Article 1. Purpose (3)
Article 2. Scope of application (3)
Article 3. Mission, strategic vision and values of Bip&Drive (3)
Article 4. Composition (3)
Article 5. Functions (3)
Article 6. Protection of the physical and moral integrity of staff members and non-discrimination (4)
Article 7. Recruitment and promotion policy (4)
Article 8. Training (4)
Article 9. Occupational health and safety (4)
Article 10. Appropriate use of information systems (4)
Article 11. Confidential and classified information. Discovery and disclosure of secrets (5)
Article 12. Money laundering (5)
Article 13. Anti-bribery policy (5)
Article 14. Gift policy (6)
Article 15. Financial policy (7)
Article 16. Social security (7)
Article 17. Environment (7)
Article 18. Corporate image (7)
Article 19. Clients (7)
Article 20. Competition (7)
Article 21. Suppliers (7)
Article 22. Public authorities (8)
Article 23. Business partners (8)
Article 24. Sanctions (8)
Article 25. Obligation to report (8)
Article 26. Enquiry and Complaints Body (9)
Article 27. Management of the Enquiry and Complaints Body (19)
Article 28. Procedure for handling complaints (9)
Article 29. Approval (9)
Article 30. Communication (9)
Article 31. Training (10)
Article 32. Monitoring (10)
Article 33. Validity (10)
Chapter 1. General provisions.
Article 1. Purpose
The purpose of this Code is to foster the ethical conduct of all Bip&Drive members, as well as third parties linked to the company, in a way that complies with current legislation and with the principles and values of the company.
Article 2. Scope of application
- The principles and guidelines of conduct contained in the Code of Ethics apply to all staff members and directors of Bip&Drive regardless of their hierarchical level (hereinafter referred to as members) and foster actions for their business partners (any party with which the company has some type of business relationship) to be governed by values and ethical requirements similar to those of this document.
- The guidelines and policies of this Code are applicable in the workplace and in all activities involving the company members on a professional level (meetings, events, social media activity, etc.) both inside and outside the offices of Bip&Drive.
Article 3. Mission, strategic vision and values of Bip&Drive
The mission of Bip&Drive is to provide innovative solutions through the use of technology and new payment methods to simplify and streamline the mobility of our clients.
Our strategic vision is to be the best mobility platform in the market.
We intend to achieve this by complying with the ethical principles that govern our activity as a company and are reflected in the following values:
- Commitment to the Universal Declaration of Human Rights, workers' rights and the environment.
- Scrupulous respect for lawfulness and for regulations.
- Innovation and creativity.
- Work environment of trust and teamwork.
Chapter 2. Compliance Body
Article 4. Composition
The Compliance Body is unipersonal and under the responsibility of the Compliance Officer.
Article 5. Functions
The functions of the Compliance Body are the following:
- To foster and supervise the implementation of the compliance management system.
- To inform the governing body about the implementation of controls.
- To oversee staff training in the in-house control of compliance.
- To receive, analyse and implement appropriate measures in the event of complaints about violations filed by third parties or staff members which may entail a criminal offence.
- To represent the company in possible criminal proceedings in line with the group's criminal liability requirement.
- To draw up compliance reports.
- To ensure that all documented information on the compliance system is (i) reviewed and approved; (ii) is available; (iii) is suitable for use; and (iv) is adequately protected against the lack of confidentiality, inappropriate use or loss.
- To ensure that the compliance management system is reviewed every two years.
Chapter 3. Ethical principles of business conduct
Article 6. Protection of the physical and moral integrity of staff members and non-discrimination
Bip&Drive is committed to preventing, detecting, resolving and, where appropriate, punishing inappropriate conducts which may take place, emphasising the duty of all group members to prevent any situation of moral and sexual harassment, and discriminatory treatment.
Article 7. Recruitment and promotion policy
- The Bip&Drive recruitment and promotion policy is governed by the principles of equal opportunities and professional aptitude.
- If anybody associated to persons of public responsibility is contracted to provide professional services, approval shall be required from the Board of Directors, as well as a report from the Compliance Body and proof of the candidate's professional aptitude.
Article 8. Training
It is Bip&Drive policy to ensure that all members have their knowledge and technical skills refreshed to the necessary level by means of ongoing training. They will also receive training on company protocols and codes of conduct.
Article 9. Occupational health and safety
Bip&Drive is committed to guaranteeing occupational health and safety, so it rigorously complies with all the occupational risk prevention measures provided for in current legislation.
Article 10. Appropriate use of information systems
Bip&Drive members must use information systems within the ethical channels and solely for professional purposes. As a result, the "Bip&Drive Code of Conduct for the Use of New Technologies" is of mandatory application.
The following conducts are prohibited:
- Visiting websites with pornographic content.
- Accessing restricted areas of company or third-party computer systems.
- Accessing other users' emails or files.
- Sharing or revealing the user ID and password provided by the company.
- Voluntarily introducing programs, viruses, macros, applets, ActiveX controls or any other logical devices or strings which may cause damage to group or third-party computer systems.
- Failing to use or disabling antivirus programs or updates.
- Destroying third-party information.
- Entering the computer networks of competitors in order to damage computer files.
- Using computer programs without the corresponding licence.
- Uploading, downloading or exchanging software, music, films and any other digital content without authorisation.
Article 11. Confidential and classified information. Discovery and disclosure of secrets
- All Bip&Drive members must ensure the protection of information which the company has labelled as confidential and classified against any attempt of unconsented internal or external access.
The following conducts are prohibited:
- Gaining access to another person's papers, letters, emails or any other documents or personal effects without their consent in order to discover their secrets or violate their privacy; intercepting their telecommunications or using technical devices to listen to, transmit, record or reproduce sound, image or any other communication signal.
- Gaining access without authorisation, using or modifying, to the detriment of a third party, another person's classified data of a personal or family nature registered in computer, electronic or telematic files or formats, or in any other type of file or public or private registry; accessing said data by any means; and altering or using it to the detriment of the data subject or a third party.
- Gaining access by any means to the data, written or electronic documents or computer files to find out information labelled as classified or confidential, or secrets about third-party companies.
- Spreading, disclosing or transferring information labelled by the company as confidential or classified, or secrets about third-party companies.
Article 12. Money laundering
The fight against money laundering is one of the ethical principles of Bip&Drive. Therefore, it complies with all national and international regulations on the prevention of money laundering.
Similarly, Bip&Drive does not establish business relationships with persons or entities that fail to comply with the aforementioned regulations or that fail to provide requested information about compliance with them.
Article 13. Anti-bribery policy
- Bip&Drive performs its business with full respect for national and international anti-bribery legislation.
As part of the Bip&Drive anti-bribery policy and in compliance with other provisions in this Code of Ethics, the following conducts are prohibited:
- Offering or giving a gift or compensation to an authority, public official (national or foreign) or any other civil servant for them to perform an act contrary to the duties inherent to their position.
- Influencing a public official (national or foreign) or authority by taking advantage of any situation derived from their personal relationship with said person or another civil servant to secure a resolution which may create a personal or third-party financial benefit.
- Offering or giving unjustified benefits or advantages to directors, administrators, employees or partners of a trading company or of a society, association, foundation or organisation in order to create a personal or third-party benefit, in breach of requirements on the purchase or sale of goods or on the contracting of professional services.
- Offering, promising or granting any undue, pecuniary or other type of benefits or advantages; corrupting or attempting to corrupt, either individually or with the help of a third party, an authority or public official for their benefit or that of a third party, or responding to their requests in this regard, in order for them to act or refrain from acting in relation to the exercise of public functions to achieve or keep a contract, business or any other competitive advantage in the conduct of international financial activities.
- Making donations or contributions to political parties on behalf of Bip&Drive.
For the purposes of this Code of Ethics, public officials are understood as:
- Holders of municipal, regional or national public positions, including members of legislative bodies, holders of executive positions and holders of judicial power.
- Leaders of political parties.
- Candidates for public office.
- Employees of the government, ministries, government agencies, administrative courts and public boards.
- Officials of public international organisations, such as the World Bank, United Nations, International Monetary Fund, etc.
- Employees of public companies, unless the company operates under normal trading conditions in the relevant market, i.e. in a way which is essentially equivalent to that of a private company, without preferential subsidies or other privileges.
Article 14. Gift policy
- Bip&Drive defines normal courtesy practices as gifts or favours which do not exceed the sum of €50 and which feature the company logo, or items used in meetings, conferences or congresses.
- No gifts shall be made above this amount if they fail to promote Bip&Drive due to the non-presence of the company logo.
- Gifts received by Bip&Drive members in excess of €50 shall be raffled among staff members.
- No gifts shall be given to public officials.
- Invitations to events not related to the company's business may only be accepted or offered if the inviter is the sponsor of the event and they are not individual invitations.
Article 15. Financial policy
- Bip&Drive is committed to complying with accounting and financial regulations.
- The professional activity of all members of the Bip&Drive financial department, as well as its external partners, is governed by the principles of segregation of duties, integrity, objectivity, competence and professional diligence, confidentiality and professional conduct.
- The Bip&Drive financial department has implemented the necessary approval routes for the management of its financial resources.
- Bip&Drive has external and internal auditing systems.
Article 16. Social Security
It is Bip&Drive policy to be up to date with the payment of Social Security contributions and not to request undue rebates or deductions.
Article 17. Environment
- Bip&Drive carries out its business with scrupulous respect for the environment, minimising any impact on it and complying with environmental regulations.
- Bip&Drive partners which due to their business carry an environmental risk must comply with national and international regulations, implement external and internal auditing procedures and regularly update their prevention plans.
Chapter 4. Ethical requirements in relations with third parties
Article 18. Corporate image
- All Bip&Drive employees and managers shall contribute to upholding the reputation and corporate image of professionalism, transparency and regulatory compliance through their professional practice.
- Bip&Drive members shall make an appropriate use of social media in order not to damage or compromise the corporate image.
Article 19. Clients
- Bip&Drive's relationship with its clients is based on the principles of honesty, confidentiality and information security.
- Company members are prohibited from spreading, disclosing or transferring confidential information about clients.
- Bip&Drive members and business partners are prohibited from making false allegations or expressing uncertain characteristics about offers or advertising of company products or services.
Article 20. Competition
Bip&Drive aspires to lead the industry through excellence, effort, continuous improvement and fair treatment of its competitors, complying with the guidelines of the free market and competition law and requiring the same behaviour from its business partners.
Article 21. Suppliers
- The selection of Bip&Drive suppliers is governed by the principles of impartiality and objectivity.
- Bip&Drive members are obliged to comply with the company's purchasing policy in the selection of suppliers.
- Company members with decision-making capacities are prohibited from receiving any type of remuneration, gift or personal benefit from suppliers which may have an influence on their objectivity and impartiality.
- Company members are prohibited from spreading, disclosing or transferring confidential information about suppliers.
Article 22. Public authorities
- The relationship between Bip&Drive and public authorities is based on the principles of transparency and truthfulness.
- Ethical requirements in relationships with public authorities entail the prohibition of the following conducts by company members and business partners:
- Falsifying or concealing data when requesting subsidies, rebates or any type of aid from local, regional, national or European public authorities.
- Failing to comply with established conditions by substantially altering the purposes for which the subsidy was granted during the development of an activity subsidised with funds from the public authorities.
Article 23. Business partners
- For the purposes of this Code of Ethics, a business partner is defined as any party, except for company members, with which Bip&Drive has or plans to have some type of business relationship, such as customers, suppliers, consultants, advisors or investors.
- Bip&Drive requires its business partners to adopt compliance management systems.
- Bip&Drive may at any time request information on risks of criminal liability from its business partners in order to assess whether the controls implemented by these companies are sufficient to detect, avoid and manage said liability. If such controls do not exist, the company shall demand their implementation. If this is not possible, this fact will be included in the assessment of criminal liability.
Chapter 5. Disciplinary measures
Article 24. Sanctions
- Failure to comply with this Code of Ethics shall result in disciplinary sanctions, the levels of which shall be established in accordance with applicable collective agreements and the workers' statute.
- Conducts explicitly prohibited by this Code and/or criminal offences shall entail dismissal. This is without prejudice to Department of Justice having knowledge of the facts.
Article 25. Obligation to report
Any Bip&Drive member who witnesses any of the conducts explicitly prohibited by this Code of Ethics is obliged to report said fact via the communication channel established for that purpose.
Chapter 6. Communication channel and procedure for handling complaints
Article 26. Enquiry and Complaints Body
- Bip&Drive has a communication channel with the Enquiry and Complaints Body in which company members can make enquiries when they have any questions about the application of this Code of Ethics, or to report a conduct which may breach any of the ethical principles contained in this Code.
- The Enquiry and Complaints Body is external to Bip&Drive in order to guarantee the confidentiality of the complainants and prevent the misuse of the communication channel. All this is without prejudice to the decisions which may be adopted by the Department of Justice and the relevant authorities in relation to awareness of the complainant's identity when the punishable act, if any, is transferred to them.
Article 27. Management of the Enquiry and Complaints Body
Queries and complaints may be sent to the following email address:
Artículo 28. Procedimiento de tramitación de las denuncias
- Complaint phase: The Enquiry and Complaints Body will report complaints showing reasonable evidence of any irregular conducts to the compliance officer, guaranteeing the confidentiality of complainants, unless both bodies are operated by the same person.
The complaint must contain the identity of the complainant and the accused, a detailed statement of the facts included in the complaint and, as far as possible, any other information or document which proves the veracity of the events.
- Investigation phase: the compliance body will gather all the information needed to clarify the facts, respecting the privacy rights, the defence and the presumption of innocence of the person under investigation.
- Resolution phase: if, as a result of the internal investigation conducted, there is evidence of any conduct which contravenes the compliance management system, the compliance body shall implement the relevant disciplinary measure. All of this is without prejudice to the awareness of the Department of Justice about the punishable acts and any civil and criminal actions which may be relevant in each case.
Chapter 7. Approval, communication, training, monitoring and validity
Article 29. Approval
This Code of Ethics was approved by the Board of Directors on 5 June 2018.
Article 30. Communication
Bip&Drive undertakes to communicate this Code of Ethics to its members and the rest of company via its website.
Article 31. Training
Bip&Drive has trained all its employees and managers in this Code of Ethics.
Article 32. Monitoring
Bip&Drive is committed to monitoring compliance with this Code of Ethics as part of its monitoring of the effectiveness of the group's compliance system.
Article 33. Validity
This Code of Ethics shall be reviewed every two years in order to adapt it to variations in business activities or criminal liabilities, unless there is a legislative change before the expiration of said period, in which case it may be reviewed at any time.