EXCELTIC S.L., within their Organisations, are governed by a Criminal and Anti-Bribery Compliance Management System, which aims, on the one hand, to create a culture aligned with compliance with the rules governing our society and to prevent, within our internal and external activity, any action that violates the law in the field of our business. To this end, EXCELTIC, with the commitment at the highest level from its Governing Bodies, has created a Compliance Committee to ensure compliance with the Criminal and Anti-Bribery Compliance Management System, acting in any risk situation and in a preventive manner, updating and reviewing its Policies and Procedures on an ongoing basis.  

The culture of compliance is based on fundamental principles that every member of any of our companies must adopt in order to work at EXCELTIC: ability to serve our clients and collaborators, integrated conduct at work inside and outside the organisation, adoption of commitments based on loyalty and confidentiality of information to generate a climate of trust and respect, promotion of the excellence of our professionals through training and talent.  

Our shareholders, customers, suppliers, collaborators and employees are the direct beneficiaries of our culture of ethical values in our business activities or in any type of relationship. Compliance with our Anti-Bribery and Criminal Compliance Management System and the adoption of our principles are the ethical pillars of our organisation.  

A Code of Ethics and an Ethical Channel have been adopted as the main tools within our Criminal and Anti-Bribery Compliance Management System, which help us in our daily actions with the commitments we have acquired, as a reference framework for dealing with compliance.  

We highlight as essential values:

• Leadership of our employees and focus on our customers.
• The service vocation of those in charge of the teams.
• Adaptation to regulatory and social changes, etc.
• Responsibility in decision-making.
• Loyalty, continuous dedication over time.
• Meritocracy, supporting workers committed to leadership, loyalty and excellence.
• Encouragement of teamwork, favouring a good working environment, and respect for equality, freedoms and rights.
• Training, considering knowledge as an asset to be protected.

With regard to business conduct and the relations of our employees with customers, suppliers and society in general, the following standards and skills are regulated, prohibited and strongly encouraged through procedures and policies:

• Compliance with current legislation in all areas.
• Duty of secrecy and confidentiality.
• Rejection of corruption in business or any form of fraud or bribery.
• We regulate potential conflicts of interest.
• We encourage strict compliance with Social Security and tax obligations, collaborating in the prevention of money laundering.
• We stand for transparency in all areas, especially in the financial sector.
• We are committed to the environment and sustainability.
• We strictly monitor compliance with workers' rights and public freedoms, labour rights, equality.
• We defend the proper functioning of the market, intellectual and industrial property rights.
• Always ready to cooperate with the authorities.
• We extend our standards to our actions in the international arena.
• Respect for the human rights recognised in the framework of the United Nations Guiding Principles on Business and Human Rights, in the International Bill of Human Rights.

You can consult our Code of Ethics in the following link .

Our Compliance Committee works actively to respond to any reported problem or incident and ensures at all times the confidential management of the information provided, as well as monitoring the supervision of our Criminal and Anti-Bribery Compliance Management System, promoting improvements, reassessing risks and supervising compliance with the System.

In order to encourage interaction with all those involved, the EXCELTIC Ethics Channel has been established as a communication channel for communications or alerts, suggestions or queries in all matters related to the prevention and detection of crime in the company.

Exceltic Ethical Channel

In accordance with Directive (EU) 2019/1937, EXCELTIC SL, has a confidential channel through which both members of the Organization, as well as third parties who have a relationship with it, can report suspicions of unlawful conduct or conduct contrary to current legislation, the Code of Ethics, procedures and / or other internal rules of the organization. They can also use it as a means of communication to share doubts or questions about Exceltic's Compliance Model and the application of the Code of Ethics and other internal procedures and policies.

The Channel is a communication tool, accessible to all employees, customers, suppliers and other third parties, through which to alert or report irregularities, non-compliance and unethical and unlawful behaviour.

You can access our channel through the following link:

Ethical Channel

The communication of possible irregularities or non-compliance shall contain, as far as possible, the following points:

• Description of the allegedly irregular conduct, contrary to the law or to the provisions of the Code of Ethics.
• Possible persons involved.
• Approximate dates of commission of the acts.
• Means by which the conduct has been carried out.
• Business areas affected.
• Relevant processes affected (e.g. procurement, accounting...).
• Documents or evidence of the facts.

In any case, it is recommended that the communication be as descriptive and detailed as possible, thus making it easier for the recipient to identify the person(s) or department(s) involved. In the communication processed, the complainant/alertor must be duly identified, except in those cases in which the communications are processed as anonymous. In order to decide whether or not to admit it for processing, the complainant/alertor may be asked to clarify or complement the facts, providing such documentation or data as may be necessary to accredit the existence of the irregular conduct. When it is determined that the facts are sufficiently indicative of possible non-compliance or unlawful conduct, the corresponding internal investigation file shall be opened.

Exceltic, SL, will safeguard and protect the details of the complainant/alertor, as well as those of the alleged perpetrator in the case of a complaint and other third parties that may be involved, guaranteeing the confidentiality of this information at all times.

Exceltic guarantees the protection of those persons who use this Channel in good faith. Thus, those persons are protected who, having reasonable grounds to believe, in light of the circumstances and the information available to them at the time of the communication, that the facts they report or report are true. Whistleblowers/alertors are protected against any form of retaliation, whether direct or indirect. This protection shall not be lost even if the whistleblower or reporter reports inaccurate information due to a mistake made in good faith. Any personal motivation that the whistleblower or alerter may have in reporting shall not be taken into account in granting this protection. Persons using this channel in a malicious, frivolous or abusive manner, or deliberately and knowingly communicating incorrect or misleading information, as well as persons communicating information that is in the public domain, or unconfirmed rumours and hearsay, are therefore excluded from any protection.

Last modified: 2 March 2023