Code of Conduct

The world changes and at Embega
we change with the world


  • 1.1 Purpose
    The purpose of this Code of Conduct (hereinafter referred to as the "Code") is to remind all employees, account auditors (hereinafter referred to as "relevant persons"), customers, suppliers and public and private institutions (hereinafter referred to as "third parties") of the unwavering commitment of Embega S.Coop. ((hereinafter referred to as Embega) to comply with the laws and regulations in force and with the provisions of this Code.
  • 1.2 Professional Secrecy
    Compliance with the provisions of this Code is based on cooperation, trust, respect, as well as on the confidential treatment of all observations, discussions and communications between third parties and relevant persons appointed by Embega.


  • 2.1 Persons to whom this Code applies
    All persons of Embega or those acting on its behalf or representation, to the production plant and facilities or any of its subsidiaries ("Embega suppliers").
  • 2.2 Control structure in charge of monitoring
    Monitoring compliance with the Code is the responsibility of the Process Committee, whose tasks are summarized as follows:

    • a) Ensuring proper communication of the Code to everyone at Embega and to anyone else to whom it is of interest.
    • b) Reviewing the Code.
    • c) Maintaining confidentiality.
    • d) Preparation, on an annual basis, of a summary document for the Board of Directors, including the degree of implementation and the list of actions necessary to achieve the objectives set out in the Code.
  • 2.3 Communication of the Code
    The communication of this code of conduct will be made to all Embega employees through the established welcome manual. This manual will indicate the obligation to read and comply with this Code of Conduct.
    Whenever there are important changes and/or the Process Committee deems it appropriate, punctual communications will be made following the guidelines of the following points.

    • 2.3.1 Embega
      Task Channel Responsible
      1.- Comunicación al Consejo Rector.Consejo RectorPresidente Consejo Rector
      2.- Comunicación a los responsables de ProcesosReunión colaboradoresResponsables Procesos
      3.- Comunicación a todas las personas.Reunión colaboradoresResponsable colaboradores
    • 2.3.2 Third parties
      Task Channel Responsible
      1.- Communication to suppliersGeneral criteriaResponsible for Value chain
      2.- Communication to consultants and auditorsOperational meetingsResponsible contact person
    • 2.3.3 Internet
      A copy of this code can be found on Embega's website and another on the internal network.
  • 2.4 Contractual value of the Code for employees
    All employees are required to read the Code and to behave in accordance with the principles contained therein
    contained therein.
  • 2.5 Contractual value for members of the Board of Directors, the Rector and statutory auditors
    Compliance with the Code is an obligation for the Managers, members of the Governing Council, as well as for the account
  • 2.6 Contractual value of the Code for consultants and suppliers
    Compliance with the Code is an obligation for Embega's consultants and suppliers. Embega reserves the right to terminate any contract with consultants or suppliers who do not comply with this Code.


  • 3.1 Registration and manufacturing license
    Embega and its third parties shall have a business license to operate, and comply with the terms defined therein.
  • 3.2 General Principle: compliance with the legislation in force
    In carrying out professional activities, any Embega person or third party shall be aware of and comply with the laws in force in the country in which he/she lives and works on a regular or occasional basis; any Embega person or third party who is forced or instigated to break the law shall immediately report the matter to his/her Manager or HR Manager.
  • 3.3 Anti-corruption and bribery
    It is strictly forbidden to offer to third parties, any gift, which by its value, can be interpreted as a gift that exceeds courtesy and is made in order to obtain favorable treatment for Embega.Embega may not finance candidates or political parties.It is strictly forbidden to access funds and credits of public origin without the prior authorization of the Finance Department.

    • 3.3.1 Prevention and vigilance
      Embega's Board of Directors is responsible for ensuring compliance with both this section and this code of conduct. They meet monthly to monitor the management of the company.
  • 3.4 Reporting inappropriate conduct
    Any person belonging to Embega who observes bad practices or practices that are not in accordance with this Code of Conduct may report them to his or her Manager or to Human Resources through the usual channels of communication.


  • 4.1 General Principle: Compliance with applicable laws and regulations
    Any transaction carried out in the interest of Embega must comply with the applicable legislation in force and must be auditable (General Accounting Plan approved by Royal Decree 1514/2007).
  • 4.2 Authorization and copy of all transactions
    All transactions must be recorded at the accounting level.
    Every transaction must have its corresponding copy. A copy that can be consulted at any time, allowing the identification of the authors of the transaction, those who authorized, recorded and filed it.
  • 4.3 Cooperation with control agents
    All information shared from Embega with internal auditors and/or external agents must be updated, truthful, rigorous, prepared by appropriate personnel and must comply with current legislation.


  • 5.1 General Principle:
    Embega recognizes the fundamental principles of the Declaration of Human Rights, according to the UN definition (United Nations of 1.948).
  • 5.2 Contracts: compliance with current legislation
    Embega's employees and third parties shall be hired in accordance with the legislation in force; a contract (or valid document) must be in writing.
  • 5.3 Wages
    Embega shall keep records of the payment of monthly wages and the management of the hours worked by each employee, partner or contractor.
  • 5.4 Working hours and overtime
    The working day or work schedule of Embega's employees shall not exceed the legal limit under any circumstances.
  • 5.5 Wage conditions
    Embega shall pay its employees at least the minimum wage in accordance with local legislation (based on the hours that the law stipulates must be worked).
    Wages shall be paid on a regular basis according to the task performed and local legislation.
  • 5.6 Overtime Pay/Compensation
    Employees of Embega and its third parties shall be compensated for overtime in accordance with legal requirements.
  • 5.7 Leave
    Embega employees shall be granted leave in accordance with applicable legislation and local traditions (e.g. sick leave, vacation leave, maternity leave, public holidays, etc.).
  • 5.8 Benefits
    Embega shall provide its employees with the benefits to which they are entitled by law (e.g. health insurance, social security, pensions, etc.).
  • 5.9 Child labor
    Embega and its third parties shall not hire children (1) and shall keep a record of the date of birth of all employees.
    In the event that the presence of a minor is detected in the company, the People department will be informed in order to terminate the contract and the causes will be analyzed and the relevant corrective and preventive actions will be defined.
    Note 1: In accordance with the International Labor Organization (ILO) Minimum Age Convention of 1973, a child is considered to be any person under 15 years of age, except in cases where local laws consider a higher age or compulsory schooling, in which case the higher age shall apply.
  • 5.10 Forced and Hard Labor (Access Requirements)
    • Shall not use force (1)
    • Shall not hire prisoners (2)
    • Employees shall not be forced to perform involuntary labor.
      Note 1: Forced labor is any work that is performed under threat of punishment, confiscation of belongings (such as ID card, passport, etc.) and for which the person has not volunteered.
      Note 2: The use of civilian or military prisoners is prohibited.
  • 5.11 Discrimination
    Embega and its third parties shall avoid discriminating against employees on the basis of their faith, gender, marital status, age, political affiliation, place of birth, sexual orientation or any other reason prohibited by law.
  • 5.12 Associationism
    Embega and its third parties shall ensure that their employees have the possibility to associate freely.

6 ENVIRONMENTAL POLLUTION - Water, Atmosphere, Noise, Soil, Chemical Agents and Wastes

  • 6.1 General Principle
    Embega and its third parties shall have the permits and comply with the provisions of the law on environmental matters. In particular:

    • Air pollution
    • Noise Pollution
    • Water Pollution
    • Soil Contamination
    • Chemical agents
    • Hazardous and non-hazardous waste.
  • 6.2 Requirements
    Embega and its third parties shall comply with:

    • Statutory environmental inspections: ensuring compliance with corrective actions resulting from governmental me- dioenvironmental inspections; documenting and timely completion of such actions.
  • 6.3 Continuous improvement:
    Embega and its third parties shall demonstrate their involvement in continuous improvement in environmental aspects:

    • Emissions to air
    • Emissions to soil and water
    • Noise
    • Hazardous and non-hazardous waste
    • The use of natural resources, e.g. energy, raw materials, chemicals etc. as well as the reduction of fossil fuel use.
    • The supplier shall continue to work on the substitution of hazardous chemicals with non-hazardous chemicals.


  • 7.1 General Principle
    Embega and its third parties shall comply with the provisions of the law on occupational safety and health.

    • Fire prevention.
    • Accident and incident management.
    • Occupational health and safety training.
    • Safety elements of the machinery.
    • Safety instructions.
    • Selection and use of Personal Protective Equipment (PPE).
    • First aid equipment and personnel training.
  • 7.2 Requirements
    Embega and its third parties shall comply with:

    • Statutory occupational health and safety inspections: ensuring compliance with corrective actions resulting from government inspections; documenting and timely completion of such actions.
  • 7.3 Continuous improvement:
    Embega and its third parties shall ensure and demonstrate continuous improvement in areas related to health and safety, in order to go:

    • Reducing the number of accidents and incidents
    • Increasing the participation and motivation of the workforce in the improvement of their work environment.


  • 8.1 General Principle
    Every person at Embega has the obligation to ensure, with the utmost confidentiality, all relevant information that is managed in the performance of its activities, both internally and externally.
    Embega, in compliance with the applicable data protection legislation, is committed to protecting all information related to its employees or third parties.
    Any Embega person who needs to share confidential information with third parties, directly or indirectly, must share such information with his or her Manager or Embega's Board of Directors.


  • 9.1 Sanctions
    If Embega's people do not comply with any of the articles of this Code, they will be subject to sanctions, which vary according to the provisions of Embega's internal regime.

10 Contributions of the code of conduct to the supplier approval process

  • 10.1 Pre-evaluation Document (Initial Requirement)
    By signing the Pre-evaluation document (containing the Start-up Requirements), Embega's suppliers will accept the start-up conditions. The Pre-evaluation document will consist of 4 questionnaires related to:

    • Quality System
    • Environmental Management
    • Occupational Health and Safety Management
    • Management of employees and personnel in general