Compliance

Bossar since 2019 has been implementing and developing an internal structure for the prevention of crimes within the company.

Bossar Packaging, S.A., (hereinafter “Bossar”), has implemented a Crime Prevention Model according to art.31 bis from Spanish Código Penal.

In 2010, with the reform of the Spanish Código Penal, the criminal responsibility of companies was included on it. Later on, in 2015, the need for companies to have organization and management models for crime prevention (Crime Prevention Models) was established.

Bossar since 2019 has been implementing and developing an internal structure for the prevention of crimes within the company.

For this reason we want to inform you about following subjects:

 

1. INTERNAL CONTROL BODY / COMPLIANCE OFFICERS

A multi-person Internal Control Body (ICB) has been created, made up of three Compliance Officers:

  • Antonia Jabalera  (Quality & Project Management Director).
  • Sandra Coronado (Human Resources Responsible)
  • Agustín Mir (Financial, IT & HR Director, and Attorney).

The ICB is in charge of ensuring the coordination and supervision of the operation and compliance of the Crime Prevention Model implemented.

The ICB was also created with the aim of speed up the decision making in matters of compliance, monitoring and operation of the Prevention Model Of Crimes. All this with the aim to have a higher efficiency, agility and effectiveness of the Crime Prevention Model and the creation of a culture of compliance in the company

 

2. ETHICAL CHANNEL

Bossar has created an Ethical Channel as a high-level control measure, in order that any direct member (administrators, employees, professionals and managers) or related (collaborators or suppliers) can communicate any indication or suspicion of commission of a conduct that may involve:

  • Non-compliance with applicable regulations, protocols, procedures, and internal controls
  • Actions that are not in accordance with ethical principles and good business practices
  • Actions that could be criminal

The e-mail used for this is: canaletico@bossar.com

The incidences are received by the ICB and procedures are regulated to avoid conflict of interest, so that the person reported cannot be part of the people involved in the processing of the complaint.

 

3. CONTROL DEVELOPMENT

At Bossar we have proceeded to develop and implement transversal and specific controls to prevent the commission of crimes.

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