PONS CONSULTORES DE PROPIEDAD INDUSTRIAL, S.A and PONS PATENTES Y MARCAS INTERNACIONAL, S.L., hereinafter PONS IP, has adopted a Regulatory Compliance System that complies with the requirements of article 31 bis of the Spanish Criminal Code introduced by Organic Law 1/2015 of 30 March, which amended Organic Law 10/1995 of 23 November of the Spanish Criminal Code, and entered into force on July 1, 2015.
The PONS IP Criminal Regulatory Compliance System, adopted by the governing body, is made up by the Compliance Policy Statement, as well as the Compliance Manual, an Executive Summary and complementary annexes.
- AGREEMENT ADOPTED BY THE GOVERNING BODY
PONS IP's governing body approved the company's "Compliance Policy" and Crime Prevention and Compliance Plan. Additionally, it created the compliance body responsible for monitoring the performance and compliance with the prevention and detection of possible crimes, within the framework of the company's actions, as well as for supervising and monitoring the effectiveness of internal controls for the prevention of crimes and compliance with the ethical standards established within the company.
- COMPLIANCE POLICY STATEMENT
The Compliance Policy comprises the general principles that inspire the content and that are applicable in all PONS IP internal regulations and that are applicable to all members and the activities they carry out.
- COMPLIANCE MANUAL
Document describing the organization, collecting and explaining the PONS IP risk map, the possible criminal behaviors that may be committed, and the monitoring and control measures implemented or to be implemented in PONS IP.
- GENERAL CODE OF CONDUCT OR CODE OF ETHICS
Internal company code that compiles the basic guidelines and general principles that must govern and be applied in the actions of PONS IP members. This Code has been developed in such a way that it acts as a "cornerstone" of the PONS IP compliance culture by which it is intended to guide the actions of all its members in the performance of their duties and in their commercial and/or professional relations.
- GENERAL RELATIONSHIP AND CONTRACTING POLICY CONCERNING CLIENTS, COLLABORATORS AND/OR SUPPLIERS
The purpose of this Policy is to establish the behavior guidelines or models that complement the General Code of Conduct for the members of PONS IP to interact and/or contract with:
- o Clients;
- o Collaborators and/or suppliers;
- o Public Administration, Public Entities, authorities, public officials or public administration personnel.
- GENERAL CODE OF CONDUCT FOR COLLABORATORS AND/OR SUPPLIERS
The purpose of this Code is to ensure that PONS IP's collaborator and/or supplier performs its business activity in accordance with the PONS IP General Code of Conduct. Such document specifically outlines:
- o Principles of conduct for collaborators and/or suppliers.
- o Ethical behavior and measures against bribery and corruption.
- o Safety and environment.
- o Information provided to third-parties.
- o Responsibility of collaborators and/or suppliers.
- ETHICAL CHANNEL
PONS IP has implemented an Ethical Channel and has made it available to any person related to the company so that they can report any breaches or potentially criminal conducts to the compliance body. To access this channel, we provide you with the following contact email: firstname.lastname@example.org.
- DISCIPLINARY SYSTEM
PONS IP has implemented and communicated a disciplinary system among its staff as a means of sanctioning those activities that violate PONS IP's internal procedures and regulations.
Sanctions have been determined taking into account the applicable Collective Bargaining Agreements, as well as the provisions of the ET and/or specific applicable regulations.