Ethics and Compliance

  • Ethics and Compliance
    Ethics and compliance are two essential elements for any organization committed to social and economic progress, therefore, to guarantee this commitment, from the Board of Foundation we want to project the message that all the actions of the people related to the foundation, must be guided according to the highest ethical standards, thus contributing to the development of society, whom the foundation ultimately serves.

    From the Board of Foundation, we are aware of the importance of projecting to the entire organization the difference between what we have the right to do and what is right, not everything is acceptable to achieve our objectives, and even less so if this threatens the rules which we have endowed ourselves. For this reason, we convey our firm conviction to pursue and act against any type of irregularity, even if its realization supposes a benefit, direct or indirect, for the FIDAMC.

    Likewise, after the 2010 reform of the Criminal Code and, especially, after the modification made by Organic Law 1/2015, we are aware of the need to have an organization and management model in the prevention of criminal risks. Consequently, and in accordance with the requirements of article 31 bis of the Criminal Code, we have implemented a Crime Prevention Model, Corporate Compliance, which guarantees compliance with the legal system.Corporate Compliance elements:

        •   Analysis of criminal risks
        •   Criminal risk management
        •   Ethics and Compliance Committee
        •   Code of Conduct
        •   Complaints Channel
        •   Training and information
        •   Periodic review
    Corporate Compliance Policy download:

    Compliance Policy
  • Code of Conduct
    The FIDAMC Code of Conduct (Code) is the document which contains the basic rules of behavior that must obey by people who work to the Foundation. The matters contemplated in this Code are complemented by the rest of the internal policies, protocols and procedures that regulate specific matters.

    The Code facilitates the knowledge of what is allowed and what is prohibited, being a powerful tool for the prevention, or, where appropriate, the detection of irregular conduct, and, therefore, constitutes the key piece of the Model. Crime Prevention, Corporate Compliance, adopted by the Board of Foundation in accordance with the requirements of article 31 bis of the Penal Code.

    Code of Conduct download:

    Code of Ethics
  • Ethics and Compliance Committee
    According to article 31 bis of the Criminal Code, the Ethics and Compliance Committee is the autonomous body in charge of guaranteeing the Crime Prevention Model, Corporate Compliance, which is made up of compliance personnel, according to the list below.

    Ethics and Compliance Committee
    President Human Resources Manager
    Secretary Compliance Officer
    Vocal Human Resources Officer
    Vocal Operations Manager
  • Whisteblowing Channel
    ¿What is the Whisteblowing Channel? It is the instrument of communication that FIDAMC makes available to any interested party to report, confidentially and without fear of reprisals, any irregular act or conduct related to the foundation. Scope The scope of the Whistleblowing Channel includes any breach of the Code of Conduct and applicable law. This channel cannot be used to make labor claims and / or individual requests of any kind. Prohibition of retaliation against the complainant Taking any action against an employee of FIDAMC that constitutes retaliation for making a complaint is strictly prohibited. Action against bad faith complaints The FIDAMC expresses its commitment to pursue and act against complaints of bad faith, understood as those that, knowing they are false, are formulated with the purpose of harming the accused and/or damaging the interests of the foundation. Confidentiality of the Whistleblowing Channel In accordance with the applicable law, the complainant may maintain their anonymity, however, to speed up the investigation and facilitate the clarification of the facts, it is recommended to show the identity of the complainant. In this case, the complainant's personal data will be confidential, and will be handled exclusively by compliance personnel. How to make a report? The complaint can be filed through the following channels:

    - E-mail:
    - Web form: Whisteblowing Channel Form
    Personal data protection The personal data provided will be kept during the investigation process, and will be deleted within three months from the receipt of the complaint, unless, may necesary the adoption of measures against the denounced, in this case they will be kept for the time established by the applicable legislation.
    For more information on the processing of personal data provided in the Complaints Channel, read the following link:
    Protection of personal data
  • How can I raise a doubt?
    FIDAMC has an enabled channel through which any interested party can make inquiries or suggestions on issues related to the Corporate Compliance at the following e-mail.