Our organization has implemented an Ethical Channel with the aim of establishing a confidential communication channel that allows the reporting of inappropriate conduct, thus promoting a safe work environment, free of harassment and discrimination, and promoting an ethical business culture based on transparency and good government.
Both the ethical channel and the management and investigation of the communications that are carried out through this medium, contemplate all the requirements, guarantees and protection measures provided in Law 2/2023.
Code of Ethics
The Code of Ethics is a fundamental element of the organisation and management model of the Terrats Medical Group that provides behavioural guidelines for various situations to all its members and collaborators, considering their diverse circumstances and governed at all time by the values and principles that it cultivates.
The values of the group that are established in the Code of Ethics are:
The objective of this Code of Ethics is to establish the guidelines and basic principles that must guide the ethical behaviour of all the people who work at and make up the Terrats Medical Group, their daily development during internal relations and the interactions they have with all stakeholders, managers, suppliers, customers and companies of the Group.
Through this Code of Ethics we compile our values, mission and ethical standards, which make up our corporate culture and provide all our employees with the framework for day-to-day decision-making.
Complying with these guidelines will help us to be a Group that bases its management model on transparency, equality and honesty. Compliance with this Code and its rules, as well as professional/employment management based on the principles set out in it, shall be mandatory.
The scope of the code of ethics
The Code of Ethics is addressed to all levels of management, as well as to individual employees, external professionals and specialists, suppliers and other stakeholders.
It is public knowledge and will apply to both natural and legal persons at national and international level, affecting all employees linked to the Terrats Medical Group which comprises the following companies: SENSIS INVEST SLU, TERRATS MEDICAL, S.L.U. (within Spain) TERRATS MEDICAL, USA, LLC, SENSIS USA and DESS DENTAL SMART SOLUTIONS GmbH, Humanus Dental AB (internationally) and any future Group companies. Shareholders and members of the Group's Board of Directors. Other people linked to the Group, including volunteers, unpaid trainees, stakeholders: customers, suppliers, internal collaborators and other interested parties linked to the Terrats Medical Group.
The recommendations contained in the Code of Ethics do not supersede any provision of any applicable convention, law, regulation or other applicable provision. In this sense, this Code does not replace other internal policies and must be applied in conjunction with other procedures and protocols that the Terrats Medical Group has implemented in order to be able to deal with the greatest number of possible scenarios.
The essential foundations for achieving the goals set are the values that define us as a Group, which are as follows:
-Professionalism: all members of the Group will act diligently, responsibly, efficiently and with a focus on excellence, quality and innovation.
-Integrity: all members of the Group shall act lawfully, honestly, in good faith, objectively and in line with the interests of the Group and its principles and values as expressed in this Code of Ethics.
-Self-monitoring: all members of the Group will make decisions based on four basic premises: (i) they must be ethically acceptable; (ii) they must be legal; (iii) they must be in the Group's corporate interest and (iv) whoever instigates a decision must be willing to take responsibility for it.
-Quality: our products are manufactured under the strictest quality controls, being accredited by the most rigorous international certifications. For us, quality is intrinsically linked to our business.
-Excellence: The Group works continuously to achieve excellence in service delivery, seeking to develop long-term relationships based on trust and mutual respect.
-Honesty: All Group employees are committed to act with honesty and integrity and to uphold professional ethics when conducting business and professional relationships.
Principles of ethical conduct of the Terrats Medical Group
In order to properly develop this Code of Ethics, the Group is guided by the following ethical principles , in order to create a culture of ethics and compliance with our economic agents:
- Honesty: All employees of the Terrats Medical Group are committed to promoting conduct based on honesty and mutual trust. Any lack of this principle when communicating information, either within the company or externally, contradicts the Group's Code of Ethics. Likewise, the information provided by the professionals of the Terrats Medical Group to its suppliers will be truthful and will not be projected with the intention of misleading.
- Transparency: In all cases, the Terrats Medical Group applies standards of transparency, information and protection, is committed to offering a quality of services and products equal or superior to that legally established, competing in the market and carrying out marketing and sales activities based on the merits of its products and services. Contracts with the Group's customers shall be drafted in a clear and simple manner. In pre-contractual or contractual relations with customers, transparency shall be promoted and information shall be provided regarding the different existing alternatives, especially those referring to services, products and tariffs.
- Confidentiality: The Terrats Medical Group will guarantee the confidentiality of its clients' data, undertaking not to disclose them to third parties, except with the client's consent or by legal obligation or in compliance with judicial or administrative resolutions.
Principles of the Compliance Management System
The principles governing the Compliance Management System are:
- Protection of intellectual and industrial property
- Commitment to public health
- Protection of corporate resources and cybersecurity
- Anti-corruption and prevention of conflict of interest management
- Relations with government agencies, civil servants and the authorities
- Due diligence in promotional practices
- Gifts, hospitality and other courtesies
- Respect for free competition
- Due diligence in the administrative, economic and financial management of the Group
- Commitment to the environment
- Collaboration in the prevention of money laundering
- Protection and security of our staff.
Code of Ethics
Protection of whistleblowers and affected parties
Any person making a report of wrongdoing or non-compliance through the use of the Ethics Alert Channel will be covered by the guarantees of protection and rights, in the case of bona fide reports.
The identities of any person making use of it and of the persons involved in the matter reported shall be kept confidential as will the information provided.
The anonymity of the reporting party will be guaranteed if this is chosen in the form.
The absence of reprisals of any kind against the reporting party shall be guaranteed, provided that he/she acts in good faith, without prejudice to criminal, disciplinary or other sanctions in the event that the reporting party himself/herself has participated in the reported matter, constituting a breach or irregularity from the perspective of the Group or of current legislation.
Any person who has made use of the Ethics Alert Channel through which he/she has sent any type of communication or query shall have the right to be informed by the Compliance Committee/Compliance Officer of the corresponding progress and the outcome of the investigation, in the specific case that any such internal investigation has been initiated. To this end, the reporting party will receive an identification code pertaining to his or her communication for tracking purposes.
Any person who makes a report through the use of the Ethics Alert Channel shall have the right to withdraw the report if he/she does not wish to continue with the ordinary processing of the same, allowing the report to be withdrawn once it has been made. However, if there are reasonable indications that a breach/irregularity has been committed based on the facts reported, the Compliance Committee/Compliance Officer will initiate a case ex officio and will initiate the corresponding procedure.
Persons using the Ethics Alert Channel are responsible for the truthfulness of their identity and all information transmitted and for acting in good faith. The Terrats Medical Group reserves the right to disclose the identity of the reporting party to the authorities if the caller has acted in bad faith or a court order has been issued.
The Ethical Alert Channel shall be governed by the following principles:
- Principle of confidentiality and data protection. The confidentiality of the identity and information provided by the reporter is guaranteed, ensuring its confidentiality and complying with data protection regulations.
- Principle of non-retaliation. Any form of retaliation or discrimination against the reporter by virtue of the communication made is prohibited. The Compliance Committee shall act immediately if there are indications of retaliatory measures against whistleblowers.
- Principle of proportionality. All activities shall be carried out in accordance with applicable law, in an objective and appropriate manner and respecting the principle of proportionality.
- Principle of impartiality and transparency. The investigation and assessment of communications shall be carried out in an objective, impartial and transparent manner, respecting the rights of all parties involved and ensuring the proper conduct of the investigation process.
- Principle of collaboration and cooperation. Active collaboration and cooperation between the entity, the reporting parties and the competent authorities is encouraged to ensure effectiveness and efficiency in the management of communications.
- Principle of access to information. The parties involved have the right to access relevant information and to be informed about the progress and results of the investigation, always respecting legal and confidentiality limits.
- Principle of compliance with the law. The ethical channel of the entity shall be governed by strict compliance with the applicable laws and regulations, ensuring that all actions related to communications are carried out within the legal framework.
- Principle of protection of the rights of the persons involved. Throughout the investigation process, respect for and protection of the following fundamental rights shall be guaranteed:
- Right to honour. The reputation and good name of the persons involved shall be preserved, avoiding any defamation or unjustified damage to their reputation.
- Right to the presumption of innocence. The right to the presumption of innocence shall be guaranteed throughout the process, up to the stage of the conclusion of the investigation.
- Right to information. The persons involved shall have the right to be informed in a clear and precise manner about the accusations and the evidence that supports them, guaranteeing their right to know the facts reported and to participate in the process.
- Right to defense. The persons involved are given the opportunity to exercise their right to defense in an effective manner, presenting evidence, arguments and allegations to refute the accusations against them.
- Right to protection. All necessary measures shall be taken to safeguard the integrity and security of the persons involved, avoiding any reprisal or prejudice derived from their participation in the investigation process.
- Principle of reparation. The protection and, if necessary, redress of the legitimate rights and interests of the reporter and of the persons involved is ensured by taking appropriate measures to prevent or remedy any harm arising from the communications or investigations.
The entity reserves the right to impose sanctions on a reporter who makes a communication with knowledge of its falsity, in order to safeguard the veracity and integrity of the ethical channel, and to prevent misuse or abuse.
Processing of communications
The corresponding Ethics Alert Channel will be managed through an appropriate communications procedure.
The Channel Managers will be in charge of receiving all communications from reporting parties, either anonymously or with corresponding provision of their personal data. These are the persons whom all reporting parties with a legitimate interest in communicating any type of irregularity or non-compliance committed (or that could potentially be committed) within the group should contact.
- Compliance Officer: César Escribano Patón
- Compliance Committee member: Florencia Reyes Delgado
- Compliance Committee member: Aleix Ricart Presas
The group will ensure the confidentiality of personal data and will comply with Data Protection regulations, and specifically with the provisions of Regulation (EU) 2016/679 of the European Parliament and the Council, General Data Protection and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights.
If you would like to visit our Ethical Alert Channel policy, click here.Ethics Alert channel