Code of Conduct Anti-Bribery and Anti-Corruption

Bribery – is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action. It is illegal, and it is a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain a commercial, contractual, regulatory or personal advantage.

Corruption – Generically speaking corruption is when a person who occupies a dominant position, agrees to receive an undue advantage for the rendering of a service. Corruption can be active or passive depending on whether the act or omission is committed by the person who corrupts or the person who gets corrupt.

One of the fundamental principles of Galamas is to comply with the Code of Conduct Anti-Bribery and Anti-Corruption, which is addressed to all employees, partners, suppliers and employees.

Thus, Galamas undertakes to:

1. Never engage in any form of bribery, either directly or through any third party.

2. Never offer or make an improper payment, or authorise an improper payment (cash or otherwise) to any individual, including any local or foreign official anywhere in the world.

3. Never attempt to induce an individual, or a local or foreign official to act illegally or improperly.

4. Never offer, or accept, money or anything of value, such as gifts, kickbacks or commissions, in connection with the procurement of business or the award of a contract.

5. Never offer or give any gift or token of hospitality to any public employee or government official or representative if there is any expectation or implication for a return favour

6. Never accept any gift from any business partner if there is any suggestion that a return favour will be expected or implied.

7. Never facilitate payments to obtain a level of service which one would not normally be entitled to.

8. Never disregard or fail to report any indication of improper payments to the appropriate authorities.

9. Never induce or assist another individual to break any applicable law or regulation.


Code of Conduct Anti- Cartel

Galamas will not tolerate the practice of a cartel. Involvement in a Cartel is unacceptable and against our main free, fair and competitive market values. This Code of Conduct Anti-Cartel serves to detect and prevent the practice of cartels.

What is a cartel?

A cartel is an agreement or concerted practice between competitors to fix prices, combine business trends, divide or share markets in order to reduce competition and create a monopoly.

A cartel is considered to be one of the most serious violation in most jurisdictions, which can lead to significant fines as well as criminal penalties.

With this Code, Galamas is committed to:

1. Never make direct or indirect contact (through third parties, including agents, suppliers or customers) with a current or potential competitor with the aim of forming a cartel.

2. Never propose or reach an agreement, directly or indirectly, formally or informally, with current or potential competitors, regarding any sensitive to competition-related issues, including:

  • Fixing prices
  • Dividing or sharing markets, customers or territories
  • Manipulating a bidding or a tender process

3. Report to the company’s legal department and / or to the competent authorities any evidence or practice of anticompetitive and inappropriate commercial conduct by a current or potential competitor.

4. Do not attend a trade association meeting where competition sensitive issues are discussed. If such matters are raised during a meeting, Galamas officials should immediately request the end of the meeting. Otherwise, they must leave the meeting and request that this be noted in the minutes of the meeting.

5. Make sure that all internal and external correspondence, including e-mails, texts and documents, debates and public statements, do not contain any statement that could be misinterpreted by third parties, authorities and courts in the context of a potential Anti-Trust Investigation.

6. Maintain independence to settle prices and selling services.

7. Limit any information discussed with business partners or third parties, to what is strictly necessary to complete or evaluate a business.



Code of Conduct and Professional Ethics

All Galamas employees and management bodies must promote internal and external relations with clients, suppliers and entities in general, in a legal, ethical and professional manner, adopting a conduct based on values ​​such as honesty, respect, integrity, Loyalty and equality. These are the values ​​that Galamas honors to keep and guarantees the reputation gained since 1934.

In order to ensure ethical and professional conduct we must:

1. Serve clients with care and dedication, respecting the material and sentimental esteem they have for their assets, always striving to meet their expectations.

2. Always keep in mind the continuous improvement of the service, being transparent in the procedures and taking decisions with exemption, equity and objectivity.

3. Follow a behavior of anti-corruption practices, active or passive, and bribes, in relationships with Customers, Suppliers and other Entities, for example any form of payments, favors and complicity that may lead to the creation of illicit advantages, such as offers or improper payments from customers or suppliers.

4. Adopt practices in a way that avoids conflicts of interests, respecting the legal framework and internal rules, not carrying out activities for personal interest that overlap or that are contrary to Galamas interests.

5. Ensure professional secrecy regarding internal and clients information, which should not be for public knowledge, acting with discretion concerning to facts and information that have been provided to us during the exercise of our duties, fully respecting the Commitment of confidentiality.

6. Respect and protect human rights by adopting non-discriminatory behavior on the basis of race, ethnicity, sex, age, disability, religion, opinion or political affiliation, condemning any form of harassment, verbal or physical humiliation and coercion or threat.

7. Respect national and international rules and conventions concerning the activity and the workers rights and duties.

8. Fight against attitudes and behaviors that may jeopardize Galamas image and prestige.

9. Ensure compliance with safety, health, hygiene and well-being rules in the workplace, notifying the supervisors whenever any irregular situation detected can jeopardize the safety of people, facilities, equipment, and goods in general.

10. Contribute to sustainable development and to the preservation of the environment, giving priority to non-polluting practices and energy saving.

11. Ensure the protection and keep in good condition the company’s assets using Galamas resources efficiently, in order to achieve the defined objectives and not for personal or other purposes.

12. Maintain a good relationship with colleagues, hierarchical superiors and subordinates, in a responsible and cooperative way, giving priority to good environment, respect and good personal treatment.

Privacy and Personal Data Protection Policy

Safeguarding the privacy of personal information is essential in any business but particularly in ours. Organizations increasingly gather personal information as business systems and processes become more complex and sophisticated. Personal information has therefore become more vulnerable to ​​a variety of risks, namely its loss, undue use, unauthorised access and unauthorised disclosure.

Safeguarding the privacy of our clients’ personal information (individuals or organizations), and of suppliers, workers and entities in general with whom we do business, is fundamental.

Inadequate privacy policies and procedures lead to the following risks:

– Bad reputation of the company;
– Legal liability and penalties applied by the regulatory authority;
– Charges due to misleading commercial practices;
– Mistrust of the clients, suppliers and workers;
– Lack of consent of individuals and organizations regarding the use of their personal details;
– Loss of business and consequent reduction in revenue and market share;
– Interruption of international commercial operations;
– Liability resulting from identity theft.

So, besides respecting legislation, Galamas has adopted management practices regarding the information gathered, used, kept, disclosed and deleted in order to guarantee its privacy.


Some examples of personal information or information considered to be sensitive:

– Names;
– Telephone numbers;
– Home or e-mail address;
– Date of birth;
– Personal Identification, Taxpayer and Social Security Number;
– A person’s physical characteristics;
– Information on health or medical conditions;
– Financial information;
– Race or ethnic origin;
– Political opinions;
– Religious or philosophical beliefs;
– Trade union membership;
– Sexual preference;
– Information related with criminal offences or criminal convictions.


In its relations with third parties (clients, suppliers, workers and entities in general) Galamas discloses its “Privacy and Personal Data Protection Policy” through the site and a “Notification” (1) in its e-mails, warning about the fulfilment of its privacy rules.

Some information is subject to “Confidentiality” (e.g. e-mails), which is different from “Personal information”, which is usually defined at law or by regulations. Normally confidential information is defined in contracts and in documents. In the course of business dealings, some information is confidential, for example:

– Business details and plans;
– Bank details;
– Quotes/estimates;
– Prices;
– Legal documents;
– Accounting records.

There is also a difference between “Explicit” consent and “Implicit” consent in the use of information. Consent is considered to be “Explicit” when it specifies the purpose, to whom it is addressed, who can disclose it, etc. “Implicit” consent is unspecified consent, which is not expressly granted by a person or company, but which is understood through a person’s or company’s actions and from the facts and circumstances of a particular situation.

In order to ensure the privacy of the personal details of the owner of the information (of clients, suppliers, workers and entities in general) Galamas adopts the following measures regarding information gathered, used, kept, disclosed and deleted:

– information is gathered by all of Galamas’ workers who have access to it, because it was given to them or because they requested it in the course of their duties;

– information should be used only by workers who need it to perform their job and only for the intended purpose;

– information gathered should be kept in a safe place, trusted by each worker and guaranteeing its privacy from parties unrelated to the processes and only for as long as necessary or as required by law;

– information may be disclosed with the explicit consent of its owner, or rather, the owner of the information specifies what information may be disclosed, or implicitly, when its disclosure was not specified but has to be obligatorily used for the process to develop or to protect the client’s interests. Information may be disclosed to the competent authorities pursuant to the law;

– information is deleted when the declared objectives inherent to the processes were realised or when the periods required at law and by regulations were reached.