Ethical Framework.
Following the best practices

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Anti-corruption Policy, Code of Conduct and the Crime Prevention Model

As a member of the United Nations Global Compact, Dominion has taken on board the principle that all "Businesses should work against corruption in all its forms, including extortion and bribery" and has developed a framework that includes its Code of Conduct, Criminal offence prevention model and its Anti-corruption and Fraud Policy.

Dominion's Board of Directors approved this Policy as an initiative to raise sufficient awareness amongst all of its employees and particularly amongst its executives. This includes a series of commitments which are consistent with the principles and values in and with the Code of Conduct. More specifically, it expressly forbids any conduct or practice of corruption, bribery or influence peddling in relation to customers, suppliers, trading partners and civil servants or public, national or international institutions.

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Whistleblower Channel

The whistleblowing channel operates according to regulations that guarantee that complaints can be made in a personal or anonymous manner, ensuring the confidentiality of the complainant at all times.

The Audit and Compliance Committee is responsible for the whistleblowing channel which, in turn, entrusts this responsibility to the Criminal Defence Body Advisory Panel, formed by four members. The Company has established some rules of procedure for analysing any complaints received and reporting these to the Audit and Compliance Committee.

A total of 3 reports were filed in 2019. In one case, the report was treated as a complaint, as the content related to this type of claim. Additional enquiries were made regarding the other two cases, which resulted in both cases eventually being shelved.

More information

The Stock Exchange

As a listed company, it also has an in-house code of conduct for matters relating to the Stock Market. This governs the rules of conduct to be respected by the company, its administrative boards, employees and representatives in their actions relating to the stock market, pursuant to the provisions of Royal Decree 1333/2005, of 11 November, which implements the Securities Market Act (LMV), regarding market abuse.

Go to CNMV

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Dominion's Policies

Dominion's ethical framework consists of various in-house standards and protocols. These policies govern relations with the different stakeholders and form a guide for our own actions that extend beyond strict compliance with current legislation. The Compliance Department develops and updates in-house policies and procedures.

Check the policies here