DIA complies scrupulously with prevailing legislation in everything it does and in all of its business markets. In 2015, the company updated its Ethics Code and opened up its whistle-blowing channel, which was formerly targeted exclusively at employees, to suppliers, franchisees and contractors. Moreover, it approved a series of corporate policies to govern its dealings with its stakeholders and developed an in-house compliance system to ensure compliance with national and international legislation.
Updated Ethics Code
On 27 July 2015, the Board of Directors of DIA approved an updated version of its Ethics Code, which formerly sets down the DIA Group’s ethics and compliance model and the codes of conduct binding upon the employees, officers and directors of the DIA Group, which includes the parent company and its subsidiaries.
The duties vested in the Ethics Committee, which operates at the group level, include that of disseminating and implementing the Code and ensuring that it is acknowledged, understood and upheld. The company has also appointed Ethics Coordinators at the country level.
All new hires are given a copy of the Ethics Code with their employment contracts which they are asked to sign in order to attest to their acceptance thereof. All DIA executives, meanwhile, accept the code in writing, thereby acknowledging their commitment to upholding the group’s business principles, making sure they are respected in the teams under them and putting them into practice.
Expansion of the scope of the whistle-blowing channel
The company has whistle-blowing channels at the corporate and country levels so that people can report potential breaches of its Ethics Code and resolve questions about its interpretation. In 2015, the company agreed to allow anonymous complaints and ran a communication plan during the last quarter to foster its usage.
One of the most noteworthy milestones last year was the decision to open this channel up to franchisees and suppliers, increasing its reach and scope of application.
DIA opened up its whistle-blowing channel to franchisees and suppliers in 2015
Use of the whistle-blowing channel
The Ethics Committee is responsible for managing the whistle-blowing channel and publicising its existence.
DIA’s compliance model
DIA’s compliance model is articulated around three cornerstones, for which the company has established different objectives, all of which are designed to ensure compliance.
• Corporate governance
To have in place a body of rules and regulations that complies with company and securities market law and complies to an exacting level with prevailing corporate governance recommendations.
To adopt company resolutions in keeping with applicable internal and external rules and regulations.
• Internal control and legal certainty
To have in place an internal risk management and control system that guarantees an appropriate control environment propitious to identification and prevention of compliance-related risks.
To endow the company with the legal certainty needed to carry out its business.
• Prevention and detection of fraud
Spain’s new corporate governance recommendations include that of establishing a corporate social responsibility policy outlining the firm’s commitments in this arena. On 11 December, the Board of Director approved the DIA Group’s Corporate Social Responsibility Policy, which defines the corporate framework governing this issue; it applies to all of the companies and countries comprising the group.
In parallel, the Board of Directors approved the a series of complementary policies that derive from the general framework established by the Group CSR Policy and regulate the company’s relations with its stakeholders: the Investor Communication Policy, Tax Policy, Risk Management Policy and Environmental Policy. Adaptation and approval of the rest of the group’s corporate policies is scheduled for completion in 2016.
Crime Prevention Plan
The DIA Group has put in place a crime prevention model which establishes optimal internal control procedures and policies for preventing the commission of white-collar crime within the organisation and exonerating the company from liability–or at least mitigating its liability to the extent possible–in the event of such acts.
In 2015, the company analysed the activities carried out by DIA’s various business units and assessed each activity’s risk in respect of the commission of potential crimes in terms of probability and impact, factoring in the controls put in place by the company to mitigate these risks.
It also appointed a person within the organisation to champion crime prevention; this person will report to the head of compliance and take responsibility for the adequate maintenance and operation of the model. In Spain, the DIA Group also has an Anti-Fraud Programme specifically designed to prevent and detect fraud in any of its manifestations.
Anti-Fraud Programme in Spain
DIA has an Anti-Fraud Programme in Spain. Using the same methodology as was followed in creating the white collar crime prevention model, the company analysed the activities carried out by DIA’s various business units and assessed each activity’s risk in respect of potential fraud and corruption, factoring in the controls already put in place by DIA to mitigate these risks.
Similarly, the company has appointed a person from within the organisation to champion fraud prevention; this person will report to the head of compliance and the corporate ethics committee and take responsibility for the adequate maintenance and operation of the anti-fraud programme.
This plan has been executed in full in Spain; work is currently ongoing to export, adapt and implement this programme in the rest of the group’s markets.