The main elements of this system are:
Prevention of crimes that could have criminal consequences for the company. Regulates financial resource management policies and the whistleblower channel.For the management of financial resources, our crime prevention model provides for the control and supervision of each of the internal protocols or policies created and implemented by Tema.
As an alert system that allows us to identify and report irregularities, bad practices or mismanagement by the company, we have a whistleblower channel.
It regulates compliance with environmental protection and care regulations. We have an internal paper management policy within the specific scope of personal data protection, in order to avoid any type of improper disclosure of personal information.
In addition, as part of our corporate identity and culture, we demonstrate our commitment to continuous improvement, customer satisfaction and environmental protection with our integrated management systems based on ISO 9001 and ISO 14001 standards.
The quality and environmental policies are available for consultation. It is only necessary to send the corresponding request to tema@grupo-tema.comspecifying the policy about which information is required, and from which company or country.
These include anti-fraud and anti-corruption policieson anti-fraud and anti-corruption, grants and donations control, intellectual property, procurement, expenses and contracting, confidentiality commitments, and the Code of Conduct, as well as the Declaration of Compliance with the requirements of independence and impartiality.
This documentation is available for consultation upon request by email at tema@grupo-tema.com, indicating the policy of interest and the company or country to which the requested information relates.
Independence and Impartiality Policy
This policy sets out the principles and commitments adopted by the organization to ensure independence, impartiality, integrity, and objectivity in the performance of its activities.
Declaration of Compliance with Independence and Impartiality Requirements
This declaration reflects our commitment to carrying out our activities and services independently, ensuring at all times the objectivity, integrity, and technical rigor of our work. We do not accept any external influence that could compromise the quality, accuracy, or impartiality of the results obtained.
Anti-Fraud and Anti-Corruption Policy
This policy applies to any act of fraud, suspected fraud, attempted fraud, or corrupt practice committed against Tema, whether by its employees, managers, members of the Board of Directors, clients, external collaborators, contractors, suppliers of goods and services, affiliated entities, or any other parties.
To this end, we have implemented a set of measures aimed at preventing and avoiding the commission of offences related to fraud, deception, and corruption, regardless of whether corporate criminal liability may apply to such offences.
Grants and donations control policy applies to the receipt and granting of cash or product donations that may be given to Tema, as well as to the receipt of grants. Identification rules and obligations are established for the receipt of grants and donations, which help to avoid or minimize risks of other possible crimes related to the misappropriation of funds, donations and/or grants that may harbor a conflict of interest.
Intellectual property policy addressed to all staff, trainees and third parties with access to the company’s information, given that intellectual property is a priceless asset, which we protect and respect internally and externally.
They include copyrights, reproduction or designs, trademarks, inventions, trade secrets, rights over knowledge and their transmission or reproduction.
Purchasing, expenses and contracting policy regulates purchases, expenses and contracting in which the persons linked to the company incur for the performance of their professional activity.
Commitment to confidentiality All our staff is committed to maintain absolute confidentiality about the facts and data obtained, both in the scope of any consultation, document, as in the scope of a complaint, to any person outside the procedure, unless the disclosure of such information is required by law, labor or judicial authority.
Code of Conduct regulates compliance with the company’s ethical standards and legal codes at its different sites or branches. It contains the rules, procedures, protocols that will affect all departments.
The Compliance Committee is an autonomous and independent body composed of three compliance officers that meets every six months to perform the functions of their position.
Regulates corporate tax behavior and prevents crimes and their consequent legal sanctions. Regulates tax decision-making policy.
Tax decision making policyensures compliance with applicable tax regulations and seeks adequate coordination of tax policy within the framework of achieving the social interest and supporting the long-term business strategy by avoiding tax risks and inefficiencies in the execution of business decisions.
Establishes the assessment and prevention of risks, vulnerabilities and virtual attacks. Applies control and compliance measures for the protection of sensitive digital information and includes the ICT policy.
ICT policyreferring to the tools made available to personnel for the development of their work activities, with the aim of creating a corporate culture of action in accordance with the law and thus avoiding any type of criminal conduct that may occur in relation to such means.It previously establishes the rules for the use of work tools and defines a system for the use and control of all the information technologies used by the members of the company.
Policy on the use of AIthat regulates the use of artificial intelligence in a secure environment, ensuring the protection of personal and sensitive data, as well as the confidentiality of third-party information. It also considers the professional supervision of the rigorousness of the results processed with these tools.
Comprehensive fraud prevention and protection of Tema’s multiple financial and tax procedures. It includes the money laundering prevention policy.
Money laundering policyrelated to the introduction into the market of money or goods from illegal activities as if they were legal tender. Tema has the firm intention of adopting measures to avoid the risk of incurring in a criminal offense, even if it is due to imprudence.
