COMMITMENT TO ETHICAL AND LEGAL COMPLIANCE

Anti-corruption measures

1) ESIC and its stakeholders (employees, students, clients, suppliers, collaborators, and society in general) undertake that, in the execution of their joint activities, they will comply with and enforce at all times the legislation on money laundering, terrorist financing, fraud, business corruption, influence peddling, bribery, and, in general, with the applicable criminal legislation and any other regulations applicable to the relationship between the parties. In particular, and without prejudice to compliance with the other obligations imposed by current legislation, the parties, in the execution of such activities, will refrain from carrying out the following actions, either personally or through an intermediary:

• Promising, offering or granting to directors, managers, employees or collaborators of the interested parties any unjustified benefit or advantage of any nature, for themselves or for third parties, as consideration for unduly favoring them or a third party over others in the acquisition or sale of goods, contracting of services or in commercial relations.
• Promising, offering, or granting any undue benefit or advantage, whether monetary or otherwise, to any public authority, official, or employee for the benefit of the latter or a third party, or responding to their requests in this regard, in order for them to act or refrain from acting in relation to the exercise of public functions in order to obtain or retain any advantage in relation to the fulfillment of the Contract entered into with any of the parties or their related companies/entities.

2) All workers affected by the subject matter of this contract/agreement (whether own or subcontracted personnel and similar personnel) will be aware of the existence of an ESIC "Code of Ethics", which must be followed by the parties, accessible at:

https://www.esic.edu/themes/esic/pdfs/A4_CODIGO_ETICO_ESIC_2022.pdf

3) The parties undertake, during the term of the contracts or agreements that bind them and during the subsequent period of prescription of the actions derived from the same, to:

Maintain accurate and reasonably detailed financial books and records relating to the activities performed.

• Maintain, throughout the duration of the relationship between the parties, their own policies or procedures to ensure compliance with ethical and anti-corruption standards and provide reasonable assurances that violations of such standards will be prevented, detected, and corrected.
• To report without delay any violation of their obligations under the relationship between the parties. In such cases, the parties reserve the right to require each other to immediately adopt appropriate corrective measures and, where appropriate, to inform the competent authorities of the conduct detected.
• To verify the other party's compliance with its obligations and representations during their contractual or conventional relationship. The parties shall fully cooperate in any audit, review, or investigation conducted by or on behalf of the other party.

4) In addition to the Code of Ethics , ESIC has approved a General Regulatory Compliance Policy that includes its Code of Good Governance and Code of Good Practices , as well as Protocols against discrimination and harassment in its various communities and areas . The parties undertake to accept, comply with, and enforce these Codes and Protocols, through the contracts or agreements signed with ESIC or through their separate acceptance or communication, in order to maintain their commitment to avoid ethically reprehensible or illegal actions or those that go against shared values. These policies and protocols will be available at the links indicated in this paragraph:

https://www.esic.edu/sites/default/files/2023-05/POLITICA_GENERAL_CUMPLIMIENTO_NORMATIVO.pdf
https://www.esic.edu/sites/default/files/2023-05/CODIGO_BUEN%20GOBIERNO.pdf
https://www.esic.edu/sites/default/files/2023-05/CODIGO_BUENAS_PRACTICAS.pdf
https://www.esic.edu/sites/default/files/2023-08/06_202302_EU%20protocolo%20acoso%20universitaria.pdf
https://www.esic.edu/sites/default/files/2023-06/protocolo_acoso_educativa.pdf

Corporate Social Responsibility (CSR – ESG)

ESIC and its stakeholders are committed to a mission and values aligned with Social Responsibility, promoting the development of ethics and corporate social responsibility in the academic, social, business, and research fields. More information on this topic is available on their websites.

The parties declare that they will make efficient use of resources, such as electricity and water; they will strictly comply with the environmental legal requirements applicable to the development of their activities; they will undertake, at all times, to minimize the nuisance that their activities may cause to the environment; they have the appropriate measures necessary to prevent accidents or incidents with environmental repercussions; all their personnel, as well as those of the subcontracted companies, are duly aware of the established environmental regulations, and cannot allege ignorance or lack of knowledge of the same in any case.

The parties declare that, in the performance of their activities, they respect the labor and trade union rights of their employees, do not use child labor, reject any form of forced labor, prohibit any type of discrimination, comply with legislation on occupational risk prevention, and ensure the safety of their employees in the performance of their professional duties. Furthermore, ESIC is firmly committed to social responsibility, sustainability (SDG 2030), and the environment:

https://www.esic.edu/institucion/responsabilidad-social-esic
https://www.esic.edu/institucion/sostenibilidad-y-ods
https://www.esic.edu/institucion/sostenibilidad/impacto-medioambiental

Internal Information System and channel for violations

The channels that ESIC has implemented for any communication regarding regulatory compliance are: Direct Communication at the highest hierarchical level; Direct Communication to the Regulatory Compliance Department ( canaletico@esic.edu ); Direct Communication through the enabled telematic channels for queries and reporting of infractions (intranet and Web https://www.esic.edu/contacto-esic or Internal Information System | Business School and Official Center | ESIC

Violation of the agreement

If any of the provisions herein are violated, or any of the obligations, representations, or warranties set forth in this declaration are breached or defectively fulfilled, the parties may unilaterally terminate the contract/agreement between them without incurring any penalty. If the breach of this clause causes harm to the parties—including harm resulting from the subsequent termination of the contractual or conventional relationship—they may seek compensation, without prejudice to reporting violations to the competent entities or authorities.

This commitment is written in Spanish (any translation into another language is considered unofficial), will remain accessible via the Internet on this website and must be interpreted in accordance with Spanish regulations. This text completes and complements the agreements signed by the entities of the ESIC network and the provisions of the ESIC Legal, Privacy and Cookies Notice.

The versions of this commitment are available for consultation in the cache stored in the Internet Archive(see).