Sidenor 2022 Sustainability Report

41 possible quality, service and cost conditions, and contains the commitment of its staff to performing all its tasks in a friendly, transparent and honest manner. Corruption and bribery One of the fundamental principles of our Code of Ethics establishes that the business and professional activities of Sidenor and its employees shall be based on the value of integrity and developed according to the principles of honesty, avoidance of any form of corruption and respect for the specific circumstances and needs of all persons involved. In line with this fundamental principle of ethical integrity, 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 favors 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 also be made anonymously or confidentially. As a matter of fact, Sidenor also provides all its employees with an email account 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 2022, none of the Group companies of Sidenor Holdings Europa received any complaint related to cases of corruption, bribery or money laundering. Besides, in 2016, we also implemented a criminal risk prevention program, whose objective is to provide Sidenor with a prevention and control system aimed at reducing the risk of offence commission in the execution of its business and professional activities. After analyzing the criminal risks that might affect the Company and identifying potential offences, including corruption, bribery, traffic of influence and money laundering, the internal control system aims at preventing and mitigating their commission, completely or partially. Since its implementation, the program has been regularly updated and adapted according to changes occurring in the organization, new business circumstances and the result of the review and analysis of processes which are exposed to the risks of offence commission stipulated in the reference standard. Certifications At Sidenor, we have a management system that we integrate into all our activities so as to comply with the highest quality, health and safety and environmental protection, energy as well as information security standards. This commitment is reflected in our various certifications.