Code of Conduct
1 - Introduction
The Fabrica Nacional de Moneda y Timbre - Real Casa de la Moneda (FNMT-RCM) has developed during the course of its existence a series of values that form the basic framework for the implementation of its products and services for the general public. These values are:
- Security: All the Corporation's activities are based on integrated security, which is applied to the production processes, the products, the treatment of information and to its plant and personnel.
- Professionalism: The commitment to honest, responsible and efficient performance in following its course of action focused on the achievement of excellence.
- Quality: The FNMT-RCM has a commitment to quality that governs the Corporation's daily activity, covering and meeting the needs of the ultimate users of our products and services and promoting the practice of ongoing improvement.
- Confidentiality: All corporate personnel practice criteria of discretion and caution in the treatment of information and in their communications with third parties.
- Sustainable Growth: This is understood to be industrial development in a manner compatible with the environment and with environmentally friendly policies.
- Technological Upgrading: Intended to equip the FNMT-RCM products and services with the newest and optimum technological upgrades and in accord with the funds available for R&D&I.
- The assurance of collaboration with public administrations and agencies: So as to provide companies and citizens with the most favourable conditions for access to the public services related to the activity of the FNMT-RCM.
2 - Objective
This Code of Conduct is founded on the growing demand from the general public for initiatives and practices relating to Corporative Social Responsibility. Its objective is to serve as a guideline for the manner in which internal and external relations are maintained, by reinforcing the values that constitute corporate marks of identity.
3 - Scope of Application
The standards of behaviour anticipated in this Code are binding on all managers and employees of the FNMT-RCM, and they shall in turn be observed by the Corporation's collaborating companies or contractors who shall undertake to transmit these standards of conduct to their own managers and employees, as well as to any sub-contractors involved in the invitations to bid with the FNMT-RCM; all of this in accordance with the legal instruments that regulate the relevant contractual relationships.
4 - Follow-up and control of the application of the Code of Conduct
The body responsible for the follow-up and control of the application of this Code of Conduct and, as applicable, for the preparation of proposals regarding its modification or review, shall be the Code of Conduct Follow-up Committee1.
The interpretation of the Code of Conduct is the responsibility of the Management Committee.
Any employee of FNMT-RCM or any other stakeholder may report any irregularity detected in respect of compliance with the principles and obligations set down in the Code of Conduct, in addition to making queries and suggestions as to its application. Such information, queries and suggestions shall be addressed to the Code of Conduct Follow-up Committee.
When reporting an alleged case of non-compliance with the Code of Conduct, it is necessary to complete the questionnaire which is available at http://portal.fnmt.es/formulariosFirma. This ensures that the matter will be processed with the utmost security and confidentiality.
The system will guarantee strict confidentiality and no anonymous communications shall be admitted. The identity of persons making use of this email account may be known solely to the members of the Follow-up Committee and to the employees engaged in the internal backup system.
This channel may be used solely for the purpose of submitting information, queries and suggestions related to the Code of Conduct.
For the information received to be considered as valid, the following must be provided:
- Name, surnames and identity number or employee number of the sender.
- Arguments or reliable, accurate proof as to failure to comply with the pertinent section of the Code of Conduct.
- Person or group to whom the alleged case of non-compliance refers.
The Follow-up Committee shall analyse the information submitted, request the relevant proof and present the dossiers with all the information in its possession to the Chairman of FNMT-RCM, together with the proposals or recommendations as to those measures which, in its opinion, ought to be put in place so as to prevent similar situations from arising in the future.
The highest-ranking competent body shall adopt the appropriate decisions or measures in accordance with labour regulations in force, regardless of any administrative or criminal responsibilities, which may derive therefrom. In this case, the courts, the Public Prosecutor's Office or to the competent authority that corresponds will be informed to proceed accordingly.
(1) The Code of Conduct Follow-up Committee shall be formed by the Human Resources Manager, the Secretary General and the Internal Audit and Quality Control Manager.
5 - Standards concerning the performance of the work
1. Equal opportunity
The FNMT-RCM shall select and promote its managers and employees in accordance with the principles of merit and capacity and it shall encourage equal treatment of both men and women. In addition, it shall foster equal opportunity and shall not discriminate by race, gender, civil status, sexual orientation, ideology, religion, nationality, disability or any other personal condition.
2. Professional conduct. Quality
The managers and employees of the FNMT-RCM shall perform their work in keeping with the general principles of integrity, honesty and transparency and they shall act with dedication and diligence.
They shall comply with the established quality standards, undertaking to proceed in accordance with their responsibilities and practicing ongoing improvement and adaptation to new technologies, as set out in the Business Plan of the Entity, with a view to attaining the complete satisfaction of the customer.
3. Training policy
The FNMT-RCM shall promote the training of its staff, both in technical and behavioural aspects, promoting equal opportunities, through the detection of gaps in function of an array of qualifications for each job, as well as a skills development plan based on communication and mutual trust between each employee and his superior.
The managers and employees of the FNMT-RCM shall undertake to refresh their managerial and technical skills in order to develop their abilities, and to utilize the training programs provided by the corporation for the purpose of enhancing their professional development and adding value to the corporation's products and services.
4. Incompatibility of occupations
The managers and personnel of the FNMT-RCM are subject to the rule of incompatibility established by Law 53/84 on Incompatible Occupations of Personnel in the Service of the Public Administrations, and to any subsequent rulings arising from said law.
In accordance with Article 19 of Law 53/84, the classification of incompatible occupations shall exclude, "collaboration with and occasional attendance at congresses, seminars, conferences or courses of a professional nature". This activity, and the other activities affected by this regulation, is subject to the terms set out in point 7.2 UTILIZATION OF THE FNMT NAME AND LOGO.
5. Conflicts of interest
The managers and employees of the FNMT-RCM shall avoid situations that could lead to a conflict of interest. A conflict of interest would occur when the private interests of the managers and employees, or the interests of persons related to said managers and employees interfere with their duties and responsibilities within the Corporation.
Related persons are considered to be: the spouse or the person with whom the professional has a like relationship of affection, the ascendants, the descendants down to the fourth degree of kinship, or the third degree of affinity, the blood siblings and the spouses of the ascendants, descendants, and siblings, and for the above-mentioned purposes shall include de facto unions and other similar relationships under the terms anticipated in the applicable law.
Also, shall be considered as related the companies or entities in which the employee or director, or any of the persons connected thereto, directly or through a nominee, is in any of the situations referred to in the first paragraph of Article 42 of the Code of Commerce2.
In these cases any manager or employee affected by a conflict of interest while performing his work shall refrain from any decision-making and, in the event of any uncertainty concerning the possible conflict of interest, the person concerned shall notify his immediate superior.
No manager or employee of the FNMT-RCM may bid in selection processes for the contract award of goods or services intended for the Corporation or in processes for the disposal of the Corporation's property or any assets that they may be in charge of managing, either directly or via associated parties.
6. Safety and Health in the workplace
One of the basic objectives of the FNMT-RCM is the appropriate organization of safety and health in the workplace. To do this the Corporation complies with the accident prevention laws applicable to its business locations in addition to putting into practice ongoing improvement in risk control and staff working conditions.
At the same time, expresses its total rejection of practices of harassment or mobbing, both in its psychological or sexual aspects because of gender, strongly expressing their willingness to make a commitment to not tolerate any of the above situations.
Managers and employees must be familiar with, comply with and enforce the regulations that are designed to protect the health and safety of the workers and of everyone affected in the course of their activities (clients, suppliers, collaborators, subcontractors, etc.), and they must ensure that the workplaces are kept safe and healthy, as well as eradicate any behaviour that may be considered harassment.
Due to the nature of the activity performed by the FNMT-RCM, information is an important asset in the Corporation and, as such, it should be given special treatment.
All information (that is not public knowledge) utilized or generated by the activity of the Corporation, and related to the products, services, clients, suppliers, personnel, working methods, organization, corporate strategies, financial information, etc., is considered to be "Confidential" in accordance with the procedure “ES .SI.02.00001 Standard of classification of the Information according to its confidentiality" and subsequent updates.
The handling of this confidential information shall be restricted to those persons who need to use it in carrying out their work within the Corporation. These shall not be disclosed to third parties except for the information or technical specifications that need to be provided to suppliers for the contracting of goods and services, in which case an identical commitment to confidentiality shall be required of them.
In addition, any confidential information received from companies external to this Corporation shall be accepted and treated with the same discretion.
In the event of cessation of the labour or professional relationship, the obligation to keep the information strictly confidential shall remain in force and such information shall not be utilized in the interests of another company or agency nor shall it be disclosed without express authorization from the FNMT-RCM.
 Situations of control of companies:
a) It holds the majority of the voting rights.
b) It has the power to appoint or dismiss the majority of the members of the governing body.
c) It may dispose, by virtue of agreements concluded with third parties, of the majority of the voting rights.
d) It has used its votes to appoint the majority of the members of the governing body who hold office at the momento when the consolidated accounts must be drawn up and during the two business years immediatedly preceding. In particular, that circumstance shall be assumed when the majority of the members of the governing body of the controlled Company are members of the governing body or top management of the controlling Company, or of another Company controlled by it. In that event, consolidation shall not arise if the Company whose directors have been appointed is bound to another in any of the cases foreseen in the first two letters of this section.
For the purposes of this section, the voting rigths of the controlling Company shall be added to those it holds through other dependent companies, or through persons acting in tis own name, but on account of the controlling Company, or other dependen tones, or those with which it has made arrangements through any other person.
6 - Rules relating to the corporation's environment
The FNMT-RCM is aware that its corporate activity affects the social, ecological and economic environments that affect the different groups interested in its activity (public administrations and agencies, companies, private individuals, etc.) as well as society in general.
The managers and employees of the FNMT-RCM should incorporate the concept of sustainability in their work, both in the performance of their functions and in the daily decision-making processes, undertaking to comply with the pertaining national and international laws to the social, labour-related and environmentally-conscious spheres.
"Prestige" being one of the most important assets of the Corporation, managers and employees shall, in their dealings with the end users of their work, observe a permanent attitude of service, fostering quality in both products and services and conducting considerate and honest business transactions, driving the search for new activities and the continuous improvement of the competitiveness, strengthening the FNMT-RCM as a company of public interest.
The information received from clients shall be safeguarded in accordance with the terms set out in point 5.7 Confidentiality.
In conformity with the Public Procurement Law and the Entity Contracting Norms to safeguard free competition and the selection of the most economically advantageous tender the selecting of suppliers shall be governed by the principles of free access to auctions, publicity and transparency of procedures and non-discrimination and equal treatment of applicants to ensure, in connexion with the aim of budgetary stability and expenditure control, the efficient use of funds.
Personnel involved in the acquisition processes shall refrain from disclosing to third parties the prices and information submitted by suppliers, except in the event of legal obligation. In addition, they shall behave in an impartial manner and at all times seek the best interests of the Corporation, basing their course of action on criteria of quality, cost-effectiveness and service. In addition, there is a code of conduct for suppliers that sets out the commitments to be assumed.
3. Gifts and rewards
Managers and employees of the FNMT-RCM may not accept valuable gifts, financial rewards, trips or any other gifts or deliveries of goods or services, directly or indirectly through related people who exceed the limit set out in this document from clients, suppliers, institutions or any other person or company that may have participated in selection processes or that may have been awarded a contract or, if applicable, anyone with whom they may have conducted business in which the FNMT.RCM is the supplier/receiver of goods or the provider/receiver of services.
For the sake of courtesy promotional gifts of insignificant value may be given or accepted if they are, within reason, in keeping with the existing business relationships. Any gift costing more than €100 should be returned or placed at the disposal of the Corporation via the Human Resources Department, which will decide upon the procedure to adopt.
4. Internal and external communications
The FNMT-RCM undertakes to establish an efficient internal channel of communication among the employees, the management and the different corporate departments and to provide information on its policies and courses of action appropriately and truthfully in a manner that will help to reduce ambiguity and will obviate the spreading of rumours. The objective is to achieve a positive image and a climate conducive to inspiring the Corporation's personnel with a sense of belonging. Transparency among the different groups must be one of the basic principles that govern internal communications for all FNMT-RCM personnel.
The name and logo are two of the most important assets of the Corporation. Therefore, managers and employees shall take the utmost care to preserve the corporate image at any public appearance or when addressing the media. All information requested by the media shall be passed on to the Communications Area, which will coordinate any release of information and give it their prior approval.
5. The environment
The FNMT-RCM shall conduct its business in such a way as to avoid or reduce, insofar as is possible, any negative impact on the environment, complying with the legal requirements and acting with diligence to correct any anomaly that might cause environmental harm.
The persons affected should, within the scope of their responsibilities, be familiar with the environmental policy and they shall act with respect, comply with the standards of good environmental practice and make efficient use of the plant, equipment and resources at their disposal.
In addition, it is to be hoped that every employee will notify his immediate superior if he observes any anomaly that violates or might violate the environmental standards, as well as any that might promote a saving of energy.
7 - Regulations concerning the use of the resources
1. Use of equipment and the Internet
The FNMT-RCM makes a commitment to its managers and employees to place at their disposal the resources and means necessary for the performance of their work, and the latter undertake to make responsible use of said resources.
The FNMT-RCM holds the property rights and the copyright for the use and development of the software and computer systems, equipment, manuals, videos, projects, studies, reports and other works and rights created, developed, improved by or utilized by its employees in their work or based on the IT facilities of the FNMT-RCM. The employees may not utilize these facilities for their own purposes or for any other purpose than for the FNMT-RCM, nor may they replicate, assign or make use of them to their own advantage.
Managers and employees shall honour the principle of confidentiality insofar as concerns the characteristics of the rights, licenses, software, systems and technological knowhow, the right of ownership to which, or the development or usage rights of which, belong to the FNMT-RCM.
Utilization of the equipment, systems and software that the FNMT-RCM puts at the disposal of the managers and employees for the performance of their work, including Internet access and operational facilities, should conform to criteria of safety and efficiency, and should exclude any online use, action or function contrary to the instructions or interests of the FNMT-RCM. These are reflected in the following procedures and subsequent updates:
- ES.SI.02.00002 Information Technology Services Acceptable Use Policy
- ES.SI.02.00004 Email Service Acceptable Use Policy
The individual keys for access to any FNMT-RCM computerized system should be treated in a strictly confidential manner. The user identity and the password for the operating systems, applications, phones and email accounts and the like, are of a personal nature; they legitimize the user in the system and give him access to his authorized environment. For this reason, except in cases where expressly authorized, it is strictly forbidden to transmit user/password identifications, digital certificates or any other authentication system to any other person. In the event that a person finds out that another knows his secret key, he must change it immediately. In cases of temporary substitutions of personnel, the substitute person must receive a separate access authorization.
For this reason, except in cases where expressly authorized, it is strictly forbidden to transmit user/password identifications, digital certificates or any other authentication system to any other person. In the event that a person finds out that another knows his secret key, he must change it immediately. In cases of temporary substitutions of personnel, the substitute person must receive a separate access authorization.
The managers and employees may not install or utilize in the computer systems that the FNMT-RCM places at their disposal, any programs or applications that it is illegal to utilize or that may damage the systems or harm the interests of the FNMT-RCM, their clients or third parties. Should it be necessary to install a new program or computer system, this will have to be done through the User Help Centre.
2. Utilization of the FNMT name and logo
One of the most valuable assets is the name and logo of the FNMT-RCM. These inspire confidence in the Corporation's clients, in its suppliers, in the State as owner and in the general public. Managers and employees should therefore take the utmost care to preserve its image, and only make use of them when the Entity is being officially represented.
It is absolutely forbidden to utilize the name and logo of the FNMT-RCM in documents, activities, professional workshops, seminars, fairs or any other event unrelated to the business and institutional purposes and objectives of the FNMT-RCM. Any use that diverges from the above-mentioned should be notified in advance through the Communications Area and authorized in accordance with the criteria and guidelines that may be established.
The use of the name and logo in any of the Corporation's channels of communication shall be carried out in accordance with the regulations set out in the Corporate Image Manual.
3. Utilization of electronic mail
The FNMT-RCM is the owner of the electronic mail tool and is entitled to define its utilization based on Article 5 of the Statute of Workers, which determines worker compliance with the specific obligations of their jobs.
8 - Publication
The Code of Conduct shall be published in the web address (Electronic Centre), Intranet or any other means as determined by the Steering Committee, to general knowledge of the staff of the FNMT-RCM and the recipients of the products and services of the Entity.
Updated version - October 2017