Sidenor Corporate Report 2019

17 Gregorio Iparraguirre Campos Sales Manager Enrique Canal López Chief Operations Officer According to the Code, “Where an employee has grounds for suspicion or becomes aware of any non-compliance with this Code of Ethics, he/she shall immediately communicate them to his/her superior or to the Human Resources manager of his/her worksite. This can be made anonymously, confidentially or in any other manner”. Sidenor also provides all its employees with the electronic mail digital tool so that “any employee who has grounds for suspicion or is aware of any non-compliance with this Code of Ethics or has doubts, concerns or complaints regarding its content, might communicate them, anonymously and confidentially”. In 2019, none of the Group companies received any complaint on matters related to corruption, bribery or money laundering. In 2016, we also implemented a criminal risks prevention programme whose objective is to provide the Company with a prevention and control system aimed at reducing the risk of criminal acts perpetrated in its context. After performing an analysis of the criminal risks that might affect the Company and identifying potential offences, we launched an internal control system aimed at preventing and mitigating their commission, completely or partially, and provided employees who are directly concerned with information and training in this regard. Among the criminal risks detected, several are related to corruption, bribery and money laundering. The programme was implemented in 2016 and, in the following years, updated and adapted according to the changes and new circumstances of the Group. Certifications At Sidenor, we have a management system that we integrate into all our activities so as to comply with the highest quality, safety and environmental protection standards. This commitment is reflected in our various certifications: