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Compliance

SUMA CAPITAL S.G.E.I.C., S.A. (hereinafter “SUMA CAPITAL”) has implemented a Crime Prevention Model, as per the provisions of art. 31 bis of the Spanish Criminal Code.

In 2010, with the reformed Criminal Code, Spain introduced corporate criminal liability. After that, in 2015, the requirement was established for companies to have an organisation and management model to prevent criminal acts (Crime Prevention Model).

Since 2020, SUMA CAPITAL has implemented and developed an internal structure to prevent the commission of crime in the company.

As such, we hereby notify you of the following:

 

1. INTERNAL OVERSIGHT BODY / COMPLIANCE OFFICER

The company has established a single-position INTERNAL OVERSIGHT BODY (IOB) comprising one Compliance Officer.

The IOB is the body charged with ensuring coordination and oversight of functioning of and compliance with the Crime Prevention Model implemented.

Likewise, a COMPLIANCE COMMITTEE has been set up to make day-to-day decision-making regarding compliance more agile, to monitor this and report to the corporate Governing Body on the development and functioning of the Crime Prevention Model. All in order to ensure greater efficiency, agility and effectiveness of the Crime Prevention Model and a culture of compliance inside the organisation.

The COMPLIANCE COMMITTEE is made up of the Compliance Officer and two members of the Board of Directors.

 

2. WHISTLEBLOWER CHANNEL

SUMA CAPITAL has set up a channel for whistleblowers (canaldenuncias@sumacapital.com) as a high-level oversight measure, so that any direct member (administrators, employees, professionals or executives) or associate (collaborators or suppliers) can report any indication or suspicion of behaviour that may constitute:

  • A failure to comply with applicable regulations, protocols, procedures or internal controls.
  • The commission of acts that are not in line with ethics and good practices of business.
  • The commission of acts that could be criminal.

The reports are sent to the Compliance Officer and an external advisor and governed by procedures to prevent conflict of interest, so the reported individual can never be involved in processing the report.

 

3. OVERSIGHT

SUMA CAPITAL has developed and implemented transversal and specific oversight measures to prevent the commission of crimes.