COMMITMENT
The Management of YONDBEE SOCIAL EFFECTS S.L. is responsible for developing and implementing a Compliance Management System based on the application of appropriate policies and procedures that ensure compliance with all applicable laws and regulations.
Appointing a compliance officer does not exempt Management from its ultimate responsibility to establish an effective criminal compliance system.
The Management of YONDBEE SOCIAL EFFECTS S.L. communicates its clear commitment to criminal compliance (“”higher hierarchy, higher demand””) and complies with the requirements of this criminal compliance policy and the implemented criminal compliance management system.
YONDBEE SOCIAL EFFECTS S.L. is committed to the continuous improvement of the criminal compliance management system.
COMPLIANCE OFFICERS
The Governing Body has appointed a Compliance Officer who has a legal and economic understanding of compliance issues; they are reliable and trustworthy.
The responsibilities and tasks delegated to the Compliance Officer are well-defined and documented, which is done through an appointment letter from the Governing Body directed and endorsed by the Compliance Officer.
The Compliance Officer has sufficient resources to adequately fulfill their obligations.
The Compliance Officer works jointly with the company’s management and has full cooperation with other organizational bodies.
RISK IDENTIFICATION AND ASSESSMENT
The Criminal Compliance Management System is based on a documented process in which criminal compliance risks are identified and assessed. The identification and assessment of risks are repeated periodically or in response to a specific extraordinary event, significant change in the structure or activity of YONDBEE SOCIAL EFFECTS S.L., changes in jurisprudence, or relevant legislative changes.
DEVELOPMENT OF CORRECTIVE MEASURES
Once the risk identification and assessment process is completed, measures are developed to eliminate the cause of non-compliance and prevent recurrence.
YONDBEE SOCIAL EFFECTS S.L. develops or, where appropriate, reviews existing compliance-related documents (considering the results of the risk identification and assessment).
TRAINING
Employees receive compliance training, and their attendance at such training is documented.
The contribution of the company’s staff to the effectiveness of the Criminal Compliance Management System is essential for them to help prevent and detect criminal risks, avoiding their materialization and recognizing risk factors.
COMPETENCE
YONDBEE SOCIAL EFFECTS S.L. ensures the competence of compliance staff based on appropriate education, training, or experience.
Performance objectives are periodically reviewed to ensure reasonable safeguards exist to avoid incentivizing criminal risk-taking or promoting inappropriate conduct concerning criminal compliance.
COMMUNICATION CHANNEL
YONDBEE SOCIAL EFFECTS S.L. has implemented an effective Communication Channel through which employees and third parties can communicate any information related to an alleged non-compliance to the company’s Compliance Officer.
YONDBEE SOCIAL EFFECTS S.L. makes the Communication Channel available to staff and third parties with a direct relationship and legitimate commercial or professional interest, regardless of their hierarchical level and functional geographic location, for:
• Communicating non-compliance with the Code of Conduct or any other internal rule, which they are aware of and may affect the organization, provided they have been committed by staff, suppliers, or third parties with whom there is a labor, commercial, or professional relationship.
All employees, as well as other interested parties, who have rational indications of any irregularity or act contrary to legality or internal regulations, must communicate it through the Communication Channel.
YONDBEE SOCIAL EFFECTS S.L. guarantees the confidentiality of the person making the communication at all times, as well as the absence of retaliation against those communications made in good faith.
If necessary, employees who file a complaint may do so anonymously.
The address for the Communication Channel is: canaldecomunicaciones@yondbee.com
SANCTIONS FOR INAPPROPRIATE CONDUCT
Non-compliance requires an appropriate sanction regardless of the employee’s condition (including, for example, non-payment of bonuses, dismissal, or any kind of legal action).
DELEGATION OF POWERS
In cases where the Management of YONDBEE SOCIAL EFFECTS S.L. delegates decision-making in areas with higher than low criminal risk, YONDBEE SOCIAL EFFECTS S.L. will establish and apply a procedure and control system to ensure that the decision-making process and the level of authority of decision-makers are appropriate and free from actual or potential conflicts of interest.
OBJECTIVES
The objective of the Compliance Policy is for YONDBEE SOCIAL EFFECTS S.L. to become a reference organization in regulatory compliance, conveying respect for the law and good business practices to the rest of society and its employees.
The criminal compliance objectives are consistent with what is established in this Policy and the results of the criminal risk identification and assessment, are monitored according to the established planning once the criminal risk assessment process is carried out, communicated, measurable (if possible), and updated as appropriate.
