ANTI-CORRUPTION, ANTI-BRIBERY AND CRIME PREVENTION POLICY

LEZAMA DEMOLICIONES, S.L.U. in its firm commitment to ensure free market competition and ethical values, which this organization defends, extends this policy to all managers and employees of this company, effective in all areas of activity.

  1. Our company will never use bribery as a means of obtaining advantages in the contracting of works, services, permits, licences or authorisations, whether administrative or private.
  2. Gifts, favours or invitations that are likely to involve any obligation on the part of the recipient are prohibited.
  3. Facilitation Payments, also called ‘Accelerators’ or ‘Oilers’, which typically help to obtain priority over third parties, are prohibited.
  4. LEZAMA DEMOLICIONES, S.L.U. will always be Neutral in its affinity to Political Parties and any financial contribution or of any other nature, either directly or indirectly, with the aim of obtaining commercial advantages, is forbidden.
  5. LEZAMA DEMOLICIONES, S.L.U. expressly prohibits any type of Offer or Acceptance of Gifts, Hospitality or Expenses whenever such gifts may affect the result of a commercial transaction and are not reasonable or bona fide expenses.
  6. All types of charitable contributions or sponsorships are prohibited if they are used as a subterfuge to obtain advantages in the award of administrative or private contracts.
  7. All Lezama employees are able to use a REPORTS CHANNEL, via e-mail: juanjo@lezama.es, for any queries or complaints they may wish to make. Such reports may be anonymous or confidential. Lezama is committed to investigating the facts and taking the necessary measures to prevent crime.

LEZAMA DEMOLICIONES, S.L.U.

Commits to:

  • The drafting of a Code of Conduct and a Compliance Manual, accessible to any employee, where the information and scope of this document can be completed.
  • The appointment of a Compliance Officer.
  • The disclosure of this policy to all Stakeholders.
  • Training all staff on the risks involved in our activity.
  • The establishment of direct reporting mechanisms to the highest level of management.
  • Periodically monitor these aspects.
  • Apply appropriate sanctions for violation of any point of this policy.

Jose Fernández Gil
Managment
Bilbao, April 2018