Good Governance

PONS CONSULTORES DE PROPIEDAD INDUSTRIAL, S.A AND PONS PATENTES Y MARCAS INTERNACIONAL, S.L., hereinafter PONS IP, has set up a Regulatory Compliance System or “Criminal Compliance” that complies with the requirements of article 31 bis of the Criminal Code introduced by Organic Law 1/2015, of 30 March, which amended Organic Law 10/1995, of 23 November of the Criminal Code, and came into force on 1 July 2015.

The PONS IP Criminal Compliance system, adopted by the Administrative Body, consists of the Compliance Policy Statement, in addition to the Compliance Manual, executive summary and complementary annexes.

MINUTES OF THE AGREEMENT ADOPTED BY THE ADMINISTRATIVE BODY

The PONS IP Administrative Body approved the “Compliance Policy” and the company’s crime prevention and regulatory compliance plan. In addition, it set up the compliance body responsible for monitoring the operation and observance of potential crime prevention and detection within the framework of the company’s activities, as well as for supervising and monitoring the effectiveness of internal controls for crime prevention and compliance with the ethical standards established in the company.

COMPLIANCE POLICY STATEMENT

The compliance policy outlines the general principles that inspire the content and that are applicable to all internal PONS IP rules and that affect all members and the actions they carry out.

COMPLIANCE MANUAL

Document that describes the organisation, collects and explains the PONS IP risk map, the potential criminal conduct at risk of being committed, and the surveillance and control measures implemented or to be implemented in PONS IP.

GENERAL CODE OF CONDUCT OR CODE OF ETHICS

Internal code of the company that contains the basic guidelines and general principles that must govern and be applied in the actions of PONS IP members. This Code has been conceived in such a way that it acts as a “cornerstone” of PONS IP’s culture of compliance 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 POLICY ON RELATIONSHIPS AND CONTRACTS WITH CLIENTS, COLLABORATORS AND/OR PROVIDERS

The purpose of this policy is to establish the guidelines or behavioural models that complement the General Code of Conduct for members of PONS IP to establish relationships and/or contracts with:

• Clients;
• Collaborators and/or providers;
• Public Administration, Public Entities, authorities, civil servants or public administrative personnel.

GENERAL CODE OF CONDUCT FOR COLLABORATORS AND/OR PROVIDERS

The purpose of this Code is to guarantee that the PONS IP collaborator and/or provider carries out their business activity in accordance with the PONS IP General Code of Conduct. It specifically includes:

• Conduct principles for collaborators and/or providers.
• Ethical behaviour and measures against bribery and corruption.
• Safety and environment.
• Information provided to third parties.
• Responsibility of collaborators and/or providers.

ETHICS CHANNEL

PONS IP has implemented an Ethics Channel and has made it available to anyone related to the company so that they can inform the compliance body of any non-compliance or conduct suspected of being a criminal offence. Please click on the following link to access this channel. .

SISTEMA DISCIPLINARY SYSTEM

PONS IP has implemented and made known to its personnel a disciplinary system as a means to sanction 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 Spanish Employment Contract and/or specific applicable regulations.

Last modified in November 2021.