IDP GROUP GLOBAL CODE OF CONDUCT
1 CHAIRMAN’S LETTER
Ethical values have always been a central part of the strategy and development of the IDP Engineering Group.
In the current context, it is more essential than ever to act responsibly and ethically in all our activities towards all our relationship groups.
The IDP Code of Conduct defines the values of our organization, which must be a reference in all our actions, both individual and collective.
IDP currently works in more than 30 countries, we are a network in which each plays a specific role that makes a difference for our customers, our teams and our diverse stakeholders. We have a responsibility to understand why we do the things we do, through our purpose; what we focus on, through our strategy; and how we work guided by our values, behaviors and behavior.
With this Code and the organisational structure behind it, we give you the right tools to ensure that IDP continues to be a reference in the engineering sector, for the quality of its projects, for the professionalism of its teams, and for its commitment to the people and societies that welcome us.
It’s in your hands.
2 INTRODUCTION: OUR MISSION, VISION AND VALUES
IDP is part of a Group with global presence that considers the fulfilment of its obligations to be of particular importance, committing itself to observe the provisions of this Code of Conduct.
Our Code of Conduct consolidates our values and provides us with general principles against which we must assess our behaviour and future actions. This document has been designed to establish guidelines for the behaviour of all IDP members. In it we show our firm commitment to do things the right way, pretending to be a tool to help us make better decisions for our organization.
IDP’s mission, vision and values as strategic keys constitute an embodiment of the entity’s origins, object and basic purposes. These three values constitute the reference axis for the entire organization and the key to our management model.
- Mission: To offer our clients maximum satisfaction in the development of their vital and professional infrastructure projects.
- Vision: To advance in the leadership position as global and multidisciplinary engineering, providing efficient and innovative solutions in an international market.
- Values: At IDP we have clear values in which the person is the main and fundamental axis to offer the best effort, dedication and commitment to quality that makes possible the existence of our company. With a clear vocation and customer orientation, our values provide the best guarantee of consolidation in the Spanish domestic market and in our foreign subsidiaries. Some of our values could be summarized as follows:
- Trust: We treat people justly. We trust our partners and are trustworthy in everything we do.
- Innovation and continuous development.
- Fair competition: IDP is committed to respecting free markets and fair competition. All employees are required to comply with competition law. Failure to comply may result in fines or penalties. Infringement of competition law may also result in the nullity of the relevant agreement and cause significant and permanent damage to IDP’s assets and reputation. Employees should ensure that they do not receive or provide any information that could infer the behavior of IDP or its competitors in the marketplace now or in the future.
- Expert and multidisciplinary teams: Our company has a large multidisciplinary team and highly trained to lead each and every one of the areas of a project.
- Technological Differentiation: IDP is committed to innovation and technological development. This allows it to constantly invest in R+D+I and stand out in the market for its capacity and efficiency.
- Equal Opportunities: IDP is committed to ensuring diversity and equal opportunities. No one shall be discriminated against on the basis of sex, age, disability, nationality, ethnic origin, religion or worldview and sexual orientation. All employees are expected to interact with each other in accordance with the principles of mutual respect, recognizing the right to privacy and dignity. No discrimination, harassment or insults are tolerated.
- Integrity: We act with the utmost honesty, ethics and integrity in everything we do. For us, compliance with all laws and regulations has absolute priority in the IDP Group. All employees must observe the legal obligations applicable to their area of work. This shall apply to the laws of all jurisdictions within the framework of which the employee performs his or her work. All employees are therefore responsible for familiarizing themselves with and complying with the laws and regulations in their area. IDP will make every effort to assist its employees and provide them with appropriate information and/or training.
- Corporate Social Responsibility: For IDP, social responsibility is paramount as part of business activities. This is why part of this commitment is found in the company’s participation in the “United Nations Global Compact” initiative.
- Environmental responsibility: One of IDP’s top priorities is the protection of human life and the environment and we act according to our convictions. We set aside personal interest when necessary to protect these values. We do and say what we think is right and participate in them constructively. We are responsible for the environment and strive to improve life wherever we operate, aiming for a healthy, safe and sustainable environment. We take into account the needs of present and future generations as part of a whole.
- We are open to change and new ideas. We are receptive, frank and promote the free sharing of knowledge regardless of barriers or frontiers.
- Occupational Health and Safety: At IDP each employee has a responsibility to protect his or her co-workers and the environment in his or her work environment. All laws, regulations, directives and policies on environmental protection and safety at work must be complied with. Each person in charge must instruct, support and supervise his or her team in this regard.
- IDP Image Reputation: IDP’s image is largely determined by the conduct and behavior of its employees. Therefore, all employees, in the exercise of their duties, are required to be mindful of the effects of their actions on IDP’s reputation. When expressing opinions in public, employees should avoid referring to their position within the company.
3 GLOBAL SCOPE
This Code of Conduct is governed by the basic principles of the IDP Group Policy, so that the fundamental principles are adhered to by all employees of IDP Group companies when working for IDP.
This Code of Conduct will apply to all IDP Group companies globally. The Group’s subsidiaries may supplement the Code of Conduct by including more specific provisions for the regulations applicable to each jurisdiction, provided that such additional provisions are consistent with the principles set out in this document.
Each subsidiary shall ensure that all of its business units for which it is responsible also meet the requirements of this Code. To the extent that national legislation contains provisions stricter than the principles set out in this Code, priority shall be given to its application.
This Code of Conduct will apply to all employees of the IDP Group companies, including the members of the Board of Directors of the parent company and the other Business Directors of each division, as well as their corporate committees.
No violation of this Code of Conduct will be tolerated and, in particular, particularly strict rules will apply to the evaluation of the conduct of the members of the Board of Directors and the other Business Directors.
4 OUR COMMITMENT
In the spirit of social responsibility, IDP has set improvement objectives identified by areas to make them more operational, and a series of improvement measures or actions have been introduced to ensure full compliance with and satisfaction of the milestones set.
Thus, there has been an express emphasis on: corporate culture and policy, impact within the sector, communication, image, gender representation, human resources management processes, remuneration policy and structure, working conditions, family reconciliation and prevention of harassment and discrimination.
For this reason, this Code of Conduct includes a procedure that facilitates the identification of the actions that can be complied with, action to guarantee compliance, confidentiality, transparency, objectivity, impartiality and respect for the privacy and dignity of personnel.
We would like to mention in this document the launch of the People Management Plan that has been launched this year 2017 in our company. With this management plan, IDP wants to lead the engineering sector by carrying out innovative actions that help the organisation and management of the human resources area, improve the working conditions of the workers by betting on conciliation and flexibility, training and growth of our employees both personally and professionally, emphasising health and healthy habits and creating a remuneration policy appropriate to the labour market and centred on internal promotion.
4.1 Commitment of IDP Group Managers
The Directors of the IDP Group undertake to provide all the means necessary to disseminate, promote and encourage the company’s principles and values. Each member of the organization must maintain an exemplary attitude, marking a high level of exigency in compliance with the Code of Conduct. Specifically, the Directors undertake to:
- Train and make all employees aware of the importance of ethical behaviour and regulatory compliance.
- Provide all the means necessary to disseminate the company’s values and enforce the guidelines of the Code of Conduct.
- To carry out all the necessary actions to comply with current legislation in order to achieve maximum respect for the law.
- Prevent unethical behaviour and ensure compliance with the law.
- To react appropriately to cases of non-compliance with the Code of Conduct.
It is also an essential policy of our company to promote and foster a positive work climate and that all employees are treated with fairness, equity, respect and dignity. It is essential to lead a participative management style in which communication, initiative and teamwork are promoted. The principles underpinning our corporate policy can be summarised as follows:
- Non-discrimination policies
- Diversity and Inclusion Policies
- Harassment prevention policies
- Policies prohibiting moral harassment
- Advocacy policies based on merit and capacity
- Work-life balance policies
4.2 Conflict of interest and second activities
A conflict of interest arises when our personal interests directly or indirectly interfere with the interests of the company, i.e. when our own interests are contrary to or collide with the interests of the organization. They may also arise when they interfere with the performance of our duty and professional responsibility or even involve us in a personal capacity in some operation or decision of the company.
For this reason, all IDP members should refrain from representing Group entities or wanting to intervene or influence decision-making in any situation in which we have a personal interest. All members of the organisation need to be aware that a potential conflict of interest also exists when this conflict belongs to a family member or friend.
It is especially important to IDP that its employees are not involved in professional situations that represent a conflict of interest or affect their duty of loyalty. All employees have an obligation to immediately notify their manager of any potential conflict between the interests of the company and particular interests. There may be a conflict of interest when an employee:
- I acted on behalf of an IDP competitor
- Develop an external activity
- Have an economic interest in another company
- Formalize transactions linked to IDP.
With respect to the possible conflict by second activity is understood in the development of another professional activity which include, but are not limited to, the following:
- Member of the Board of Directors, Director or Manager,
- Member of the Advisory Board or Management Committee,
- Common employee,
- Any other position in a company outside the IDP Group.
Employees must have authorization from the HR Department (firstname.lastname@example.org) prior to initiating a second activity with either an IDP customer or supplier or any other company with which the employee has come into contact in the course of his or her professional activity for IDP. The Human Resources Department must obtain the consent of its manager before issuing such authorization.
As a member of the Global Compact, IDP is dedicated to combating all forms of corruption worldwide. Corruption is prohibited by international conventions and national regulations. Statutory prohibitions apply not only to actions between companies, but also to contacts with politicians or public officials. Violations are punishable by fines and can cause irreparable and permanent damage to IDP’s assets and reputation.
IDP representatives, in the context of a business relationship, shall refrain from seeking or accepting any compensation for their own benefit or for the benefit of a third party in exchange for making an unfair decision in the procurement of goods or services.
4.4 Commitment to third parties
When acting with third parties as members of the IDP Group, we must be aware that we are representing the organisation and therefore we must ensure that the behaviour is in line with the image and values of the project.
4.4.1 Public Administration
In relations with the public administration, all members of IDP are committed to complying faithfully with both current and internal regulations of the organization. In this regard, we adhere to the principle of transparency and relations with institutional representatives will be carried out through IDP representatives appointed for this purpose, accounting for the outcome of meetings and business that are carried out. Any request made by the authorities and security forces must be requested in writing.
Relations with IDP suppliers are based on the principles of loyalty, transparency and reciprocal collaboration, selecting them according to the suitability of their services, as well as economic conditions and quality. Gifts or commissions in cash or in kind that may alter the laws of free competition in the production of services or goods will not be accepted in any case.
In the event that any IDP provider engages in behavior that is not in compliance with this Code of Conduct, IDP is free to take appropriate action and, if deemed appropriate, to reject future collaborations with this provider.
At IDP we are committed to complying with the rules on free competition, avoiding any practice that limits or restricts it. The members of the organization must ensure that they provide truthful information in promotional activities and do not offer information to our customers that could lead to error. Thus, from IDP it is rejected emphatically:
- Offering, soliciting or accepting an unjustified advantage of any kind in commercial relations.
- Accept any income from illegal activities or activities that could be subject to money laundering.
4.5 Acceptance of compensations
In relations with business partners and competitors, as well as governments and public bodies, employees may only accept and offer compensation or gifts provided that the acceptance or granting of these benefits does not create the impression of influencing the decision-making process, intentionally or unintentionally. Business partners are, for example, customers, suppliers and service providers, as well as third parties with whom IDP seeks to establish business relationships. Compensation may include, for example, gifts, hospitality, invitations to events, payment of travel expenses and services that exceed normal business practices, it being irrelevant whether they are granted directly or indirectly (e.g. direct family members or to associations or organisations closely linked to them).
The acceptance in the relations with commercial partners and competitors, as well as Administrations and public organisms will have to be carried out according to the principles that are exposed. In case of doubt, the employee must obtain the approval of his/her supervisor or the relevant Business Director before accepting or awarding compensation. Even if compensation is in accordance with this Code of Conduct, it may result in tax obligations for both IDP and the employee.
This point contains particularly strict rules on the granting of compensation to public officials. Public officials are considered to be, for example, senior ministerial officials, secretaries of state, ministers, mayors, civil servants of the administration and of economic-financial organizations, and municipal administration personnel. Senior managers (e.g. CEOs) of companies in which there is a majority participation of the State or private persons performing public administration functions may also be considered as public officials.
Exceptionally, compensation of high economic value may be authorized in countries where such gifts are a local custom and courtesy. In each case, the approval of the corresponding supervisor, Business Director or Board of Directors in the country unit will be required.
4.6 Selection of suppliers and subcontractors
The selection of suppliers and subcontractors will follow a pre-established procedure and will be based on objective and comprehensible criteria. Any employee who is involved in the selection of suppliers and subcontractors and who has a personal interest that may influence the selection process should inform his supervisor or Business Director.
IDP is committed to recognizing its social responsibility and within the applicable legal framework manifests its willingness to support non-profit causes through donations. Non-profit causes include scientific, cultural, social, sports and other social projects. Donations may be made in cash or in kind and will have as their sole purpose the support of those non-profit causes without expecting in exchange any compensation or behavior on the part of the beneficiary or a third party. In particular, donations may not be offered or granted to public officials for the provision of a service or to representatives of a company for the adoption of a particular decision.
Employees may not engage in any direct or indirect professional activity in companies that are direct or indirect competitors of any IDP Group company. Exceptionally, the development of such activities will be permitted with the prior electronic authorization of the Human Resources Department (email@example.com) advised by its direct division manager.
4.9 Information processing
4.9.1 Records and reports
Accuracy and rigour are essential and indispensable criteria that must be followed in order to achieve a successful business. We all have a duty to ensure that our records, financial or otherwise, follow the guidelines of rigour and accuracy.
IDP is committed to providing accurate and truthful information to the Group’s committees, investors, employees and business partners. All records must comply with legal provisions. In accordance with accounting information principles, recorded data and archived information must always be complete, correct, timely and compatible with the system.
In this matter it is necessary:
- Retain records securely and follow marked guidelines.
- Cooperate with IDP auditors (internal or external)
- Reject any cash transaction. If no other means of payment is possible, they must be authorized, recorded and documented.
Employees shall not be permitted to disclose confidential business information or business secrets (financial data, strategic plans, planned operations) to unauthorized persons, either in the course of the professional activity or after the professional activity has ended.
4.9.3 Data protection
All employees must comply with data protection rules and regulations and, in particular, must actively cooperate to ensure that personal data is adequately protected against unauthorised access. In case of doubt or when any infraction is detected, the IDP Group’s Data Protection Officer should be informed via email at firstname.lastname@example.org
The objective of IDP is to establish effective systems for monitoring and evaluating the objectives set out in the Code of Conduct, as well as to ensure the timely fulfilment of established principles and policies.
Responsibility within the IDP Group for the application of this Code of Conduct rests with those responsible for each Area (Business Managers). They will also be responsible for periodically checking the level of compliance and updating the Code of Conduct.
The Area in which the infraction has been committed has the operational responsibility to investigate, evaluate, sanction and put an end to the infractions.
IDP appoints the Business Managers of each area who will have the necessary powers to develop aspects related to the guiding principles of the Code of Conduct and, specifically, to:
- To be the interlocutor and intermediary between IDP and the workers.
- Ensuring compliance and enforcing established policies and measures
- Participate in the design and implementation of applicable measures
- Participate in the design and implementation of training measures
- Channel any cases of harassment and discrimination to the Human Resources Department.
- Monitor indicators to ensure compliance
5.2 Interpretation and operation
The Code of Conduct describes only the general principles of legal and ethical conduct. In the event that problems of interpretation or doubts arise regarding the application of the Code, employees should channel them through their Supervisor or General Manager of each area. The latter will also act as an adviser on all matters relating to this matter, dealing with any questions that may arise in the strictest confidence.
Employees may report breaches of the Code of Conduct by any IDP Group company to the HR manager at email@example.com in Spain. No disciplinary action will be taken against an employee who reports a violation of this Code of Conduct. The foregoing provision shall also apply, even if the information provided is incorrect, provided that such information was provided in good faith.
Failure to comply with the rules of this Code of Conduct may result in disciplinary action or sanctions under labor laws, including dismissal and other legal sanctions.
6 GLOBAL COMPACT
For IDP and the effective development of the Code of Conduct it is essential to collaborate, promote and encourage social responsibility as part of business activities. This is why part of this commitment is found in the company’s participation in the “United Nations Global Compact” initiative. The initiative is based on ten fundamental principles aimed at achieving a more social and ecologically beneficial globalization and preventing corruption.
For the purposes of the fight against terrorism, the prohibition of the direct and indirect provision of funds and economic resources to certain individuals, legal persons, groups, groups and organisations has been introduced by the European Union Regulation (EC) No 881/2002 and (EC) No 2580/2001, as amended, which apply directly in all Member States of the European Community.
IDP seeks to improve day by day its processes, its relationships with suppliers and customers, checking its business partners and employees as to whether their name and identity exist in the lists of persons, legal entities, groups or organizations that they publish as annexes to the Regulation.
The principles of the Global Compact are as follows:
- HUMAN RIGHTS:
- Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights within their sphere of influence.
- Principle 2: Businesses should ensure that they are not complicit in human rights violations.
- Principle 3: Businesses should support freedom of association and the effective recognition of the right to collective bargaining.
- Principle 4: Businesses should support the elimination of all forms of forced labour carried out under duress.
- Principle 5: Businesses should support the elimination of child labour.
- Principle No 6: Businesses should support the abolition of discriminatory practices in employment and education.
- Principle 7: Businesses should maintain a precautionary approach that is environmentally friendly.
- Principle 8: Businesses should encourage initiatives that promote greater environmental responsibility.
- Principle No 9: Businesses should encourage the development and diffusion of environmentally friendly technologies.
- CORRUPTION AND BRIBERY.
- Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.