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Compliance System Policy

Criminal compliance system of Algoritmos, Procesos y Diseños, S.A.

This English version is provided for information purposes only. In the event of any discrepancy between this version and the Spanish version, the Spanish version shall prevail.

2. Criminal compliance policy

2.1. Purpose

This criminal compliance policy has been drawn up as a result of the decision adopted by APD's Board of Directors.

APD is aware that the balanced fulfillment of its corporate responsibilities must be accompanied by the constant pursuit of excellence in business ethics in all of its decision-making processes, which must be understood within a corporate environment in which strict respect for the most advanced national and international rules, practices, and principles in this area is one of the basic pillars of its operations.

With regard to the prevention of criminal conduct, Organic Law 5/2010 of June 22, which amended Organic Law 10/1995 of November 23 (the Spanish Criminal Code), not only introduced the offenses applicable to legal entities but also referred to the need to establish monitoring and control measures for their prevention and detection. This legal regime was amended by Organic Law 1/2015 of March 30, which set out in detail the requirements for having management and control systems in place that enable legal entities to demonstrate their due diligence in the area of criminal prevention and detection.

In line with these legal requirements, APD has equipped itself with internal instruments that meet the need for appropriate control and management systems applied in the area of criminal detection and prevention.

To this end, APD has drawn up and implemented the following instruments within its organization:

APD's Code of Ethics or general code of conduct: a document that sets out the basic guidelines or general principles that must govern and apply to APD personnel in their actions and in the performance of their duties or their business and professional relationships.
Specific policy on conduct toward suppliers and partners: a document that provides APD members with guidelines supplementary to the general code of conduct in their relationships with suppliers and partners.
Disciplinary system: a document that regulates the offenses and sanctions to be imposed on executives and employees who fail to comply with the measures established in the general code of conduct and in its supplementary rules.
Procedure for submitting and handling reports: a document that establishes the manner and conditions for submitting reports and how they will be handled at APD.

This “Criminal Compliance Policy” is now added to these internal regulatory instruments and, together with those previously mentioned, constitutes APD's criminal compliance and anti-corruption management system (hereinafter the regulatory compliance system), which is an integrated body with sufficient provisions to meet the expectations reasonably placed on organizations that operate with the highest levels of commitment, as is the case with APD.

2.2. Scope of application and definitions

2.2.1. The criminal compliance system applies both to APD and to all companies controlled by it, directly or indirectly, with “control” deemed to exist when so determined by the regulations applicable to each company.

In those companies in which APD does not have control, its representatives on the Governing Bodies shall promote, insofar as possible, the adoption of a criminal compliance system consistent with and similar to that of APD.

2.2.2. The criminal compliance system applies to all members of APD, in particular: to the shareholders, members of the Board of Directors, executives, and employees and, where applicable, to any other interested parties linked to APD's activity. Likewise, suppliers and other partners related to APD must be familiar with, take into account, and, where appropriate, accept APD's policies and conduct instruments.

2.2.3. The terms and concepts used in this document that have not been expressly defined herein shall have the meaning given to them by Spanish Standard UNE 19601 on criminal compliance management systems.

2.3. General principles of the criminal compliance system

The general principles that underpin APD's criminal compliance system and that inspire the content and application of all its internal corporate rules, as well as the conduct of its organization, are as follows:

APD, and in particular its Board of Directors and executives, shall act, and shall require that others act at all times, in compliance with current legislation and in accordance with the provisions of its criminal compliance system, with the main objective of seeking to prevent, avoid, detect, and respond appropriately to the commission of any acts that may constitute offenses under the criminal law applicable at any given time.
The prevention and detection of, and appropriate response to, criminal acts are fundamental objectives for APD and are consistent with its general policies of conduct. Accordingly, appropriate mechanisms are established within its organization to achieve these objectives through the regulatory development of the general principles of this compliance policy, as well as the establishment of sufficient procedures for managing criminal risks and procedures in the event of non-compliance and irregularities, particularly with regard to anti-corruption measures, thereby minimizing the organization's exposure.
APD shall encourage preventive conduct, properly identifying the activities in the course of which criminal acts may be committed and promoting proactive and responsible behavior among the members of its organization, in keeping with the most advanced and modern international principles on regulatory compliance.
APD undertakes to communicate the duty of all members of its organization to report, in good faith, any acts or conduct that are reasonably suspected of constituting criminal acts, establishing the appropriate channels, mechanisms, and means for reporting them, for their impartial and immediate investigation, and for any possible sanction by the relevant bodies of the organization, guaranteeing in all cases that good-faith whistleblowers are protected from retaliation and that their confidentiality is preserved.
APD shall likewise communicate to all members of its organization the consequences of infringements of the criminal compliance system, as well as, where applicable, the disciplinary sanctions established for offenders, which shall be applied by the Compliance Body in accordance with applicable labor regulations and with full respect for the rights of the persons under investigation.
For the purposes indicated above, the criminal compliance system shall be duly disseminated and made available, kept up to date at all times, for the knowledge and application of all members of the organization, as well as other interested parties that may pose or give rise to criminal risks.
APD shall provide an appropriate framework for defining, overseeing, monitoring, and achieving the objectives of the criminal compliance system, in particular by providing sufficient material and human resources to the unit responsible for regulatory compliance, without prejudice to the direct responsibility of each unit or department of the organization and to the supervisory obligation of the Compliance Body.
Proper application of the criminal compliance system is the responsibility of the Compliance Body, which is a single-member body vested with autonomous powers of initiative and control and with independence in the performance of its duties, and whose powers and principles of action are set out in section 2.4 of this document.
The criminal compliance system shall be subject to periodic review and continuous improvement by the Compliance Body, which shall report on any matter related to the organization's criminal risks as well as on changes in criminal compliance obligations and their impact on the organization, and shall likewise prepare the criminal compliance performance measurements and the results of any evaluation thereof.

2.4. Actions concerning the criminal compliance system

The main actions that APD will carry out on an ongoing basis for the effective application of its criminal compliance system are summarized below, on a non-exhaustive basis.

2.4.1. Risk assessment and control activities

The activities in the course of which criminal acts may be committed shall be identified by the Compliance Body and the heads of each of the organization's departments.

Control activities consist of drawing up protocols or procedures that will specify the process by which the members of the organization form their will, adopt decisions, and execute them; these protocols or procedures shall be implemented, supervised, and documented by the Compliance Body.

Risk scenarios and control activities are set out in the criminal risk report or in the criminal risk management system, which also identifies the appropriate performance and execution of the controls. The Compliance Body is responsible for supervising the application of said report and ensuring its suitability.

2.4.2. Supervisory activities

The criminal compliance system shall be continuously supervised to ensure that its design and operation are appropriate to the requirements of the applicable regulations, with the Compliance Body being responsible for supervising its proper functioning.

In carrying out this activity, the Compliance Body is responsible, on a non-exhaustive basis and in general terms, for performing the following activities:

Assessment of the criminal compliance system. The Compliance Body periodically evaluates the design and operation of the control activities provided for in the criminal compliance system.
Action plans for deficiencies. For each deficiency identified in the criminal compliance system, an appropriate action plan shall be designed and implemented to mitigate the risk associated with the deficient control.
Response to non-compliance. In cases of non-compliance with the criminal compliance system, or upon the identification of criminal acts, the Compliance Body shall conduct the necessary investigations. Should proceedings be initiated that could give rise to criminal liability for APD, action shall be taken in accordance with the provisions established by the Compliance Body itself in its “Action Protocol” pursuant to Article 31 bis of the Spanish Criminal Code.
Information and communication. The Compliance Body is responsible for promoting the initiatives necessary for the proper dissemination of information and training of personnel on ethics and the prevention of criminal risks, so that the members of the organization can properly fulfill their obligations in this area.
Documentation. The Compliance Body is responsible for promoting the actions necessary for the proper implementation and maintenance of the minimum documented information required for the purposes of Annex C of UNE 19601.
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