Criminal Compliance Policy

SICOMORO INTEGRAL SERVICES, S.L. (hereinafter SICOMORO) is a company in the Information and Communication Technologies sector, whose business activities are oriented towards cultural and leisure centers and are as follows: Management services and “call center” for the sale of tickets, access controls and marketing, development, implementation and maintenance of software solutions.

Our vision is described as a company that performs these services in a reliable, secure, solid, flexible and profitable way, with management that anticipates and adapts to change, learns from experience and constantly innovates.

We define some VALUES to share, which always take into account key aspects in the management of LEGAL COMPLIANCE, specifically in the criminal field, which allow us to develop a company culture, a way of working and making decisions in our organization, which are the following:

We demand compliance with the criminal legislation applicable to the company.
We are aligned and will be congruent with the goals of the organization
We will identify the activities in which the crimes that must be prevented can be committed.
We prohibit the commission of criminal acts.
We minimize the organization’s exposure to criminal risks.

Thus, SICOMORO undertakes to develop, implement, maintain and continuously improve its CRIMINAL COMPLIANCE Management System (SGCP) with the aim of continuous improvement in the way in which we provide our services and in the way in which we comply with the inherent legality of our clients and our organization. Therefore, it is SICOMORO’s policy that:

Criminal Compliance objectives are established and reviewed annually.
Business, legal or regulatory requirements and contractual obligations and this Criminal Compliance policy are complied with.
Training and awareness activities are carried out in terms of Criminal Compliance processes for all staff.
The necessary means are established to guarantee the continuity of the SGCP.
A process for analyzing the risk of compliance with criminal offenses is developed.
Treatment plans and corresponding controls are established to mitigate the risks detected.
The responsibility of employees is established in relation to:
report suspicious facts or behaviors related to criminal risks
preserve the confidentiality, integrity and availability of the informant, guaranteeing that he does not suffer reprisals in compliance with this policy
and comply with the policies and procedures inherent to the Criminal Compliance Management System.

The representative of the company’s Governing Body is directly responsible for maintaining this policy, and may be advised by a Compliance Body that will provide advice and guidance for its implementation.