GREEN LIGHT GO LEADERSHIP & CULTURE, SL is a Company founded in 2021 that has maintained throughout its history a business commitment to all those who interact with the Company or its employees. This commitment has always been based on principles of business ethics that guide the operation of GREEN LIGHT GO LEADERSHIP & CULTURE, SL, forming part of its corporate culture.
For this reason, the Company has implemented this ANTI-CORRUPTION POLICY, the purpose of which is to raise awareness about the provisions of Organic Law 1/2015, of March 30, which modifies Organic Law 10/1995, of November 23, of the Criminal Code, and the obligations provided for in matters of prevention of crimes, such as bribery, influence peddling, facilitation payments, corruption in business or any other conduct that may imply a violation of the aforementioned legislative framework.
This standard is also in line with the provisions of ISO 37001 on anti-bribery management systems.
This Anti-Corruption Policy applies to the management body, directors and employees of GREEN LIGHT GO LEADERSHIP & CULTURE, SL, as well as to third parties (clients, external collaborators, contractors, suppliers of goods and services, related entities, and other parties) that mediate, collaborate or participate in the legal transactions of the Company.
An effective anti-corruption programme must be based on the firm, explicit and visible support of the Company’s management staff. Therefore, from its highest levels, GREEN LIGHT GO LEADERSHIP & CULTURE, SL expresses its commitment to zero tolerance for corruption, a commitment that is supported by this Policy, which is the result of a business culture based on fundamental values such as integrity, business ethics and transparency.
Consequently, at GREEN LIGHT GO LEADERSHIP & CULTURE, SL corruption is prohibited at all times and in any form, whether direct or indirect, active or passive, with the Company’s governing body assuming the commitment to ensure that all employees and Business Partners are aware of and understand the values and standards of the company and, in particular, this Anti-Corruption Policy.
The Anti-Corruption Policy of GREEN LIGHT GO LEADERSHIP & CULTURE, SL is therefore based on carrying out its activities in an honest and ethical manner, in accordance with the values reflected in the Company’s “Code of Conduct and Ethics”. Therefore, the Company’s Management also assumes the following commitments:
For the purposes of this Policy, the following are understood as:
a) “Public official”:
b) “Bribery”:
According to international regulations, bribery is defined as an incentive or reward offered, promised or provided to a public official in order to obtain a commercial, contractual, legal, economic or personal advantage, and which includes the following conduct:
Bribery is illegal in all countries and is therefore a crime that carries severe financial penalties and imprisonment for those responsible.
The Spanish Penal Code punishes these behaviors in various ways, classifying the crimes of bribery (arts. 419 – 427bis), corruption in business (art. 286 bis) and bribery of officials (art. 286 ter).
c) “Facilitation payments”:
Facilitation payments are any small payments, favors, or gifts of low nominal value that are offered or given to a person—a public official or an employee of a private company—to expedite the issuance of a non-discretionary permit or procedure, such as obtaining a business license, connecting services, or clearing customs. All types of facilitation payments are prohibited under this policy.
d) “Extortion”:
Anyone who, with the intention of making a profit, forces another person, using violence or intimidation, to perform or omit an act or legal transaction to the detriment of his or her assets or those of a third party.
e) “Gift”:
In a broad sense, a gift is considered to be any present, favor, advantage, free provision or any other physical present or monetary donation.
f) “Pressure group or lobby”:
A group of influential people organized to lobby for certain interests.
a) Unacceptable behaviors
GREEN LIGHT GO LEADERSHIP & CULTURE, SL will not accept that any employee or third party acting on behalf of the Company:
b) Gifts, meals and entertainment
This policy does not prohibit the giving or acceptance of gifts and hospitality in accordance with the customs and practices of Spain, except in cases where such prohibition is expressly established.
In this sense, the giving or acceptance of modest gifts, attentions, meals or entertainment is permissible under reasonable criteria and provided that it is not a liberality, understanding that:
c) Charitable donations
Charitable donations are permitted directly to government entities or non-governmental organizations (but not to public officials) as part of the effort to promote corporate social responsibility. These types of donations are permitted provided that:
d) Facilitating payments
GREEN LIGHT GO LEADERSHIP & CULTURE, SL does not make or accept facilitation payments or “kickbacks” of any kind, such as small unofficial payments made to secure or speed up a process or procedure before the Public Administrations.
GREEN LIGHT GO LEADERSHIP & CULTURE, SL prohibits any type of indirect payment to public officials through agents or intermediaries acting on behalf of the Company. For this reason, it carefully selects its allies, suppliers, and business partners, and requires the necessary guarantees to prevent indirect payments being made on its behalf, and must suspend the relationship with the supplier and initiate the relevant legal actions in the event of detecting any breach of the Spanish legal framework, the Code of Conduct and Ethics or the Company’s policies.
Contracts with managers, intermediaries or any person who may act on behalf of or on behalf of GREEN LIGHT GO LEADERSHIP & CULTURE, SL must delimit the scope and area of their action, and must include penalty clauses in the event of violations of the Code of Conduct and Ethics, this policy or the Company’s guidelines against corruption.
GREEN LIGHT GO LEADERSHIP & CULTURE, SL will not initiate any contractual relationship with third parties that may represent it before Public Administrations or national or foreign authorities, without first initiating a due diligence process to verify the profile, skills and reputation of said third party.
The extent of this due diligence process will depend on the complexity of the relationship established with the supplier.
The report resulting from the due diligence process must be submitted to the Company’s Board of Directors for approval.
GREEN LIGHT GO LEADERSHIP & CULTURE, SL maintains a strict record of its accounting books and records, which faithfully reflect the Company’s transactions and assets.
The prevention, detection and reporting of conduct prohibited by this policy is the responsibility of all persons who make up the Company.
Employees and collaborators must immediately inform the Management Body of any unlawful conduct or suspicion of unlawful conduct of which they become aware.
Any employee who violates this policy may face disciplinary action, up to and including termination of employment for gross misconduct.
GREEN LIGHT GO LEADERSHIP & CULTURE, SL will proceed in each case according to the disciplinary and sanctioning system and depending on the severity of the infractions and the sanctions that they carry.
Complaints received by the Company’s Management Body will be treated with the utmost confidentiality and under no circumstances will reprisals be taken against persons who report in good faith.
GREEN LIGHT GO LEADERSHIP & CULTURE, SL will periodically require all its employees to formally declare that they are aware of and comply with this Policy, and will provide the necessary training for understanding and compliance with the Policy.
This Anti-Corruption Policy will be published on the corporate website.
The Management Body will be responsible for ensuring compliance with the anti-corruption policy.
This Anti-Corruption Policy came into force on May 4, 2022, by means of minutes approved at the Extraordinary General Meeting of Partners and is available to all GREEN LIGHT GO LEADERSHIP & CULTURE, SL staff.
Any modification to the Anti-Corruption Policy will be approved by the General Shareholders’ Meeting, published on the corporate website and notified in a timely manner to all recipients of this document.
GREEN LIGHT GO LEADERSHIP AND CULTURE, SL.
B67752162
Trafalgar Street, 10, 3-2
08010 BARCELONA
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