Articles and codes

Code of Conduct

Code of Conduct


The purpose of this Code of Conduct of the FUNDACIÓN AMANCIO ORTEGA GAONA (hereinafter referred to as ‘FAO’) is to establish the values, principles and standards of behaviour aimed at ensuring the ethical and responsible conduct of all employers, managers and employees of the FAO (hereinafter referred to as ‘Subject Persons’) in the exercise of their professional activities.


This Code of Conduct is one of the main elements of the FAO Model for the Prevention and Detection of Crime. It applies to all Subject Persons, regardless of their geographical, hierarchical or functional location, or the contractual modality that determines their relationship with it.

This Code takes into account the principle of criminal liability of legal persons as set out in the Spanish legal system, and prevents and prohibits conduct by Subject Persons that may give rise to liability on the part of FAO.

This Code is the fundamental rule that governs the behaviour of the Subject Persons and constitutes their commitment to the ethical principles that must govern all areas of action, establishing the values, principles and guidelines of conduct aimed at guaranteeing the ethical and responsible behaviour of the Subject Persons, describing the corporate culture of the FAO.

FAO has a Supplier Code of Conduct which sets out the standards of behaviour required of FAO suppliers.


The principles and values applied to the Subject Persons are described below.


Among its Subject Persons, FAO promotes behaviour based on a respect for the law and ethical values and principles, which are the pillars of FAO's culture of compliance.

All Subject Persons shall act in strict compliance with the law in force and respect the internationally recognised ethical principles contained in the Universal Declaration of Human Rights, being governed at all times by a respect for human rights and the values of integrity and honesty, and avoiding any action that may be contrary to the law in force.


Relationships between Subject Persons, as well as relationships with third parties, shall be based on professional respect, trust and mutual collaboration. FAO strongly rejects any form of harassment, as well as any conduct that is intimidating or offensive to the rights of individuals.

In the exercise of its professional activities, FAO does not accept any discrimination based on the race, ethnicity, colour, nationality, age, sex, marital status, sexual orientation, ideology, trade union membership, religion, family status, disability or any other status of its employees or third parties. FAO respects and protects the sexual freedom, privacy and moral integrity of Subject Persons and third parties in the context of all work and/or professional activities.

FAO promotes the professional development of Subject Persons and provides equal opportunities for their career development. In this regard, FAO applies high ethical standards in all recruitment and career development processes.


3.3.1. Workplace

FAO makes available sufficient means for the development of its activities to Subject Persons. Likewise, it adopts the preventive measures established in the applicable legislation to guarantee the health and safety of Subject Persons.

FAO respects workers’ freedom of association and the right to collective bargaining, subject to the regulations applicable in each case.

FAO firmly rejects modern forms of slavery and child labour, respecting the internationally recognised ethical principles and provisions of the International Labour Organization (ILO).

FAO respects applicable legislation and collective agreements regarding the minimum wages to be paid to Subject Persons.

3.3.2. Respect for the environment

In carrying out its activities, FAO adopts an ethical and responsible attitude which combines creating value with sustainable development, considering environmental protection as the main objective, complying with applicable regulations and minimising the impact that its activities may have on the environment.

Subject Persons shall protect and respect the environment, and carry out their activity minimising the environmental impact derived through its exercise, seeking out the efficient use of all resources available to FAO.


Subject Persons, in their relationships with third parties, shall not directly or indirectly accept gifts or compensation of any kind intended to improperly influence their professional or administrative relationships, both with public and private entities.

FAO does not give, promise, offer or accept any kind of payment, commission, gift or remuneration to or from any employee, executives, or heads of a business for the purpose of obtaining favourable treatment against competitors or of securing a business opportunity.

Subject Persons may only accept gifts, presents or hospitality from third parties when the value does not exceed 300 euros. If the value of the gift exceeds the above amount, the Compliance Body shall be consulted, who must then exceptionally authorise such a benefit.

FAO expresses its firm commitment to and zero tolerance for any form of corruption (corruption among individuals, bribery, influence peddling, etc.), establishing action standards in the Anti-Corruption Policy.

3.4.1 Relationships with beneficiaries

Relationships between FAO and its beneficiaries are governed by the principles of honesty and transparency, always seeking the satisfaction of the beneficiaries in the development of business relationships.

Subject Persons shall not carry out actions that could be mistaken for something else or may, directly or indirectly, deceive beneficiaries or any third party, in order to get them to carry out a transaction or contract a product that, if they had known its real characteristics, they would not have carried out or contracted.

3.4.2 Relationships with suppliers

Relationships between FAO and its suppliers shall be based on respect, trust and good faith.

Personnel responsible for selecting suppliers shall avoid conflicts of interest between FAO and third party contractors by following principles of transparency and fairness.

Subject Persons shall avoid any kind of interference or influence from suppliers or third parties that could alter the objectivity of the selection and contracting process, as well as the principles governing the relationship between FAO and its suppliers.

3.4.3 Relationships with third parties (public administrations, companies and other players in the market)

FAO's activity is governed by the principles of transparency and honesty in relationships with third-party market players, both public and private.

In relationships with Public Administrations (of local, regional, national, European and international scope, and including public companies and other entities or organisations of a public nature), the Subject Persons shall act following principles of integrity and honesty, with absolute respect of the norms of behaviour that govern the relationships with organisms and public authorities, and rejecting any action that can be linked to bribery, traffic of influences or any form of corruption.

In the course of any relationship with governments or public companies, no Subject Person may offer, grant, solicit or accept, directly or indirectly, any gifts or gratuities, favours or compensation, in cash or in kind, of any kind whatsoever, to or from any authority, regulatory body, public official or any person engaged in the performance of public duties, which could influence and relate to the taking of decisions concerning FAO by the governments or institutions concerned.

FAO is also committed to compliance with the law, providing maximum cooperation with the authorities in all matters where required, including the fight against money laundering and the financing of terrorism.

In no event does FAO accept that any action contrary to the principles outlined in this Code may compromise the image of FAO or the integrity of Subject Persons.

FAO also defends the proper functioning of the market, trust, honesty and professional ethics. FAO is committed to compliance with competition law, avoiding any conduct that may constitute collusion, abuse or restriction of competition, acting in the markets in a fair manner, without misleading advertising or denigrating practices of third parties.

FAO defends proper tax management and the contribution to supporting public expenditure, promoting transparency in the performance of all its operations, as well as collaboration with the Tax Agency.

3.4.4 Relationships with society

Subject Persons maintain independence in their actions. Any contribution that they make to political parties, authorities, bodies, public administrations and institutions in general will always be made in accordance with current legislation, in a personal capacity and guaranteeing their independence. In the event that a conflict of interest may arise regarding the acceptance of a public position, the Subject Person must inform the Compliance Body of the situation.

FAO's principles of behaviour are transparency and reliability of financial information and compliance with applicable regulations, reflecting clearly and accurately the transactions, facts and events in FAO's records.


FAO considers information to be one of its most valuable assets and therefore this Code of Conduct promotes its protected use.

3.5.1. Confidentiality

Internally, Subject Persons shall treat the information to which they have access by reason of their professional activity in a confidential and reserved manner, refraining from using any data, information or document obtained during the exercise of their activity in FAO for their own benefit, and from communicating it in any way.

The obligation of confidentiality shall remain after completion of the activity at FAO and shall include the obligation to return any FAO-related material in the possession of the Subject Person upon termination of their relationship with FAO.

FAO does not allow the use of information from other entities that could be classified as confidential. All of this affects both current Subject Persons and those who will be hired in the future, who may not bring documents, files, software or any other type of information from third parties to their new job.

3.5.2. Processing of personal data

FAO guarantees confidentiality of the personal data of Subject Persons, beneficiaries, suppliers and any other third party, and undertakes not to disclose such data, except with the consent of the foregoing, or in compliance with legal obligations or judicial or administrative rulings.

The collection, use and processing of personal data shall be carried out in such a way as to guarantee the right to privacy, in compliance with the legislation on the protection of personal data insofar as it is applicable.


Subject Persons undertake to make responsible use of the assets, resources and any other means placed at their disposal for the development of their professional activity.

Subject Persons are not authorised to access third-party computers, handle information or software not provided or authorised by the FAO or make copies of any FAO or third-party programme.

In this regard, the Subject Persons shall respect the intellectual property and the right of use that correspond to FAO in relation to courses, projects, programmes and computer systems; equipment, manuals and videos, knowledge, processes, technology, know-how and, in general, the projects and works developed or created in FAO, whether as a result of their professional activity or that of third parties. Therefore, they may be used in the exercise of the professional activity in FAO, and all the material in which they are contained shall be returned when required.

FAO is the owner of the property and of the rights of use and exploitation of the software and computer systems, equipment, manuals, projects, studies, reports and other rights and works created and/or developed by the Subject Persons as part of their professional activity or based on FAO's IT competencies.

FAO also undertakes to respect the intellectual and industrial property rights held by third parties outside FAO.


The Compliance Body is responsible for ensuring compliance with the general behaviour principles set forth in this Code of Conduct. To this end, it performs the following functions:

  • Dissemination, knowledge and compliance among all Subject Persons.
  • Interpretation of the content and application of the Code of Conduct, as well as resolution of conflicts that may arise from its application.
  • Establishment of the disciplinary scheme and the measures applicable in the event of Code of Conduct breaches.

In exercising its functions, the Compliance Body ensures:

  1. The confidentiality of all data and background information, as well as of the proceedings carried out, unless the law or a court order requires the disclosure of said information.
  2. The thorough analysis of any information or document on the basis of which it its work is established.
  3. The instruction of a procedure appropriate to the circumstances of the case, in which it always acts with independence and full respect for any Subject Person.
  4. The indemnity of any Subject Person as a result of the communication of an anomalous action or complaint made in good faith.
  5. The rigorous and objective justification of any decision taken.

In exercising these functions, the Compliance Body may be assisted by a third party independent of FAO.


This Code of Conduct is disseminated to all Subject Persons.

All Subject Persons are required to comply with the Code of Conduct from the time they join FAO and during their professional performance for FAO. A written record must be kept of their acceptance of and commitment to the values, principles and standards of conduct contained in the Code of Conduct in their professional performance.

Failure to comply with the Code of Conduct compromises the reputation and corporate image of FAO. Therefore, all Subject Persons are obliged to report any conduct that contravenes or may contravene the Code of Conduct to the Compliance Body, using the Ethics Mailbox referred to in the Appendix of this Code of Conduct.

Failure to comply with this Code of Conduct, as well as with the provisions set out in the Model for the Prevention and Detection of Crimes, may result in the application of the disciplinary system, and may lead to the termination of the employment relationship or other sanctions provided for in the Workers’ Statute or in the corresponding collective agreements, without prejudice to any administrative or criminal sanctions that may arise.


This Code of Conduct has been approved by the FAO Board of Trustees and has been incorporated into FAO’s internal rules and regulations. It shall remain in force until its cancellation or modification is approved.

Any modification to this Code of Conduct must be approved by the FAO Board of Trustees.

The Compliance Body shall be responsible for submitting proposals for modifications to the FAO Board of Trustees based on the suggestions and modifications proposed by Subject Persons, future commitments that may be made by FAO in the exercise of its activity, changes in the FAO environment and legislative changes that may affect its content.

Appendix - Ethics Mailbox

What is it?

FAO shall make an Ethics Mailbox available to Subject Persons, through which they may report to the Compliance Body any type of illegal behaviour or non-compliance with the Code of Conduct of which they are aware.

What conduct can be reported?

All irregularities or acts contrary to the law or to the rules of action contained in the Code of Conduct or in the Model of Prevention and Detection of Crimes can and must be reported.

In addition, any suspicions regarding the following can be reported:

  1. The improper application of the principles contained in the Code of Conduct or in the Model of Prevention and Detection of Crimes of the PONTEGADEA Group or, in general, all conduct that may imply a violation of the applicable legislation.
  2. Non-compliance with the Code of Conduct, internal regulations of the PONTEGADEA Group or applicable legislation that could involve criminal actions.

By what means can I file a complaint?

All Subject Persons who become aware of an irregularity committed shall notify it through the channels provided for this purpose by FAO:

  • Via
  • Via ordinary mail with certificate of receipt to the following postal address: Buzón Ético Fundación Amancio Ortega, Cantón Grande nº 4, 15003 – La Coruña.

Complaints made may be anonymous.

Furthermore, FAO has made access to this Mailbox available to third parties with a legitimate interest, so that they can report possible non-compliance or criminal activity if detected.

Who handles it?

Complaints sent through this channel are managed by the Compliance Body, which is responsible for analysing the facts reported, processing the communications received, as well as handling and resolving the proceedings initiated as a result of the complaints, with the absolute independence and confidentiality of all the bodies responsible for managing the company, except for the Board of Trustees.

It does this while ensuring maximum confidentiality regarding the identity of the person reporting, without prejudice to legal obligations and the protection of the rights corresponding to companies and persons accused unjustly or in bad faith. This Ethics Mailbox may not be used for illegitimate or personal motives, or those contrary to good faith.

In exercising this function, the Compliance Body shall respect the principles set forth in the Code of Conduct with respect to ensuring the confidentiality of the identity and the absence of retaliation or negative action against the complainant in good faith. The rights to privacy, defence and the presumption of innocence of the accused person shall also be respected.

The receipt and processing of submitted complaints are regulated by the Ethics Mailbox Regulations.