Code of Conduct for Suppliers


This Code of Conduct defines the minimum standards of ethical and responsible behaviour that must be observed in the carrying out of activity by suppliers of the FUNDACIÓN AMANCIO ORTEGA GAONA (hereinafter referred to as ‘FAO’), in accordance with the corporate culture of compliance of FAO firmly based on the values, principles and guidelines for action set out in its Code of Conduct, mandatory for all its employers, managers and employees.

FAO undertakes to make available the necessary means to ensure that suppliers are aware of and understand this Code of Conduct, and are able to comply with it.


All FAO suppliers are required to adhere to this Code, which should govern the behaviour of such suppliers as they carry out their activity, and reflect their commitment to the principles, values and standards of conduct that shape FAO's corporate culture.

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 that may give rise to liability on the part of FAO.


The principles, values and conduct guidelines applied to suppliers in the terms described in the previous section are set out below:


Suppliers shall promote behaviour among its workers based on a respect for the law and ethical values and principles.

Suppliers 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.


Suppliers shall treat their employees with dignity and respect. Under no circumstances shall it tolerate any type of harassment or 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 condition, nor any conduct that is intimidating or offensive to the rights of individuals.


3.3.1. Workplace

Suppliers shall make available to their employees the sufficient means for the development of its activities. Likewise, they shall adopt the preventive measures established in the applicable legislation to guarantee the health and safety of their employees.

Suppliers shall respect their workers’ freedom of association and the right to collective bargaining, subject to the regulations applicable in each case.

Likewise, they shall not allow any type of slavery or child labour, respecting the internationally recognised ethical principles and provisions of the International Labour Organization (ILO).

Lastly, they shall respect applicable legislation and collective agreements regarding the minimum wages to be paid to their employees.

3.3.2. Respect for the environment

In carrying out their business activities, Suppliers shall adopt 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 business activities may have on the environment.

Suppliers 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 them.


Suppliers, in turn, in their relationships with third parties, shall not directly or indirectly accept gifts or compensation of any kind intended to improperly influence as they carry out their activity, avoiding any form of corruption (corruption between individuals, bribery, influence peddling, etc.).

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

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), suppliers 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 their relationship with FAO, suppliers shall not 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.

Suppliers shall also be 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 shall they accept that any action contrary to the principles outlined in this Code compromise the image of FAO.

Suppliers shall be 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.

3.4.2 Relationships with society

Suppliers shall 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 supplier in question must inform FAO’s Compliance Body of the situation.


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, suppliers are obliged to 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 for their own benefit, and from communicating it in any way.

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

3.5.2. Information of a privileged nature

Access to information of a privileged nature that suppliers may have will be governed by the obligations, limitations and prohibitions established in the applicable regulations.


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

In this regard, suppliers shall respect the intellectual property and the right of use that correspond to FAO, whether as a result of their professional activity or that of third parties.

Suppliers shall respect the intellectual and industrial property rights held by third parties outside FAO.


Suppliers shall have the obligation to comply with the applicable tax regulations and to seek adequate coordination of practices in tax matters. On the basis of the above, the actions of suppliers in tax matters shall be governed by the principles of integrity, transparency, prudence and efficiency.


All suppliers shall be required to comply with this Code of Conduct. A written record must be kept of their acceptance of and commitment to the values, principles and standards of conduct contained in it in their professional performance.

In this regard, and to ensure compliance with this Code, all suppliers with a legitimate interest may bring, in good faith, allegations of non-compliance or queries concerning the interpretation or application of this Code, to the attention of the FAO Compliance Body through any of the following means:

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


This Code of Conduct has been approved by the FAO Board of Trustees and has been incorporated into its 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.