the Corporate Governance Committee, approved a new Code of Ethics, which outlines a range of guiding principles and rules of conduct that govern the actions of all companies within the Group and all professionals (members of the go- verning bodies, managers, workers, trainees and interns). Moreover, beyond its strict in-company scope, the Group is committed to promoting awareness and its adoption among its business partners, journalistic and publishing collaborators, suppliers and business collaborators. The Code sets out general ethical principles and general rules of conduct relating to: i) Regulatory compliance and integrity of professional conduct. ii) Use of resources for the performance of professional activity. iii) Conflicts of interests among professionals and customer relations with the Group. iv) Internal control and prevention of corruption: regulating aspects such as the reliability of information, control of records, reserved and confidential information, protection of personal data, gifts and favors, bribery and anti-corruption measures, and prevention of money laundering and irregularities in payments. v) Corporate image and reputation. vi) Relations with other stakeholders (shareholders and investors, partners in commercial projects, clients and customers, employees, suppliers, contractors and business partners, competitors, governments and authorities, etc.). The Compliance Unit is responsible for ensuring compliance with the Code and for promoting its dissemination and providing relevant training in the matter. In this regard, in 2015, the Code was communicated and disseminated among all employees who are subject to its principles, and a specific plan is in place for all professionals in 2016. The Code of Ethics is permanently available on the corporate website www.prisa. com and PRISA’s global intranet, Toyoutome. Complaints channel PRISA has a complaints channel for receiving and dealing with complaints concerning irregularities or breaches of both external and internal regulations in matters affecting the Group, its employees or its activities. This channel was first implemented in 2011 in order to comply with the Sarbanes-Oxley Act and it has been maintained by express decision of the Board of
Memoria 2016 EN_PRISA_20160315_V4 baja
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