1. Objective.
The objective of this policy is to reinforce IMTO’s commitment—hereinafter “the Group”—to ethical and transparent business practices, and to prevent any form of corruption and bribery in all our commercial and business activities, whether domestic or international.
2. Scope of Application.
This policy applies to all employees, executives, contractors, suppliers, business partners, and all parties that interact with the Group directly or indirectly.
3. General Principles.
• Prohibition of Bribery and Corruption: Bribery, corruption, and any other form of illegal or unethical conduct involving the offering, solicitation, or acceptance of improper benefits are strictly prohibited.
• Legal Compliance: a commitment to complying with national and international regulations related to the prevention of corruption and bribery, such as the Code for Combating Fraud and Corruption, Law 10/2010, as well as the consolidated anti-fraud legislation introduced by EU Directive 2017/1371.
• Zero Tolerance: The group has a zero-tolerance policy regarding any form of bribery, whether directed at or committed by employees, customers, suppliers, or any other person associated with the organization.
• Transparency: All employees and contractors must act transparently in all business interactions and maintain accurate and complete records of all financial and business transactions.
4. Responsibility and Commitment.
All individuals who are part of the Group are responsible for adhering to the following codes of conduct in the performance of their duties:
• No Acceptance of Bribes: No payment, gift, or benefit of any kind may be accepted, offered, or promised for the purpose of obtaining commercial or business advantages.
• Disclosure of Conflicts of Interest: All members of the Group must disclose any conflict of interest that may arise in connection with the conduct of business relationships, whether with customers, suppliers, or other stakeholders.
• Education and Training: The Group is committed to providing ongoing training on business ethics, compliance with anti-corruption laws, and best practices for employees.
5. Relationships with Third Parties.
In relationships with Suppliers and Business Partners, rigorous due diligence must be conducted in the course of business dealings. To this end, the Group will ensure that they share the same ethical principles regarding the prevention of corruption and bribery.
6. Whistleblower Mechanism.
The group provides all its employees and contractors with a confidential whistleblower system where they can report any suspected instances of corruption or bribery completely anonymously and confidentially.
Any report received will be investigated thoroughly and confidentially, and the necessary corrective actions will be taken if any violation is confirmed.
7. Noncompliance.
Failure to comply with this policy will be considered a serious offense, with the consequences that this entails.
8. Review and Update.
Periodic review to ensure efficiency and compliance with any regulatory and operational changes that may occur.
Mascaraque, January 28, 2025
