ETHICAL CODE

Our professional conscience: we work with honesty and sincerity to produce communication characterized by a high level of creativity, respecting the consumer and achieving the goals set by our client for their brand, product or company.

Respect: towards our employees, clients and their brands, consumers, laws, languages and cultures, our suppliers and, more generally, human rights, labour law and the environment.

Humanity: we must treat our employees responsibly and with respect.

CREATIVITY

Our passion and our duty: Those who work in advertising and communication should do so out of passion. It is a demanding profession that requires honesty, fairness, commitment, hard work and credibility from those who do it. Above all, it requires the ability to leave the beaten path, be original and know how to surprise and arouse interest to sell the advertised product, brand or service.

Creativity is not limited to advertising and communication campaigns. It must be present in everything we do, in our strategies and in everything we produce, at all levels and in all sectors. There is no place in what we produce for what is ‘average’, and our work should contribute to making life better.

RESPONSIBILITY TOWARDS OUR CLIENTS

Our clients are our most important asset. Our constant responsibility and most urgent goal is to create value for our clients and to serve their goals by giving our best in terms of creativity, service, innovation and performance.

We must always be vigilant to ensure that our work and the information we hold on our clients remain strictly confidential.

We must always focus on the client, their brands and products and not seek the limelight at the expense of the client or the effectiveness of their advertising and communication.

We must strictly respect contracts with our clients just as our clients respect their contractual obligations to Alecria.

Our actions must be guided by the utmost attention to clients’ interests. We must always be available to respond quickly and effectively to their requests and to anticipate their expectations. We must have respect for the money they invest in advertising and communication and ensure they achieve the best results in terms of both profit and image.

Most importantly, we must have the will to develop and grow with our clients and never lose touch with their concerns, needs and ambitions.

RESPONSIBILITY TOWARDS OUR STAFF

Our employees are the future of our business. They must be chosen for their professional qualities without exclusion, preferential treatment or discrimination. Respect for people and their diversity is the basis for building the Alecria employee community.

Our employees are the living expression of Alecria’s values. Although professional qualities and talent are of enormous importance, we must also consider the human qualities and behavioural aspects of our employees. We must work together and communicate with each other in a professional, respectful and trusting manner.

Personal information on each employee must be treated confidentially.

 

Alecria is committed to developing the professional skills and capabilities of its employees through training, enabling them to reach the highest quality levels in the performance of their work and increasing their ‘spendability’ within the company. Alecria aspires to be the best employer and to create the best workplace in the industry.

RESPONSIBILITY TOWARDS OUR MEMBERS

Our members create the conditions for the development of our business. To continue existing and growing, Alecria must add value and generate profits for its members, who expect a good return on their investments. It is our task to generate profits in a way that rewards our members for their financial commitment and trust in us.

We must regularly provide our members with information that is reliable, accurate, honest and in compliance with the law on corporate matters.

The accuracy of our financial reports and, more generally, of the information we provide to members is of utmost importance, because our credibility rests on it.

It is the responsibility of all employees to contribute to the accuracy of Alecria’s accounts and financial reports.

And it is our responsibility to treat all our members fairly.

RESPONSIBILITY TOWARDS THE PUBLIC

The public determines our success when it demonstrates that it appreciates our work. The consumers of our clients’ products and/or services, and more generally the public, although they have no contract with us, are the ones who determine, with their reactions, the success of our creative work and many of our initiatives.

All our work must be honest, legal, truthful and respectful of consumers, their sensitivities and diversity.

RESPONSIBILITY TOWARDS THE COMMUNITY

Alecria strictly respects the culture of the countries in which it operates and takes great care not to offend local values or moral codes. It is always ready to put its expertise in communication and advertising at the service of local communities, both socially and economically.

RESPONSIBILITIES TOWARDS SUPPLIERS

Our suppliers are our partners We have a duty to demand that our suppliers meet the highest quality standards in terms of service, performance and price. This duty is indeed an obligation not to compromise and to work only with the best suppliers at the best conditions in each sector.

In return, Alecria regards its suppliers as partners with respect for their professionalism, autonomy and independence. The choice of our partners must be based exclusively on the desire to guarantee Alecria the best service, at the most advantageous market price. Any other factor must be excluded. New relationships must be the result of tender processes in which the same conditions are ensured for all suppliers.

Orders to suppliers must be in writing.

Discounts applied by suppliers must be compatible with current regulations and legislation. They may only be requested or accepted if they are part of normal business relations and do not violate the contracts that bind us to our clients.

 

Contracts with suppliers must be transparent and regulate all obligations and commitments undertaken by both parties.

REFUSAL TO ENGAGE IN PARTISAN CAMPAIGNS

We believe in fairness. While we are always ready to put our communication talents at the service of advertisers, the community and the public through NGOs, we do not work for a political party, sect or organisation that carries out ideological or partisan propaganda.

COST CONTROL

Sensible costs mean maximum investment. We must ensure that overheads are limited to the bare minimum. Any shortfall in this area constitutes a misappropriation of Alecria’s resources and reduces the ability to invest and grow.

Particular attention must be paid to Alecria’s rules on travel and other expenses as set out in this document.

INTERNAL CONTROL

We have put in place internal control systems to ensure compliance with Alecria’s rules. Respect for people is at the core of our values and we need to ensure that all people within Alecria feel respected and valued regardless of their level of responsibility.

RULES OF CONDUCT

Objective: To define the rules of conduct to be observed by employees.

Rules and Procedures

Respect for the law: The company and their employees must act in compliance with the laws and regulations in force in the country in which they operate.

Honesty and transparency: Employees must behave in a fair and honest manner with clients, partners and strive to develop sustainable and trustworthy relationships. Employees shall act in an ethically correct and irreproachable manner.

Respect for employees’ rights: Alecria must ensure that the rights of employees are respected. It must not engage in discriminatory behaviour when hiring or towards employees, nor commit harassment of any kind, and must treat all employees with dignity without discrimination based on gender, race, religion, etc., and must not take advantage of its position to obtain favours from an employee or secure favours by virtue of personal relationships.

Professional commitment: All employees must perform their work to the best of their abilities, in a spirit of mutual support.

Alecria’s opportunities: employees must not

(a) take personal advantage of opportunities they have become aware of using Alecria’s assets or information or by virtue of their position

(b) use Alecria’s property or information, or their position within the company, for personal gain

(c) compete with Alecria.

Employees have a duty to promote the legitimate interests of Alecria whenever the opportunity arises.

Confidentiality: Employees shall not use confidential information relating to Alecria or its clients, nor disclose it to third parties or other employees not authorised to acquire such information.

Fair dealing: Employees shall deal fairly with clients, suppliers, competitors and other employees. No employee may take unfair advantage, through manipulation, concealment, misuse of privileged information, misrepresentation of material facts, or other misconduct.

Protection and proper use of the company’s assets: Employees are required to safeguard the company’s assets and ensure their efficient use. Theft, negligence and waste directly affect the company’s profitability. The company’s assets must be used for legitimate business purposes.

Conflict of interest: Employees must avoid any situation of conflict, real or perceived, between the interests of the company and their personal interests, or the interests of their family members or friends. A conflict-of-interest situation arises when an employee acts or holds interests that make it difficult for him/her to work for the company objectively and effectively. Conflict-of-interest situations also arise when an employee, or a member of his or her family, obtains improper personal advantages by virtue of his or her position within Alecria. Employees have a duty to avoid financial or other relationships that could adversely affect Alecria by causing a conflict of interest. Employees may not hold shares in companies, suppliers or clients, with which they deal as employees.

If a situation of possible conflict of interest arises, employees are required to inform their direct superior immediately, who will then inform the Managing Director.

Employees are encouraged to report any illegal or unethical behaviour (including violations of these Rules of Conduct): When in doubt about the best thing to do in a certain situation, employees should contact management. Employees are also encouraged to report any violations of laws, regulations or rules of the Code of Conduct to the appropriate persons. All reports will be handled confidentially and, consistent with the investigation, the identity of the person who reported the matter will not be disclosed. The company will not allow retaliation for well-intentioned reports.

HARASSMENT AND VIOLENCE IN THE WORKPLACE

Objective: To establish the Code of Conduct on harassment and violence in the workplace.

Scope: All components of the Company.

Rules and Procedures

Harassment: To guarantee employees a working environment in which there is no room for any kind of harassment, Alecria strictly forbids any verbally, physically or visually offensive behaviour, including humiliating racially or ethnically motivated comments and unwanted approaches with sexual connotations.

Alecria prohibits any forceful harassment by superiors, co-workers, consultants, suppliers, clients or other third parties with whom it has business dealings.

Reports of harassment incidents will be promptly verified and, if the investigation confirms that the report is well-founded, necessary action will be taken promptly.

Employees who wish to report an incident of harassment should contact management or their direct supervisor. It is important that incidents of harassment are reported promptly, so that management can react by dealing with the matter responsibly.

Violence in the workplace: It is the responsibility of every employee to help identify cases of violence or possible violence in the workplace, such as threats or acts of violence against employees and/or property. Management must be ready to act on reports of violence or possible violence made by employees.

If management becomes aware of a possible or probable act of violence, it must take appropriate measures to eliminate or limit the risks while it is preparing to deal with the case.

Anyone who threatens or commits an act of violence against Alecria property will be removed as soon as it is safe to do so and will remain away from the company until the outcome of the investigation into the incident.

COMPLIANCE WITH LAWS AND REGULATIONS

Objective: To ensure that all Alecria activities are carried out in compliance with all applicable laws and regulations.

Alecria wants to ensure that all employees do their work within the law.

Rules and Procedures

All parts of the company and its employees are required to comply with all laws and regulations in force in the country in which it operates.

Employees are expected to comply with laws and regulations, not only because it is their duty as citizens, but also because violating laws and regulations can expose Alecria to litigation, sanctions and significant damages. Any violations of the law by employees will be dealt with by Alecria in accordance with the principles and procedures in force as well as the rules on labour discipline.

FRAUD

Objective: To define the Code of Conduct in relation to the prevention, reporting and verification of fraud cases.

Rules and Procedures

Fraud is defined as ‘the theft or misuse of company or client resources by management, employees or third parties; intentional misrepresentation of the company’s financial position or intentional misrepresentation leading to financial losses or misleading financial reporting’.

There are therefore two types of fraud:

• theft or misuse of company or client resources
• fraudulent financial reporting.

All cases of theft or misuse of company or client resources, and all cases of fraudulent financial reporting, if confirmed by investigation constitute serious offences and lead to disciplinary proceedings, which generally result in the employee’s dismissal for cause and, if appropriate, criminal or civil proceedings.

Reporting cases of fraud to the competent authorities within the company

All employees are required to immediately report any suspicions of possible fraudulent activity to management and one of the following:

– direct superior of the employee

– finance office

– Company management

All reported cases will be treated confidentially. Employees can rest assured that, if the report is made in good faith, there will be no negative consequences, direct or indirect, for them as a result of having expressed their suspicion.

Verification of fraud reports

The Management must thoroughly and promptly examine all cases submitted to it, if necessary, asking for legal advice to an independent legal counsel.

It is the management’s responsibility to ensure that the investigation team has all the necessary assistance and authority to carry out its work, while maintaining the utmost confidentiality.

At the end of its work, the Management, based on its conclusions, will assess whether disciplinary or other action is necessary to protect Alecria, and will work to ensure that there is a sufficient level of internal control to avoid similar incidents in the future.