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the donor. The Company interprets
that the maximum value of gifts
and hospitality should be no greater
than 100 Euros, an amount that
may be periodically reviewed by the
Compliance Office.
- Monitoring of donations:
1. Likewise, and to the extent pos-
sible, the FCC Group will monitor
donations made to ensure that
they are used in the best possible
manner.
2. Employees should ensure that any
gifts which have an estimated value
over 50 Euros shall be monitored
and recorded appropriately by the
company that provided the service.
3. Any gifts received by FCC Group
employees that have a value higher
than the aforesaid amount shall
remain property of the Company,
and it shall be the responsibility of
the Director General of the relevant
area to decide whether to accept or
return the gift.
- Invitations:
Additionally, any invita-
tions sent to foreign officials must be
authorised by the General Manager of
the relevant department.
- Compliance by third parties:
In
cases where the FCC Group obtains
services from third parties for the
commercial development of the Com-
pany in other countries, these third
party entities must formally accept the
commitments to good conduct set out
in this FCC Code of Ethics, especially
with regard to relationships with public
officials and administrations.
- Doubts of interpretation:
In the
event of any doubt with regard to
what is acceptable practice in this
area, employees should contact the
Compliance Office.
Information: confidentiality
and truthfulness
•
Manipulation of information:
- The forgery, handling or deliberate use
of false information constitutes
fraud
.
- The FCC Group treats
transparency
of information as a principle of con-
duct, interpreted as the commitment
to providing the markets and society
as a whole with reliable information
that fairly represents the Group’s ac-
tivities, strategy and its financial, so-
cial and environmental performance.
- All employees must communicate
such information in a full,
accurate
and comprehensive manner. Under no
circumstances, should any employee
knowingly provide incorrect or im-
precise information that could lead to
errors on the part of the recipient.
- All employees of the FCC Group must
ensure that none of their activities
could be construed as an attempt to
alter the perception
of the Company
by third parties. In any case, only
authorised spokespeople of the Group
may comment publicly on activities or
results.
•
Financial information
- All employees shall
record
the
Group´s transactions, incidents and
occurrences in the organisation´s
records clearly and accurately and
shall be especially careful as to the
reliability of financial information en-
tered into the systems of the Company
and its subsidiaries, which will reflect,
on the relevant date, the rights and
obligations to comply with applicable
regulations.
- In the event that employees of the
organisation observe circumstances
that, according to the best of their
knowledge and understanding, con-
stitute a
breach of the principles
