Code of ethics and legal compliance
COS can only maintain its long-standing reputation as a business and professional partner by conducting itself fairly, ethically and correctly in all business activities it undertakes.
COS is firmly committed to legal compliance and criminal risk prevention, driving compliance measures and integrating a culture of compliance applicable to all COS employees and collaborators.
In 2018, COS is developing a Criminal Risk Prevention Protocol whose basic purposes are:
- Prevent the commission of crimes.
- Promote a true culture of business ethics
- To avoid or mitigate the criminal liability of the legal entity.
- To dissuade those who intend to commit an irregularity.
In order to comply with the basic principles of the Criminal Risk Prevention Protocol and lay the foundations for an environment of control and continuous improvement of compliance, COS has defined its Code of Conduct and Business Ethics and has set up a Whistleblower Channel.
Through its Code of Conduct and Business Ethics, COS sets out the corporate values and behavioral guidelines to be followed and identifies conduct expressly prohibited within the company relating to:
- Conflict of interest
- Personal Benefit, Corruption and Bribery
- Equality and non-discrimination
- Financial Provisions
- Conduct with Customers
- Conduct with suppliers
- Conduct with external consultants
- Conduct with Competitors
- Conduct with partners
- Confidentiality and Information Security
- Respect for Human Rights (United Nations Pact)
- Environment and Sustainability
- Occupational Risk Prevention
This applies to all COS employees and collaborators and is regularly communicated to all of them.
Based on these principles, the Organization has established its Whistleblower Channel, through which both employees and other interested parties may communicate complaints or suggestions and concerns related to the commission of irregularities within the Company.
Although the organization has enabled a Whistleblower Channel, any natural person may use the external reporting channel of the Independent Whistleblower Protection Authority, I.W.P.A., to report the commission of any action or omission falling within the scope of the Whistleblower Protection Act, either directly or after communication through the relevant internal channel. A public disclosure may also be made as long as the conditions set forth in the Whistleblower Protection Act are met.
COS has appointed a Compliance Committee with sufficient authority and power to supervise and oversee the operation, effectiveness and compliance with the Criminal Risk Prevention Model.