Ethical Code

1. Introduction

This document summarises the ethical principles on which the activities of Farmaprojects S.A.U. (hereinafter Farmaprojects) are based. It contains a description of the forms of conduct that must be promoted and of conducts which must be avoided.

The Ethical Code is the highest level of regulatory instrument in the regulatory structure of Farmaprojects. Its principles are developed in the policies, standards and procedures. It represents the company’s commitment to compliance with the laws and the ethical values which are defended in them.

At all levels in Farmaprojects we strive to ensure real and effective application of these principles, so that this system of self-regulation will succeed in removing any act which could endanger the legal values and assets to be protected.

This Ethical Code is incorporated in the Farmaprojects corpus of rules and regulations, and compliance with it is therefore obligatory, as it forms part of the orders and instructions of the employer, in accordance with the provisions of Article 5 of the Workers’ Statute. An infringement of this code will constitute a breach of good contractual faith, which will incur the appropriate sanction.

Having regard to the connection of the ethical principles with forms of conduct which are typified as an offence in the Criminal Code and that the main obstacle to the effectiveness of an ethical code is tolerance of non-compliance, it establishes within the company a standard of zero tolerance at all levels in its structure and seeks maximum collaboration in communication to the Ethical Channel of any risk situation that may be detected.

This Ethical Code must be accepted by any person who is to enter the organisational structure of Farmaprojects as a condition prior to their entry. It contains a sanctions regime which will be applicable in the event of an infringement of the ethical principles contained in it.

The scope of application of the Ethical Code will extend to the suppliers, clients, distributors, external professionals and representatives of Farmaprojects, who will be asked to accept it or their own Ethical Code, one which defends ethical principles and a policy of offence prevention of an equivalent status.

All contracts signed by Farmaprojects must include a clause obliging the other party to comply with the law and with the ethical principles established in the Ethical Code of our company or of their own, of an equivalent content. The other party must also apply comparable prevention and control policies which will enable verification. Failure to comply with these obligations will be equivalent to a serious breach of contract.

2. Scope Of Application

  • Scope regarding companies – this Ethical Code is applicable to Farmaprojects.
  • Scope regarding personnel – this Ethical Code is applicable at all levels in Farmaprojects, including its management bodies, senior management, checking and control bodies and all the personnel
  • Scope regarding third-party relations. The scope of application of this Ethical Code shall extend, as far as possible, to the suppliers, distributors and clients of Farmaprojects. Should this not be possible, contracting must be limited to companies which have similar policies, or alternatively standards of conduct, preventive measures and control systems must be imposed contractually to prevent forms of conduct contrary to the principles contained in this Ethical Code.
  • Geographical scope – this policy shall apply to Farmaprojects activities carried out in any geographical context, both local and international.

3. Environment, Collective Safety And Public Health

  • Farmaprojects must carry out its activities at all times with respect for the natural environment, with minimum consumption of resources and control of the environmental impact.
  • Farmaprojects must establish checks in the areas of discharges, emissions, noise, vibration, waste, destructive ozone layer gases and any other environmental threat.
  • At all levels in the company we must strive to achieve rational use of resources, respect for the environment and sustainability.
  • Controls must also be established for any activity or product which might, directly or indirectly, create a risk to public health and safety, due to the toxicity of the components or any other threat to persons.

4. Right To Privacy

  • Farmaprojects shall respect and protect the privacy of persons who, in their dealings with the company, may supply it with personal details or information of a confidential nature.
  • This protection shall extend to the workers, clients and collaborators of Farmaprojects and shall apply from the design stage to any new service that may be developed by the company.
  • The company’s web pages must display a privacy policy and cookies policy to inform visitors of the scope and purpose of the processing of their details.
  • Farmaprojects shall monitor the channels through which details of a personal nature are obtained and shall ensure that all the necessary requirements for compliance with the relevant regulations are satisfied.
  • The details shall be stored subject to security measures commensurate with their nature.
  • The checks and inspections arising from application of the offence prevention and control model and of this Ethical Code shall be carried out according to a protocol which guarantees respect for the privacy and dignity of the persons concerned.
  • Performance evaluations and any communication to the Ethical Channel shall be protected by an obligation of secrecy on the part of the persons involved in handling them.

5. Right Of Equality

  • Working relations at Farmaprojects are based on the principles of mutual respect and equality.
  • No form of discrimination will be permitted against any person by reason of their ideology, religion or beliefs, their belonging to an ethnic group, race or nation, their gender, sexual orientation, family situation, illness or handicap, their acting as the legal or trade union representative of the workers, their relationship to other workers in the company or their use of any of the official languages within the Spanish state.
  • All levels at Farmaprojects must observe this principle.

6. Safety At Work

  • All work to be carried out at Farmaprojects must comply with the safety conditions specified in the working risks prevention regulations.
  • Farmaprojects is under an obligation to establish the safety measures demanded by law and the worker is bound to respect them. It is forbidden to remove or override any safety measure applied to the job.
  • The policies, rules, procedures must include the control duties and responsibilities at each level in the company on this subject.

7. Workers’ Rights

  • In no circumstance may working or social security conditions be imposed in Farmaprojects which would impair, eliminate or restrict the rights to which workers are entitled in legal provisions, collective labour agreements or individual contracts.
  • Nor may workers be recruited without a declaration of their inclusion in the relevant Social Security Scheme.
  • With regard to foreign workers, these may be recruited only in compliance with applicable law. Contract or placement simulation techniques should not be applied.
  • Personnel selection processes must employ a form of methodology which guarantees that the job offers are genuine, and in no circumstance may misleading or false working conditions be offered.
  • The privacy and dignity of a job candidate must likewise be insured in enquiries into the references offered directly or via the social networks and former employers, and in the processing of details relating to their curriculum vitae.
  • Farmaprojects must respect the workers’ right of trade union membership and the right to strike.
  • Where contracting with foreign suppliers is concerned, the company shall strive to establish that none of them are involved in cases of child exploitation.

8. Market And Consumers

Farmaprojects bases its activities in the market on the principles of free competition and equality of opportunity, and rejects any action designed to achieve an unfair or unlawful profit, gain or advantage in relation to the clients, suppliers, competitors and other players in the market.

The following acts or forms of conduct are therefore considered unethical and are prohibited:

  • Unauthorised access to the confidential information of other companies.
  • Industrial espionage
  • Disclosure of company secrets.
  • Use of its own or external advantageous information for any kind of transaction or business.
  • False publicity.
  • Scams, fraud and deceit of any kind.
  • Spreading of false rumours concerning products, services, market conditions, and etcetera.
  • Manoeuvres to alter the price of third party products.
  • Manoeuvres to alter the listed price or value of a company.
  • Manipulation of public tender processes.
  • Falsification of forms of payment.
  • Manoeuvres to place the company in a situation of insolvency in order to evade creditors.

With regard to these activities, special attention is to be given to the following prohibited forms of conduct:

  • Accessing data, technical information concerning the products or company strategies of a competitor via a common supplier, a relative, a confidential contact or an investigation which goes beyond information that might be considered public.
  • Making false statements or promises to a client or to the market concerning the qualities or characteristics of its own product or that of a competitor.
  • Distortion of the company’s economic and financial information and especially the annual accounts.
  • Spreading rumours via the social networks, media or directly to clients, concerning a competitor, its products and services, or about any other company.
  • Taking advantage of reserved information to which it may have gained access because of its position or the work being done in the company in order to pass it to third parties, sell it or use it in order to buy or sell shares, or for any other transactional business.
  • Engaging in any kind of unfair action which may place the company in an advantageous situation in the market

9. Corruption

Farmaprojects bases its relationship with the public sector and the private sector, both nationally and internationally, on the principles of transparency and equal opportunity, and rejects any action intended to achieve advantage over competitors, in the market or in public or private contracts based on an unlawful act.

Therefore, public incumbents and officials or representatives of private companies must not be offered or favoured with money, gifts or any other financial or material benefit intended to obtain any kind of advantage in the company’s favour.

Farmaprojects will have an anticorruption policy and a standard governing travelling and representation expenses.

Any act or strategy intended to guide or influence the actions of a public servant or authority by taking advantage of any situation derived from a personal relationship with this person or with another public servant or authority in order to obtain a decision which may directly or indirectly generate financial benefits or avoid a loss of any kind by the company itself or by a third party will be deemed to constitute the peddling of favours.

No activity whatsoever may be carried out if it could constitute peddling of favours, and in particular the activities summarised below:

  • Directly influencing a public servant or authority.
  • Indirectly influencing by accepting the offer of a third party.
  • Influencing via the services of a third party.

Donations may not be given to political parties or to foundations associated with them. This prohibition shall also apply to foundations linked to Farmaprojects.

Farmaprojects will apply a protocol to ascertain the true destination of funds before making a donation to an NGO or participating in a sponsorship or patronage project or any other social, cultural, scientific, charitable, sporting or similar project, in or with  which it might participate or collaborate.

A conflict of interest shall be deemed to exist in a situation in which a company action or decision might be influenced by a particular interest of the company person or persons involved in it, or third parties with which they might have a personal association.

A duty to avoid situations which could involve a conflict of interest must exist at all levels in Farmaprojects.

In the case of action to enter, trade in or establish the company in foreign countries, no payments or gifts directed at public servants in those countries in order to facilitate an administrative process, obtain an import license or permit, favour or service of any other kind may be made.

10. Tax And Social Security

  • Farmaprojects shall comply exactly with its tax and Social Security obligations.
  • Farmaprojects accounting records must be a true representation of the company’s economic situation, including all the income and payments made. No manoeuvre designed to conceal income or benefits will be accepted.
  • All levels at Farmaprojects must be alert to any client or supplier that may try to use the company structure for a money-laundering operation. Any suspicion of a risk situation in this area must be notified immediately to the Ethics and Compliance Commission via the Ethical Channel.
  • Any transaction or dealings with an organisation or company which might be related to the financing of terrorist activities must likewise be communicated.
  • As far as possible, the use of cash in payments made by Farmaprojects must be limited and in any event must be done subject to the relevant checks to determine both its origin and destination.
  • In the event of cash being required, a register must be kept detailing the payments made with it. The register must specify the amount paid, the item, the date of payment and its destination.
  • In no circumstance may payments be made to natural or legal persons other than those stated in an invoice.
  • In no circumstance may payments be received from natural or legal persons other than those stated in an invoice.

11. Intellectual And Industrial Property

Farmaprojects bases its policy of creation of intangible assets on the promotion of creativity and innovation with the strict aim of obtaining products which will benefit public health.

Without the prior appropriate written authorisation, it will not be permitted to copy or reproduce, in whole or in part, the intangible assets of third parties, or to convert or modify, totally or partially, such assets when imported or distributed.

Books, videos, photographs, publications and editorial content, musical works, prints, advertising campaigns, slogans, leaflets, catalogues, writings, speeches, presentations, reports, studies, drawings, graphics, paintings, comics, projects, plans, maps, models, architectural or engineering designs, computer programs and any other protected works shall come within the category of intellectual property, even if the copyright symbol or the reservation of rights is not shown.

Special attention must be given to content and programs downloaded from the Internet, which must have the relevant licence from the owner of intellectual property rights, even if they have been obtained via browsers such as Google. All programs installed in the company’s computers and mobile devices must have the relevant usage license.

The same protection shall apply to trademarks, patents, industrial designs, domain names, know-how (industrial and/or commercial secret) and other intangible assets protected by industrial property.

12. Computer Security

At all levels in Farmaprojects a constant watch must be maintained to detect offences that might be committed through the use of information technologies.

In particular among such offences are the following which constitute acts prohibited in Farmaprojects:

  • Unauthorised access to the computer systems of competitors, clients, or any other public or private company or organisation.
  • Spreading of a virus or programs which could cause damage to tangible or intangible assets.
  • Service denial attacks.
  • Manipulation of electronic auctions.
  • Any other kind of computer damage, including sabotage or the simple alteration of the data or information contained in a third party computer system.
  • Electronic scams, including phishing, pharming and any other kind of trickery based on the use of information technologies or social engineering.
  • Spreading of rumours, critiques and boycotts via the Internet and the social networks, including retweets and the resending of messages of any kind.
  • Carrying out misleading publicity campaigns and promotions.
  • Infringement of the intellectual or industrial property in technological assets.
  • Industrial espionage via the Internet.
  • Illegal discovery and disclosure of company secrets obtained via the Internet.
  • Unauthorised assignment of databases.
  • Unauthorised obtaining or assignment of personal details of a confidential nature.
  • The investigation of persons in the social networks invading their privacy.
  • The registration of domains using third-party brands and business names.
  • Money-laundering via electronic or own consumption transactions.
  • Child pornography.

Farmaprojects will have a regulation to govern in detail the use of corporate TIC resources by users, both internal and external.

13. Urban Control

  • Farmaprojects will base the management of its properties, property operations and construction, building and urban development initiatives in compliance with the urban regulations and with the central, autonomous region and local regulations governing them.
  • Farmaprojects shall not carry out urban development construction or building work which cannot be authorised on land which is reserved for occupation by roads, green areas, public amenities or places whose scenic, ecological, artistic, historic or cultural value has been acknowledged legally or administratively, or which for the same reasons may have been deemed to warrant special protection.

14. Prevention And Control Model

  • Farmaprojects shall have a Prevention and Control Policy containing a description of a prevention and control model designed to avoid the commission of offences in the company.
  • This policy shall contain a description of the key elements, whether human, organisational or documentary, which the company will apply in order to avoid legal infringements, and in particular acts which could be typified as an offence in the Criminal Code.
  • At all levels in Farmaprojects a constant watch must be maintained to ensure real and effective application of the prevention and control measures envisaged in that policy, to make this self-regulation system effective in eliminating forms of behaviour which could jeopardise its reputation in the market and the tangible and intangible assets of the company and of its components.
  • This policy shall be adapted to reflect any tendency in case law and any modifications in the Criminal Code with regard to the criteria for accusation and the prevention and control requirements demanded in matters of criminal liability.

15. Ethical Channel And Communication Of Risks

At all levels in Farmaprojects there will be an obligation to communicate risk situations which might arise within or outside the company, which could cause loss or damage to any natural or legal person.

Instances of infringement of the law, of the Ethical Code and of the regulations for its development must also be communicated.

Farmaprojects will have an Ethical Channel to which warnings of the existence of a risk or non-compliance situation must be addressed, also any proposal for improving the prevention and control model.

Communications to the Ethical Channel may be sent via an electronic mail or postal address.

The channels for communication with the Ethical Channel are as follows:

The Ethical and Compliance Committee shall be responsible for managing the Ethical Channel and attending to communications sent to it.

Communications sent via the Ethical Channel must be protected by the maximum confidentiality.

16. Disciplinary System

  • Breach of this Ethical Code or of the regulations implementing it will constitute a violation of good contractual faith. The disciplinary system established in the labour regulations shall be applied and, if such is the case, in the collective labour agreement to which the company belongs.
  • The sanction proceedings shall begin with an accusation, or a communication, as a result of an investigation or originating in any other way that could warrant examination by the Ethical and Compliance Committee of the alleged infringement.
  • The protocol for investigation of the alleged infringement shall be that established in the company’s Prevention and Control Policy and shall be confidential.

17. Updating And Improvement

This Ethical Code shall be updated periodically in order to include any improvements considered necessary in order to define the ideal form of conduct to be developed in the company.

The Ethical and Compliance Committee shall carry out a constant audit of the application of the Ethical Code and of the Prevention and Control Model, and shall propose the relevant modifications in the following circumstances:

  • When relevant infringements of the Ethical Code or of the set of regulations to develop it become apparent.
  • When there are significant changes in the company or in its activity.
  • When there are changes in the company’s control structure.

The Ethical Committee and the Compliance Committee shall apply the protocol established in ANNEX V of the Prevention and Control Policy in order to investigate any incident or non-compliance concerning the Ethical Code and the Prevention and Control model of which it may become aware.

If the investigation of a risk makes it possible to identify an area for improvement, the Ethical and Compliance Committee shall issue an improvement proposal, to be sent to the department concerned, nominating a person responsible for this and a deadline for monitoring its application.

18. Connection Of The Ethical Principles With The Criminal Code

An infringement of the ethical principles described in this code may, in most cases, match elements of the criminal type of offence defined in the Spanish Criminal Code.

These references are listed below:


Ethical principleRelated offences
Safety and hygiene at workInfringement of the working risks prevention regulations
Workers’ rightsOffences against workers’ rights
Protection of trade union freedomOffences against workers’ rights
Protection of equalityOffences against workers’ rights
Protection of privacyOffences against privacy
Protection of minorsChild exploitation
Protection of foreign citizensExploitation of foreign citizens
Protection of the environmentEnvironmental offences
Protection of collective safetyCollective safety offences
Protection of public healthPublic health offences
Protection of the market and of consumersFalse publicity
 False rumours
 Alteration of prices and quotations
 Falsification of means of payment
 Punishable insolvencies
 Industrial espionage
Free competitionManipulation of public tender processes
Fulfilment of legal obligationsOffences against the Public Exchequer and Social Security
Prevention of corruption. No financing of political partiesPublic sector corruption
 Private sector corruption
 International corruption
 Peddling of favours
No use of privileged informationUse of privileged information
Prevention of money launderingMoney-laundering
Protection of computer securityIT damage
Respect for intellectual propertyIntellectual and industrial property
Protection of urban controlUrban control offences