Our aim is to reaffirm Repsol’s commitment to comply with regulations that prevent and combat corruption1 and fraud2 in all its forms3, along with the development of principles contained in the Code of Ethics and Business Conduct and expand compliance not only to all employees of Repsol, S.A. and of all the companies of the Repsol Group, whether directly or indirectly managed by Repsol, S.A, but also to our business partners4.
Repsol rejects all forms of corruption and fraud, public or private, and will apply a zero-tolerance approach in respect to any breach of this policy.
To prevent any of these situations, Repsol will perform all its operations in accordance with the applicable laws in all areas of activity and in all the countries in which we operate, respecting their spirit and purpose. Accordingly, Repsol will:
If employees have evidence, doubts or suspicions regarding any form of corruption or fraud or situations covered by this policy, they must immediately report them to their line manager or to Repsol's Chief Compliance Officer, who will act in accordance with the applicable regulations. Both employees and any third party may also transmit their information, doubts or concerns in this matter through the Repsol Ethics and Compliance Channel8.
Repsol will not tolerate any retaliation against anyone who in good faith asks questions or makes a report of actions that may be inconsistent with this policy and shall apply to the informants the guarantees and protections established by the applicable regulations and laws.
Employees who act contrary to this policy are subject to discipline, which could include termination as well as possible legal proceedings and penalties. Legal consequences imposed under anti-corruption laws can also have a serious impact for both employees and Repsol. Repsol reserves the right to adopt the measures it considers appropriate against any business partners who do not comply with this policy.
This policy was approved by the Board of Directors of Repsol, S. A. on December 21, 2022.
1Corruption: offering, promising, granting, receiving, requesting or accepting an unjustified benefit, for oneself or for a third party, to unduly favor another in the acquisition or sale of goods, in the contracting of goods and services or in commercial relations. It includes the public as well as the private or business sphere and also when the purpose or result of such conduct includes the non-compliance with the contractual, trust or legal duties of the person being corrupted or to be corrupted.
2Fraud: unlawful conduct involving intentional misleading or concealment that subtracts value from an organization or company, including obtaining or attempting to obtain some direct or indirect benefit for oneself or for Repsol, whether financial or not, to the prejudice of the interests of a third party. Especially with respect to consumers, social security and public subsidies or aid from public authorities, including the European Union.
3Other forms of corruption: extortion, bribery and influence peddling, among others.
4Business partners: partners, contractors, suppliers, agents, distributors, non-operated joint ventures and other collaborators.
5Authorities or public officials: Any person who works in the service of a public organization or institution, as well as those who are involved in the exercise of public functions.
6Valuables: cash or cash equivalent, remuneration, gifts, loans, gratuities, advantages or benefits of any kind.
7Facilitation payment: small payments made to lower-ranking public authorities or officials to expedite or facilitate the performance of their responsibilities, such as access to public services, obtaining ordinary licenses or business permits, administrative procedures, providing police protection, or loading and/or unloading of goods
8The Ethics and Compliance Channel allows you to make inquiries and report possible breaches of the Code of Ethics and Conduct in a confidential manner and without fear of retaliation. It is managed by an independent company and is available 24 hours a day, 7 days a week, by telephone and/or through the corporate website (www.repsol.com).
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