Sidenor 2020 Corporate Report

21 Integrated policy This document includes our Health and Safety, Environmental, Quality and Energy policies, as we consider our activity as a whole. Purchasing policy It defines the basic principles for the purchase of goods and services that are necessary for our business under the best possible quality, service and cost conditions. Corruption and bribery Our Code of Ethics proscribes bribes paid to authorities and public officials and prohibits Sidenor people from giving to or receiving from third parties undue payments of any kind, presents, handouts or favours that are outside the realm of market practice or can endanger, or seem to endanger the ability of adopting objective and fair business decisions. 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 2020, none of the Group companies of Sidenor Holdings Europa received any complaint on matters related to corruption, bribery or money laundering. Besides, 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 the context of the company. After analysing the criminal risks that might affect the company and identifying potential offences, the internal control system aims at preventing and mitigating their commission, completely or partially. Since its implementation, the programme has been updated and adapted according to the changes in the organisation and new circumstances of the Company. 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: