Compliance Policy

DOCUMENT REVIEW/MODIFICATION STATUS

Edition No.

Date

Nature of Review

00 

08/08/2023 

Initial edition

 

PREPARED BY

SIG Responsible

REVIEWED BY

General Manager

APPROVED BY

Management

Name: Fátima Guillén Grande

Date: 08/08/2023

Name: Agathi Kanellou 

Date: 15/08/2023

Name: Fátima Guillén Grande

Date: 15/08/2023

1. Purpose 

MCI Management, aware of the importance of defining and documenting its Compliance Policy, has ordered the implementation of an independent and sufficiently authorized Compliance Management System. The purpose is to carry out work in accordance with the prescribed System Procedures, and to ensure compliance applicable to the organization and the requirements contained in the Compliance Management System, for the benefit of customers and society in general.

Therefore, it aligns with its ethical values, reaffirming MCI’s commitment to maintaining a respectful behavior towards both regulations and ethical values, defining its framework of compliance principles.

This Policy is aligned with MCI’s culture of integrity and respect for regulations, taking into consideration not only the organization’s interests but also the demands that may arise from its stakeholders. In this sense, it is a text aligned with MCI’s strategic objectives and, consequently, with its determination not to tolerate any conduct within its organization that may constitute a crime.

Therefore, the utmost commitment is required from Management, as well as from all members of MCI.

2. Principles

Below are the main responsibilities of the Compliance Body, structured in a systematic manner:

● Independently promote and supervise the implementation of the Compliance Management System, ensuring that all parties affected by this document have access to the Organization’s compliance rules.

● Identify compliance obligations, keep them up to date, and disseminate them to Organization Members.

● Identify and manage compliance risks, analyze and assess them in order to prioritize actions and allocate resources for their prevention, detection, and management.

● Promote the use of reporting channels implemented in MCI and ensure the absence of retaliation against the whistleblower.

● Promote awareness and training cycles that enable parties affected by this document to have the knowledge and skills necessary to assume their responsibilities regarding the prevention, detection, and management of compliance risks. Likewise, it is responsible for promoting the dissemination and implementation of compliance training programs, encou-raging the dissemination and ensuring compliance with MCI’s Code of Ethics and Conduct, as well as its policies and pro-cedures of Compliance. 

● Advise not only the MCI Management but also any other member of the Organization who requires assistance from the Compliance Committee and provide reports to the Governing Body and Senior Management on the results derived from the execution of the Compliance Management System and its performance.

● Properly identify, in the appropriate format, not only the information of the pillars of the Compliance Management System but also the documentation derived from its execution, ensuring that it is available (except for information that, due to confidentiality reasons, is only accessible to certain areas of the Organization), suitable for use, and allows for traceability of access and preservation of its legibility, promoting a culture that demands compliance with the basic principles of responsible behavior for all professionals associated with MCI.

● Measure the performance of the Organization’s Compliance Management System through indicators, ensuring that all its elements operate correctly, and promoting its continuous review and improvement.

3. Obligations

To the extent that compliance with the law and the proper development of the Compliance management system is the responsibility of all members of MCI, it is expected that regardless of their position within the organization, they will ensure compliance with the provisions of this document, always observing ethical behavior and refraining from engaging in criminal activities. They should also promptly follow any instructions received from the Compliance Body in the exercise of the aforementioned functions.

All members of the organization are responsible for understanding, observing, and implementing the provisions of this Compliance Policy, collaborating with the Compliance Body, the governing body, and senior management when necessary, and adhering to the expected behaviors outlined in the aforementioned Code of Ethics and Conduct.

Furthermore, all members are required to immediately report to the Compliance Body any actions taken to prevent or remedy the potential commission of a crime or potential crime of which they are aware or that is being managed without apparent intervention from the Compliance Body.

Additionally, it is expected that all members of the organization will adhere to this Compliance Policy, attend training sessions determined by their role or position within the organization regarding Compliance matters, and promptly provide any information and documentation requested by the Compliance Body.

4. Knowledge and compliance statement

This Policy is provided and made available to all Members of the Organization on the corporate intranet.

Furthermore, MCI will make this Policy available to its business partners through its corporate website.

For Members of the Organization holding positions particularly exposed to criminal risk, their annual compliance statement with this Compliance Policy will be requested.

5. Consequences of non-compliance

In accordance with the provisions of the Code of Ethics and the Compliance Policy, all individuals affected by this document, regardless of their hierarchical level and geographical or functional location, have an obligation to comply with the principles and procedures established in these texts, to the extent applicable to them.

Likewise, in order to ensure the proper implementation of the Compliance management system, they are encouraged to report any violations thereof through MCI’s Whistleblower Channel.

To verify the above paragraph, MCI has a Disciplinary System in Compliance matters that serves as the internal guide for proving the effective implementation of MCI’s Compliance Management System, and as a means to sanction, under the current labor regulations or any other applicable regulations due to the professional relationship with MCI, violations and non-compliance with the regulatory body of the Compliance Management System applicable to the organization, which includes, among others: MCI’s Code of Ethics and Conduct, its internal policies and procedures, as well as applicable laws and regulations or market best practices.

Therefore, the Disciplinary System complies with the provisions of our Criminal Code and also applies to other non-compliance cases provided for in the Compliance Management System.

The measures taken from a labor perspective will be in compliance with the applicable regulations, without losing their effectiveness or proportionality to the seriousness of the underlying facts, and informing, if necessary, the Legal Representatives of the Workers.

In the event that it is confirmed that the actions of any Member of the Organization may constitute a criminal offense attributable to the legal entity, this circumstance will be brought to the attention of the competent Public Authorities for their knowledge and prosecution. This communication will be accompanied by the evidence and/or indications that have been collected in this regard.