.A.S.A. Track - page 30

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ticular attention to
any payments
in cash
which are unusual for the
type of transaction as well as bearer
cheques or payments in currencies
different to that previously agreed.
2. Any
irregularities
should be
re-
ported
through the forums and
procedures established in this Code
of Ethics.
3. Personnel should also remain vigilant
regarding payments made to or by
third parties that are not mentioned
in corresponding contracts, as well as
those made to accounts other than
those usually used in relations with
that particular entity, company or
individual.
4. In addition, any payments to indi-
viduals, companies, entities, into
accounts
in tax havens
and any
payments made to entities in respect
of which it is not possible to
identify
the shareholder,
owner or ultimate
beneficiary should also be carefully
checked.
5. Finally, FCC Group personnel will
closely review any
extraordinary
payments
that are not provided for
in the relevant contracts or agree-
ments.
Donations and illegal payments:
Internal and external approvals:
Based on this commitment and its val-
ues of transparency and integrity, all
donations made by FCC Group require
the necessary internal and, where ap-
plicable, external authorisations.
- The FCC Group expressly
prohibits
non-contractual or illegal pay-
ments
to any person or entity, public
or private, with the intention of ob-
taining or maintaining business or any
other benefit or advantage.
- It is also
prohibited to use personal
relationships with public officials
to obtain any undue advantage.
- The FCC Group employees
may not
make, offer or receive,
either di-
rectly or indirectly,
any payment
in
kind or any other benefit that, due to
its value, nature or the circumstances
surrounding it, may reasonably alter
the course of commercial, administra-
tive or professional relations in which
they take part. Cash gifts or equiva-
lent are expressly prohibited.
- Donations permitted - require-
ments:
1.
Permitted recipients of dona-
tions:
- Under no circumstances
may any donations be made to any
political parties or to their represent-
atives, except where expressly pro-
vided for by applicable legislation.
- Moreover, donations should only
be made to those organisations
with the appropriate organisational
structure to guarantee the correct
administration of resources. Any
donation should be properly re-
corded in the Company's records.
2. As a result, any gifts and hospitality
should be
reasonable, transpar-
ent and legitimate,
and should
be received or given exclusively
in the legitimate interests of the
organisation.
3. Likewise, they should be
occasion-
al,
in order to avoid their frequency
generating suspicion on their ulti-
mate purpose.
4. Furthermore, gifts and hospitality
should be
socially acceptable,
so
that if they became public knowl-
edge it would cause embarrass-
ment to neither the recipient nor
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