Author(s): Chief Compliance Officer
Validated by: Compliance Committee
Approved by: Governing Body
Project: Integrated Management System (IMS)
Classification: Public
NWorld, S.L. (hereinafter NWorld) recognises the importance of regulatory compliance in each of the countries where it operates as a key factor to achieve organisational excellence, market competitiveness and business sustainability.
NWorld’s Governing Body is fully committed to implementing, certifying and maintaining the Compliance Management System, in line with best practices and international standards, specifically according to “UNE 19601:2017 Criminal Compliance Management Systems — Requirements with guidance for use” and “UNE-ISO 37301 Compliance Management Systems — Requirements with guidance for use”.
The Governing Body will allocate reasonable and proportionate human and material resources to achieve these objectives.
The Governing Body is responsible for the proper functioning of the Compliance System, delegating to the Compliance Committee the authority and competencies for effective implementation, certification, maintenance and improvement, supported by management, staff and collaborators of NWorld.
The Code of Ethical Conduct (the “Code”) is our guide to appropriate behaviour, together with established work rules and procedures, to ensure correct conduct and prevent irregularities or breaches that could lead to the commission of offences.
The Code guides NWorld S.L. employees, collaborators and suppliers, and its subsidiaries and affiliates (collectively, “NWorld”) in their professional performance regarding daily work, resources used and the business environment. It clarifies basic management principles and interpersonal relationships with colleagues, collaborators, suppliers, customers, shareholders and anyone with an interest in the company’s activity.
Our actions are based on corporate values. We act with business ethics and professionalism to be a recognised benchmark.
This Code applies to all NWorld employees, suppliers and collaborators, regardless of contract type, position or workplace. They must know, comply with and collaborate in its application. At the request of the Compliance Committee, formal adherence to the Code may be required.
Our values represent our identity. We are different because the people who work at NWorld make this a unique project. We move fast, listen, seek innovation, are service-oriented and work rigorously and transparently as a team.
We listen to customers to understand needs and propose suitable solutions. We seek opportunities to improve services and create new business. We act with loyalty and good faith. We prioritise company-wide goals and avoid conflicts of interest. We value each member’s contribution, listen actively and provide innovative solutions. We continually update our technological knowledge to lead innovation. We protect NWorld’s image and reputation and demand the same from employees and suppliers.
We disclose any relationship that could create a conflict of interest. We do not accept undue compensation or advantages. We do not offer gifts or promise favours to obtain advantages. We declare gifts or benefits received and make them available to the company. We report any relationship affecting NWorld. We avoid anti-competitive practices and ensure clear and truthful advertising.
We respect equality, dignity and privacy, avoiding behaviour that undermines fundamental rights. We promote cordiality, respect and trust. We reject defamatory behaviour. We foster real equal opportunities and prohibit discrimination or harassment. We provide safe and healthy working conditions, comply with labour law and help eradicate child labour. We reject any form of violence, exploitation or harassment.
We are committed to environmental conservation, complying with legal requirements and reducing the impact of our activities. Everyone must foster environmentally respectful actions.
We treat as confidential all information arising from professional relationships with clients. We do not disclose personal or commercial information to third parties or outside/inside the organisation unless authorised. We provide truthful, necessary and timely information to managers and colleagues. We keep professional secrecy regarding non-public information. We obtain third-party information ethically and lawfully. We respect IP rights and use licensed software. Use of equipment follows NWorld’s acceptable use policy. We do not use system access for fraudulent or personal gain.
NWorld is a participant in the United Nations Global Compact. We implement practical measures in human rights, labour standards, environment and anti-corruption, adhering to its ten principles, including support for human rights, freedom of association, elimination of forced and child labour, non-discrimination, preventive environmental approaches, greater environmental responsibility, development of environmentally friendly technologies and anti-corruption.
All employees are required to report irregularities or breaches through:
Reports are handled by the Compliance Committee with maximum confidentiality and no retaliation for good-faith reporters, safeguarding honour, presumption of innocence and rights of access and defence.
NWorld has appointed an independent collegiate body to manage compliance. It oversees the Information Security, Criminal Compliance, Quality and Environmental Management Systems and supports staff, management, suppliers and collaborators on internal and external compliance matters. Contact: compliance@nfq.es.
NWorld has approved an internal regulatory regime governing sanctions for breaches of internal rules, internal fraud or offences within the entity, aligned with applicable collective agreements and the Spanish Workers’ Statute. Available on NWorld’s intranet.
The Code of Ethics entered into force on 13/04/2021. It will remain in force until amended or repealed, which will be duly communicated. Everyone must review it and comply with applicable laws, policies and guidelines. The Code cannot foresee every situation.
