Ethical code

Rabat group is aware of the need to attend our social responsibilities with our collaborators, clients, and suppliers. We have the firm intention to work for the excellence of our organization and its relations with all operators in general.

The willingness to the service, the efficient and proactive actions, focused on excellence, it is the base for the professional responsibility of everyone, based on integrity and individual corporate responsibility.

For this reason, we generated an ethical code that aims to guide behaviour for all those who are within the scope of our organization, with the purpose of reflecting our alignment with the culture of compliance.

We work from all ends of the organization to detect, suppress, and prevent situations against our rules, including the criminal ones, therefore presiding over our actions, and ethical and honest behaviour above any other value.

Our ethical code governs the actions and the relationships of partners, administrators, managers, employees, employees, in general for all the staff related for one reason or other to RABAT Group.

We are also committed to transferring the ethical code guidelines that govern our organization to all those who interact with us in one way or another.

Always and during all the time, our behaviours have to be completed, responsible and suitable to the basic rights and to the strict regulation accomplishment, whether we are part of the RABAT Group, or all those who act within its scope, especially suppliers and external collaborators.

1. Respect to the human rights

   In RABAT Group, we firmly believe what we are committed to theintegral respect to the human rights and public freedoms, basic ethical practices, included in the Universal Declaration of Human Rights, adopted and proclaimed by the General Assembly of the United Nations on December 10, 1948, Convention for the protection of Human Rights and Fundamental freedoms (Council of Europe, Rome, on November 4, 1950) and the Tripartite Declaration of the Internal Labour Organization (ILO).

   We are committed to do not collaborate with third parties in the violation of any Human Rights norm, nor to participate in any action that compromises respect for the principle of legality.

2. Respect of the essential rules

   In our actions we are committed to always comply with current legislation and adopt internal policies to avoid any non-compliance. We also pay special attention to strict compliance with any non-compliance.

   We also pay special attention to strict compliance with:

   1. The general provisions (laws, regulations, circulars from regulatory andsupervisory bodies) that regulate the activity of the RABAT Group in any country.
   2. The regulations, standards, protocols, and internal procedures that RABAT Group has implemented, and especially the present ethical code.
   3. The ethical principles and rules that apply to them, as well as the customs and good practices of the countries in which they carry out their activity.
   4. The obligations and commitments assumed by RABAT Group in its contractual relationships with third parties.
   5. The rules contained in the Spanish penal code, and particularly those that affect the legal entity in accordance with its article 31 bis.

1. Respect to the human rights of people

   We work to offer an environment of professional respect, mutual collaboration and promotion of equity that governs our relationships, and therefore we work to promote non-discrimination and non-violence among all those who are within the scope of the organization and even with third parties.

   1. Respect and professional development

      At RABAT GROUP we are committed to training as a way of professional promotion. Equal opportunities, respect for diversity and equality are pillars of our professional relationships with our collaborators.

   2. Security and health at work

      We care about implementing health and safety policies at work, basic for the professional development of all members of RABAT GROUP.

   3. Intimacy

      Personal data and people's privacy are one of the main concerns of RABAT GROUP. We follow the appropriate protocols to protect said privacy and we work daily to improve our system and train the members of our organization for its protection.

2. Respect to Heritage, property, market, and free competition
   1. General, heritage, fraud, property, and executions.

      We are committed to protecting and respecting intellectual and industrial property, and to apply policies aimed at promoting free competition and the market; to ensure the rights of consumers, to protect private property as well as to facilitate compliance with administrative and judicial resolutions.

   2. The market, the publicity and advertising, the consumers and the fee competence

      We consider our suppliers and collaborators essential to achieving our objectives of growth and improvement of the quality of service, and excellence in our activities. Our goal is to establish relationships based on trust and mutual benefit and to this end we promote compliance with contractual conditions and obligations between the parties. Also ensuring independence in contracting, as well as truthfulness in advertising of products and services, to promote ethics in our relationships, we ask our suppliers to subscribe to this Code.

3. General interests, taxation, social security, money laundering and means of payment
   1. Taxation and social security

      RABAT GROUP is committed to society through, among others, its sustainable development, contributing to the maintenance of the social state, which is why we ensure the payment of our tax and social security obligations, providing the public administration with real information, both financial, such as fiscal, as well as that related to the field of social security. Likewise, we allocate the resources as well as the subsidies to the purpose for which they were assigned.

   2. Money laundering and means of payment.

      In the fight against money laundering, we have implemented strict protocols consisting of limiting cash payments and collections, the identification of whoever contracts with Rabat Group, the accreditation of the ownership of bank accounts, the assurance of the identity of buyer-seller or client-supplier as issuer or receiver of the invoice, as well as the pertinent communication to Sepblack of those suspicious operations.

4. Public security
   1. Environment

      Our commitment to the environment is the maximum expression of respect for the future of our future generations, which is why we implement the environmental management policies and systems appropriate to our activity.

   2. Public health and drugs traffic

      We are concerned about avoiding any activity that compromises people's health in its broadest sense. We ensure the non-realization of tasks under the influence of alcohol or other legal or illegal substances that could affect the level of safety for the activity carried out.

5. Against the ethics, the transparency, corruption, conflicts of interests, financing of political parties, bribery, and traffic of influence
   1. Transparency

      It is a principle of Rabat Group to properly transmit the real image of the company, of its activities in the broadest sense. The information received from RABAT GROUP by third parties, whether public or private natural or legal persons, will always be complete, truthful, and understandable, and in no case mislead. Manipulation, falsification, or fraud in said information is absolutely forbidden.

   2. Corruption and bribery, and traffic of influence

      Contrary to influencing the will of people, whether natural or legal, to obtain any type of benefit, through practices that deviate from business ethics, we do not give, receive, offer, or accept, directly or indirectly, gifts, or compensation of any kind. who are prone to improperly obtain any type of advantage or favourable or privileged conditions outside of what involve mere acts of courtesy and in any case under the supervision of the person responsible for compliance.

   3. Conflict of interests

      When the interests of RABAT GROUP and any of those affected by this code collide directly or indirectly, whether due to professional, personal, family or any other type of interest, they will not intervene in the decision-making on the subject.

   4. Financing of political parties

      We undertake not to make donations or contributions to political parties, state or foreign. Corruption with our political representatives attacks the axis of democracy and the basic ethics of relations with our institutions, which is why such activities are absolutely prohibited.

Determined to show our honourability of its internal structures and our own existence as an economic operator, we provide ourselves with an internal framework of conduct.

1. The conflicts of internal interests

   The extreme rigor in the processing of personal data related to clients is one of the maximum commitments of RABAT GROUP, which will only be justified by legal relations. We avoid collisions of private interests with those of RABAT GROUP, especially if this affects decision-making. We extend the decision not to receive gifts directly or indirectly, whether they are in any format that is not considered mere courtesy.

2. The privileged information and confidentiality

   Confidentiality as part of the contractual good faith in RABAT GROUPS’ relations with its environment, implies the maintenance of professional secrecy, of the information available, whether commercial, economic, and strategic, use or utilization of operational processes, information systems. Work and any other internal procedure that affects people, companies, clients-suppliers and that all those who act in our area are committed to preserving.

3. The protection of assets

   We facilitate and make good use, in accordance with the laws, of all the resources and means necessary for the development of RABAT GROUPS’ professional activities and always for the benefit and in accordance with the business objective.

4. The use of Brand and image of RABAT GROUP

   The use of the image and brand of RABAT GRUOP must always be done respecting the good image of the Group, as well as the content of this code of ethics.

5. Relationships with clients and suppliers

   The treatment with the client or supplier must always be exquisite but not ostentatious or exaggerated, nor will it be acted in an arrogant manner or in any discriminatory way.

   The internal regulations of RABAT GROUP guarantee, in relation to the contracting and selection of suppliers, transparency, equal treatment and maximum objectivity, as well as regulatory compliance and subscription to this ethical code.

   The extreme rigour in the treatment of personal data related to clients is one of the RABAT GROUP's maximum commitments, which will only be justified by legal relations.

6. Relationships with partners

   We provide maximum information with absolute objectivity and transparency to our partners, for proper decision-making and direction. Likewise, it is from the members' meeting itself that the organization is committed to disseminate this code as the central axis of good practices and business ethics.

All of us affected by this code must comply with and disseminate its rules and principles; comply with the regulatory framework of laws, regulations, ordinances and standards in general that affect their specific activity; advise us properly and ask for advice regarding regulatory compliance and this code; participate in training activities; inform through the appropriate channels of any possible regulatory non-compliance or conduct included in this Code; participate in the controls carried out to identify and correct deficiencies or failures in the detection of regulatory risks or malpractices of all kinds.

The administrative and management bodies of RABAT GROUP must set an example with their own behaviour of the maximum integrity and honourability that is required of them as reference persons for others affected by this code; transmit the culture of regulatory compliance and honesty in all its actions; support knowledge of good practices, business ethics and social responsibility, as well as ensure that all people affected by this code properly understand its content and comply with and enforce its rules and contents.

Infractions, non-compliance, violations of the ethical code by any of those affected may result in the imposition of sanctions with adoption, if appropriate, of the corresponding legal actions, all in accordance with the CODE OF CONDUCT AND SANCTIONING PROCEDURE of RABAT GROUP, all this without Damage to criminal responsibilities that are legally enforceable.

commissionThe functions of the Code of Ethics's supervisor are assumed directly by the members of the compliance committee, who are indistinctly the consulting persons who must ensure the dissemination, knowledge and compliance of the Code of Ethics; as well as interpret and facilitate the resolution of conflicts that arise over its content.

approvalThe Code of Ethics comes into force on the day of its publication and its validity will be indefinite; its reviews and updates will be periodic and approved by the administrative body at the proposal of the compliance committee.

The complete text of this code of ethics was unanimously approved by the Board of Directors of GRUP FLASH RABAT S.L. on December 15th 2016..

Through the following link you can access the RABAT Group's ethical communications mailbox in accordance with Law 10/2010 on the prevention of money laundering, EU Directive 2019/1937 on the protection of whistleblowers, and the RABAT Group's compliance system. Access to the mailbox >