On 30 March 2017, SEMI Group approved a Corporate Compliance Programme.
This Programme describes in a structured way the measures that SEMI Group has arranged with the main purpose of creating an environment of prevention, detection and early management of criminal risks, contributing to generate an ethical culture and respect for the Law.
That is why SEMI has taken an active role in the fight against crime and thereby also adopts the technical, organizational and specific personal measures, as well as surveillance and control measures, and the appropriate penalty system for avoiding the production of infringements or illegal actions.
Compliance Policies and Procedures
In this context and, in order to comply with this objective, SEMI Group has internally published the following documents:
- ACS Code of Conduct
- ACS Industrial General Protocols
- Framework Protocol
- Regulatory Compliance Protocol
- Protocol for Reporting Suspected Irregular Activities
- Corporate Defense Procedure Activation Protocol
- Protocol on Training of Professionals in Regulatory Compliance Issues
- Statute of the Legal Compliance Body- Protocol on the profile, experience and organic location of Legal Compliance Body, Corporate Compliance Officer and the Corporate Compliance Delegate
- Protocol for Core Policies
- Catalogue of Forbidden Conducts and Expected Behaviors
- Code of Conduct for Business Partners
- Protocol for Compliance with Competition Standards
- Corporate Due Diligence Protocol regarding Human Rights
- Information Security Protocol
- Internal System Regulations
- SEMI Crime Prevention Plan and the corresponding attached Policies and Protocols:
- Criminal, Anti-Bribery Compliance and Behaviors Against to the Defense of the Competition Policy
- Policy on IT Conduct
- Policy on Business Courtesies
- Policy on Prevention of Money Laundering and the Financing of Terrorism
- Anti-corruption Policy
- Policy on Intellectual and Industrial Property Rights
- Confidential Treatment and Sensitive Commercial Information Policy
- Personal Data Protection Policy
- Environmental Protection Policy
- Protocol against Workplace Mobbing or discrimination
- Protocol against Sexual Mobbing or discrimination
Anyone who has knowledge or suspects of any type of infraction, illegal action, inappropriate behavior, etc. may use, in addition to the internal report to the hierarchical superior or the Corporate Compliance Officer, the different reporting channels enabled:
- Email: email@example.com
- Voicemail: +34 91 820 52 75
- Ordinary post: Canal Ético, Grupo SEMI, Avenida Manoteras, nº 6, 28050, Madrid (Spain), to the attention of the Compliance Officer.
These channels are both a way of denouncing the breach of legislation or internal regulations, as well as of resolving a consultation that may arise in the development of the organization’s activity, ensuring always the confidentiality and the absence of retaliation for the filing of a complaint.