{"id":10458,"date":"2025-06-11T11:29:58","date_gmt":"2025-06-11T11:29:58","guid":{"rendered":"https:\/\/www.fae.es\/anti-corruption-policy"},"modified":"2025-06-12T05:11:56","modified_gmt":"2025-06-12T05:11:56","slug":"anti-corruption-policy","status":"publish","type":"page","link":"https:\/\/www.fae.es\/en\/anti-corruption-policy","title":{"rendered":"Anti-Corruption Policy"},"content":{"rendered":"\t\t
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Anti-Corruption Policy<\/h2>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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Definitions<\/strong><\/h3>

For the purposes of this Anti-Corruption Policy, the following definitions apply:<\/p>

Ethics and Compliance Committee<\/strong>: The Ethics and Compliance Committee<\/strong> is the body appointed by the Administrator, responsible for ensuring regulatory compliance within the organization.<\/p>

Gift<\/strong>: A gift may be defined as any item of value that is offered or received without the expectation of payment or direct return. This includes, but is not limited to, material goods, services, hospitality (such as meals or entertainment), discounts not available to the public, and personal favours. <\/p>

Corporate Gift<\/strong>: A corporate gift is considered any item of value that is given or received openly and transparently as a symbol of courtesy or gratitude. An example of a corporate gift may be the offering of a corporate calendar, pens, or other items related to FAE<\/strong>‘s activity, with symbolic and economically insignificant value. <\/p>

Hospitality<\/strong>: Refers to any courtesy, generally of a social nature, that is offered or received in a business context, related to or because of FAE<\/strong>\u2019s activity. An example of hospitality may be offering a meal to a third party with whom there is a business relationship, following a work meeting or during a meeting where business matters are discussed. <\/p>

Business Partners<\/strong>: A business partner is considered any individual or legal entity with whom FAE<\/strong> maintains or plans to maintain a business relationship, including suppliers, service providers, strategic partners, or agents.<\/p>

Third Parties<\/strong>: A third party is considered any individual or legal entity acting independently from FAE<\/strong>.<\/p>

Bribery<\/strong>: Bribery is the offer, promise, authorization, or acceptance of any undue monetary gift or any other benefit or advantage to a public official, directly or indirectly, with the aim of obtaining or retaining business or any other improper benefit or advantage.<\/p>

Bribery also includes receiving, requesting, offering, or accepting an unjustified benefit or advantage, in one\u2019s own name or through an intermediary, in exchange for unduly favoring another in the acquisition or sale of goods, procurement of services, or commercial relationships.<\/p>

Corruption<\/strong>: Corruption consists of the abuse of power for personal gain.<\/p>

Conflict of Interest<\/strong>: A conflict of interest is considered any situation in which the personal interests of a member of the organization may interfere in such a way that their professional decision-making, on behalf of or for the organization, is compromised.<\/p>

Public Officia<\/strong>l: For the purposes of this Policy, a public official is any person who, by law, election, or appointment by a competent authority, participates in the exercise of public functions or is employed by any government entity, public company, or entity financed with public funds, at the local, regional, national, or international level. This definition includes any candidate or person running for public office. <\/p>

FAE<\/strong>: For the purposes of this Policy, any reference to FAE<\/strong> applies to both FRANCISCO ALBERO SAU<\/strong> and FAE CERVERA SL<\/strong> and may be extended to any business partner of these two companies, as required by the Ethics and Compliance Committee. In this regard, all representatives and collaborators of the aforementioned companies must comply with this Policy. <\/p>

Purpose of the Anti-Corruption Policy<\/strong><\/h3>

This Policy aims to reaffirm FAE<\/strong>\u2019s commitment to complying with ethical standards in the selection, offering, and receipt of corporate gifts and hospitality within the legal framework.<\/p>

In this regard, FAE<\/strong> promotes the establishment of business relationships in an ethical, transparent manner and in compliance with the law.<\/p>

This Policy is issued in furtherance of FAE<\/strong>\u2019s Code of Ethics and Conduct and forms part of the Criminal Compliance Management System, following the guidelines of the international standard ISO-UNE 37001 on Anti-Bribery Management Systems.<\/p>

Scope of Application<\/strong><\/h3>

This Policy is mandatory for all executives, employees, and individuals under an employment relationship or who, in any way, perform activities on behalf of FAE<\/strong>, regardless of their position or role.<\/p>


This Policy also applies to individuals or legal entities that engage with FAE<\/strong>. The Ethics and Compliance Committee<\/strong> will determine in which cases control measures must be implemented in this regard. <\/p>

The Anti-Corruption Policy will be available to all obligated parties and to any third party with a legitimate interest in it.<\/p>

Acceptable corporate gifts and hospitality<\/strong><\/h3>

Obligated parties may accept or offer a gift or hospitality, provided that:<\/p>