Code of ethics 2020-01-15T15:29:38+00:00



  • I. Introduction.
  • II. Company Commitment.
  • III. Area of application.
  • IV. Manual of Good Practices.
    • I. General Ethical Principles
      • A.   Equal opportunities and non-discrimination
      • B.   Regarding to people
      • C.   Health and safety
      • D.  Prohibition to receive consideration
      • E.  Responsible practices and non-competition
      • F.   Environmental protection
    • II. External relations
      • A. Relations with suppliers
        B. Relations with customers
        C. Relations with competitors
        D. Relations with the Public Administration
    • III. Ethical Mailbox
  • V. Compliance of the Code of Ethics or Conduct


As a result of the provisions contained in article 31 bis of the Criminal Code regarding  to the figure of the Criminal Crime Prevention Plan (Compliance) VERTIX, SA prepares this Code of Ethics or Conduct (henceforth, the Code).
This is intended to highlight what are the internal rules of the Company that are considered essential or basic for its proper functioning, thus seeking to favor an ethical culture in the company in accordance with the regulations contemplated. This Code is an additional complement, never contradictory, to that already provided by the respective legal regulations in force. They must be considered as regulatory principles: the principle of good working faith, the principle of proportionality, as well as respect for laws, rights and obligations that they recognize.
The Code of Ethics or Conduct will therefore have binding character and forced compliance on all members of the Company.
In order to ensure its integrity and effective application, in certain cases, compliance may also be requested, not only from the members of the Company but also from the suppliers and contractors with whom it is related.
Failure to comply may involve the application of the relevant legal measures. It is considered as an unavoidable duty of every member of the Company to protect and defend compliance with this Code using, if necessary, the ethical mailbox or “banner”, or immediate communication to the Monitoring Committee, in cases where it is suspected or Your disobedience is known.


To comply with the provisions of the aforementioned precept, the Company undertakes to respect the legal regulations in full, to ensure compliance, pursue their violations and collaborate with Justice if necessary.
For this purpose, this Code is prepared, which is a reference guide for developing appropriate behaviors in the development of the Company’s activities.
All these behaviors must be respected by all members of VERTIX, SA, as well as by our usual collaborators.
This Code reflects the values ​​of VERTIX, SA based on quality, integrity, professional development, equal opportunities, etc. For this reason, the commitment must be fulfilled by all workers, managers and administrators, reflecting the good conduct of the Company.


This Code is applicable to the members of the administrative positions and all employees of VERTIX, SA and other companies of the real estate group.
All persons subject to the Code have the obligation to know and comply with it, as well as collaborate to facilitate its implementation.
The Code will be notified via email to all employees and executives of VERTIX, SA who must assume its compliance.


  • A. Equal opportunities and non-discrimination
    VERTIX, SA promotes the professional and personal development of all its employees, ensuring equal opportunities through its performance policies. Does not accept any type of discrimination in the work or professional ambit because of age, race, color, sex, religion, social origin or disability. The selection and promotion of the employees of VERTIX, SA is based on the competences and performance of professional functions, and on the criteria of merit and capacity defined in the requirements of the job. People who hold management positions must act as facilitators of the professional development for their employees, so as to promote their professional growth in the Company.
    The Company does not tolerate discrimination against any of its members because of race, religion, color, sex, age, marital status, nationality, sexual orientation or disability. Therefore, the Company undertakes not to carry out acts of illegal discrimination in any area of ​​work from hiring to dismissals, or any other condition of employment or professional development. At all times the legal regulations will be strictly accomplished, both for the hiring of national or foreign citizens.
    Likewise, the use of discriminatory insults, jokes or behaviors that may stimulate an offensive or hostile working environment is not tolerated. In the event that there is any indication on this matter, the Company will take appropriate measures to find the origin of the problem and avoid its repetition.
  • B. Regarding people
    At all professional levels within the Society, respect-based relationships are promoted to achieve a good working environment. Therefore, all types of abuse, harassment, disrespect, intimidation and physical or psychological aggression are prohibited at all professional levels.
    Sexual harassment. 
    Any form of harassment at work, whether sexual or for any other reason, is prohibited. Therefore, with the condition of protecting those who may suffer from it, at the time it is reported, either by the affected person or by those who had knowledge of this fact, the measures will be adopted by the Company, immediately, of all kinds, to prevent this situation from continuing.
    For this purpose, an ethical mailbox has been installed on the Company’s website to facilitate the reporting of any event of this nature that may occur.
    Measures against harassment, abuse or discrimination will be investigated immediately and will maintain the strictest confidentiality in order to preserve the privacy and rights of the potential victim.
    Any false complaint about this will result in the corresponding disciplinary sanction in accordance with the labor and criminal regulations.
    Mobbing or workplace harassment.
    Psychological harassment or workplace harassment is defined as that “situation in which a person exercises extreme psychological violence, in a systematic and recurring manner and during a prolonged time on another person or people in the workplace in order to destroy the networks of communication of the victim or victims, destroy their reputation, disrupt the exercise of work and ensure that finally that person or people end up leaving the workplace. ”
    The harassment that may exist within the Company can be cataloged at three levels:
    · Downward harassment: the one practiced by the person who occupies a hierarchically superior position.
    · Horizontal harassment: the one practiced by an employee who enjoys the same professional level and situation on the scale of the Company.
    · Ascending harassment: the one practiced by the subordinate employee against his superior.
    Faced with a situation of psychological harassment or workplace harassment, the alleged victim must file a complaint using the Ethical Tray or go to the superior of the stalker.
    Once the alleged workplace harassment has been denounced, the necessary measures must be taken to prevent the recurrence of this crime.
    Any conduct carried out by any member of the Company that may give rise to a well-founded suspicion of the existence of any of the aforementioned crimes must be immediately communicated to the Management Body or use the Ethical Mailbox.
  • C. Security and health
    VERTIX, SA intends to eliminate the hazards identified in the workplace. Therefore, it undertakes to strictly comply with all laws related to health, safety and the environment that may affect the members of the Company. To promote it, compliance with the Occupational Risk Prevention Plan is required.
    The Company’s personnel are responsible for taking the necessary measures for accident prevention and notifying the Human Resources department in case of detecting those abnormal conditions on the operation, especially on those exposed to greater risks.
    The Occupational Risk Prevention Plan foresees an execution plan for all those measures of action in the face of different accident situations that may be produced, as well as the persons responsible in each case who will have to obey and communicate the state of emergency.
  • D. Prohibition of receiving consideration
    VERTIX, SA promotes transparency and equality since they are essential values ​​to build trust, both from an internal and external point of view, hence when workers receive gifts that are not considered insignificant details, they must notify the Compliance Officer.
  • E. Responsible Practices and non-competition
    All workers of VERTIX, SA must comply with current legislation and with the internal regulations of the Company. The application of the Code will never mean a non-compliance of the legal provisions in force.
    They also have the obligation to comply with the Company’s own procedures and instructions that may be approved in their development.
    VERTIX, SA will provide the necessary means so that each of its employees knows and understands the internal and external regulations necessary for the proper functioning and proper performance of its functions.
    In case of breach of the Code of Conduct, VERTIX, SA has a channel and procedures to notify and denounce, in a confidential manner, any irregular action that violates any of the principles regulated in the Code of Conduct.
    Employees may not provide professional services in competing companies, during the employment relationship with VERTIX, SA.
  • F. Environmental protection
    VERTIX, SA complies with current regulations in social and environmental matters. For this reason, workers must know and act at all times in accordance with this policy and adopt habits and behaviors related to environmental practices.
    Employees should make efficient use of the facilities, work facilities and equipment that are available to minimize environmental impact.
    Likewise, they must transmit these principles and demand their compliance to the third parties with whom they relate, such as collaborating companies, suppliers, etc.
  • A. Relations with suppliers
    The Company undertakes to interact with suppliers in an ethical, honest and respectful manner. They will be selected by objective criteria, always putting the interest of the Company and assessing the improvement of the conditions.
    Those suppliers that have similar policies to VERTIX, SA regarding rights and obligations with workers, in terms of occupational safety and environmental measures, will be positively valued.
    It will be the obligation of the suppliers to notify VERTIX, SA of any breach of the contractual obligations or of the measures included in this Code. Likewise, they must also report any suspected suspicion of non-compliance.
  • B. Relations with clients
    The dealings with clients must be respectful and honest, considering the cultural diversity of each person, prohibiting all types of discrimination. The services must be presented objectively, without distorting the characteristics or conditions. All unfair or fraudulent practices are prohibited, as well as all false or misleading information that may mislead customers.
  • C. Relations with competitors
    Legitimate methods will always be used with the competitors of VERTIX, SA with a totally respectful treatment. The activity in the market will be fair, without using deceptive or denigrative advertising methods. Confidential information will always be respected, in addition to intellectual property rights. In no case, information that has been obtained illicit, illegally or improperly will be accepted.
  • D. Relations with the Public Administration
    The relations with the Public Administration will be governed especially by the principle of transparency, with the total obligation of compliance with the Law.

Every worker of VERTIX, SA who has knowledge of the commission of an act that breaches this Code of Conduct or the internal regulations of the Company must communicate it through the Ethical Mailbox.
The Ethical Mailbox is located on the website, in the corporate section, and workers and suppliers will have access. The Compliance officer will ensure that all communication made on this channel is confidential.
It is strictly forbidden to retaliate against any employee who has filed a complaint. The prohibition of retaliation will not prevent the adoption of disciplinary measures when it is detected that the complaint is false and has been filed in bad faith.
Complaints will have a record that will respect data protection. The procedure to follow after receiving a complaint will be as follows: The Compliance officer will analyze the complaint to see if it thrives or not, if so, it will initiate an investigation. You must always record receipt of the statement, in case you do not continue with the search you must write down the reasons why you will not be investigated. The search can be reopened if additional information is received.
The Compliance officer must collect all the information necessary to clarify the subject reported. This complaint may be made anonymously, although it would be desirable to provide the data of the complainant in order to facilitate the search and monitoring of the facts.


The approval of this Code of Ethics or Conduct corresponds to the Compliance Officer.
This document enter into force January 1th, 2020. Its content will be subject to periodic review and the modifications considered relevant will be made according to the situation of the Society.