CULTURE OF
COMPLIANCE
GRI 2-23, 2-24, 2-25, 2-26, 2-27, 205-1, 205-2

Grupo Lamosa promotes an organizational culture based on the values that identify the company and on the compliance required by its internal regulations and applicable local laws, and continuously implements best practices in ethics and integrity.

The values on which Grupo Lamosa bases its actions are:

  • RESPONSIBILITY
  • HONESTY
  • SPIRIT OF SERVICE
  • TEAMWORK
  • CONTINUOUS IMPROVEMENT

The company’s Code of Ethics contains the guidelines for conduct that is expected of directors, management and employees, and for guaranteeing a correct relationship with the external stakeholders with whom it has a relationship, including distributors and suppliers, who must also be committed to such compliance.

Employees receive training on the Code in their induction to the company. Subsequently, they sign a commitment letter (confirming no conflicts of interest), which they renew at least every two years.

This document is complemented by policies that reinforce the company’s ethical culture:

  • Anti-Corruption and Anti-Money-Laundering Policy
  • Privacy Policy
  • Conflict of Interest Policy
  • Diversity Policy

In order to identify possible undesirable practices in the organization, Grupo Lamosa has an ethical complaints line called the “Transparency Line” available for the use of employees, where they can anonymously report possible violations of the Code or institutional policies. Other stakeholders may also use the Transparency Line.

The Ethics Committee is the body responsible for following up on any cases of non-compliance that may arise and their respective resolution, and for receiving feedback to guarantee the constant revision and updating of the Code.

Additionally, this Committee makes continuous efforts to raise awareness and communicate the contents of the Code to employees, encouraging them to commit to the established guidelines. The related communication campaigns, such as the application of satisfaction surveys that measure the effectiveness and acceptance of the Transparency Line, are also noteworthy.

The Ethics Committee is made up of the CEO, the Human Resources Vice-President, the CFO and the Internal Audit Director. This Committee reports directly to the Audit Committee which, in turn, is accountable to the Board of Directors. In the event that any issue involves a member of the Ethics Committee, the Audit Committee is responsible therefor.

It should be noted that Grupo Lamosa did not file any case of legal non-compliance during 2022.

Appendix II: Main ESG indicators specifies the cases reported to the complaints line during 2022.