Eduardo Espinosa Bustamante
Chief Executive Officer of Duro Felguera
At Duro Felguera, we conduct our business in accordance with the principles of ethics, integrity, transparency and respect for the law, in the firm belief that responsible business conduct is essential for building trust and creating sustainable value for our stakeholders.
Our Crime Prevention Model and our compliance management systems promote a culture of integrity throughout the Group and establish mechanisms to prevent, identify and manage the risks associated with our business.
Under the principle ‘Compliance is everyone’s responsibility’, we foster a shared culture of compliance, led by the Board of Directors and senior management, based on the participation of everyone in the organisation and on the continuous improvement of our prevention, monitoring and control systems.
Our commitment starts by leading by example
Ethics and integrity are essential elements of the way we do business. At Duro Felguera, we are convinced that results only generate lasting value when they are achieved responsibly and in accordance with our principles. Our commitment to zero tolerance of corruption starts by leading by example and requires the involvement of everyone in our organisation.
At Duro Felguera, we have a risk-based ethics and compliance model, which has evolved progressively to adapt to our activities, business relationships and the regulatory and international environment in which we operate.
Driven by the Board of Directors and senior management, our model integrates prevention, detection and response mechanisms, and is strengthened through regular risk assessment, monitoring of controls and continuous improvement.
Constant evolution to strengthen our model and respond to the challenges of our business and the wider environment.
Before 2009 | Controls in critical areas
Specific controls were in place in key areas of our business operations, laying the groundwork for the subsequent development of the compliance model.
2009 | First Code of Ethics
Incorporation of principles of integrity, respect for the law and an express prohibition on corruption and bribery, laying the foundations for our compliance culture.
2010–2014 | Strengthening of internal control and risk management
Development of policies and procedures in key areas, strengthening prevention and control mechanisms.
2015 | Crime Prevention Model
Formalisation of the Crime Prevention Model and formal establishment of the incident reporting channel.
2016–2017 | Development of the compliance framework
Update of the Crime Prevention Manual and formalisation of the Anti-Corruption Policy and the regulations governing the whistleblowing channel.
2018–2020 | Strengthening of policies and controls
Strengthening of due diligence procedures and the reporting of irregularities. Redefinition of the internal regulatory framework and formalisation of the Internal Control System for Financial Information.
2021–2022 | Comprehensive review and modernisation of the model
Comprehensive review of the criminal risk management model and strengthening of supervisory bodies.
2023 | Certifications and external recognition
Certification of our criminal compliance and anti-bribery management systems in accordance with the UNE 19601 and ISO 37001 standards.
First company in northern Spain and eighth in the country to achieve the highest rating in AENOR’s Good Corporate Governance Index.
2024–2025 | Monitoring and continuous improvement
Review of policies, strengthening of oversight and evaluation of management systems through audits and improvements to controls.
2026 | Consolidation and development
Continuation of criminal compliance and anti-bribery systems and development of new initiatives for risk management and tax compliance.
Prevent
We identify and assess the risks associated with our business and establish policies, controls and due diligence measures, as well as training and awareness-raising initiatives, to prevent potential breaches.
Detect
We monitor our controls and have reporting mechanisms in place, including our Ethics Hotline, which enable us to identify potential irregularities and opportunities for improvement.
Respond
We analyse potential irregularities in accordance with our internal procedures and, where appropriate, take corrective, disciplinary or contractual measures.
Review and improve
We periodically assess the model’s effectiveness, report to the governing bodies and update our systems through audits, monitoring and improvement initiatives.
The effectiveness of our compliance framework requires the involvement of the entire organisation. The Board of Directors and senior management drive and oversee the Group’s ethical commitment; the Compliance function promotes and oversees the implementation of the framework; and the various departments integrate the controls into their day-to-day activities.
Our Crime Prevention Model identifies and assesses the criminal risks associated with our activities and business relationships, establishing prevention, detection and response measures tailored to their nature and level of exposure.
Our compliance system covers the following areas:
1. Integrity and anti-corruption: Prevention of bribery, corruption, influence peddling and other conduct contrary to corporate integrity.
2. Fraud and protection of resources: Prevention of fraud and responsible management of financial resources, financial transactions and means of payment.
3. Tax and social security compliance: Compliance with tax and social security obligations, as well as the proper management of public aid and subsidies.
4. Money laundering and terrorist financing: Prevention of risks associated with transactions, payments and relationships with third parties that may facilitate unlawful activities.
5. Market and procurement: Promotion of fair competition and prevention of conduct contrary to consumer rights, intellectual and industrial property rights, and trade secrets.
6. Privacy and information security: Protection of personal data, corporate information and IT systems against unauthorised access, use or actions.
7. Environment and urban planning: Prevention of environmental damage and compliance with the regulations applicable to our activities, facilities and projects.
8. Public health and safety: Prevention of risks associated with products, substances, materials and facilities that may affect public safety and health.
9. People and rights: Protection of workers’ rights and prevention of conduct relating to labour exploitation, harassment, discrimination and other rights violations.
We periodically review our areas of focus and the associated control measures to adapt them to the evolution of our activities, regulatory changes and the risks of the environment in which we operate.
Our commitment to ethics and compliance is underpinned by a set of codes, policies and internal regulations that establish the principles of action and guidelines for conduct applicable at Duro Felguera.
All members of the Group must be familiar with and apply the regulations relevant to their roles. We also promote awareness of and respect for our principles amongst partners, agents, suppliers and collaborators.
Code of Conduct
This sets out the ethical principles and guidelines for behaviour that must guide our activities and professional relationships.
Third-Party Code of Conduct
This sets out the ethical principles and guidelines for behaviour that our partners, agents, suppliers and collaborators must adhere to in their dealings with Duro Felguera.
Regulatory Compliance and Crime Prevention
Our Regulatory Compliance Policy and our Crime Prevention Manual set out the framework for preventing, detecting and responding to potential breaches.
Anti-Corruption
Our Anti-Corruption Policy sets out the principle of zero tolerance towards corruption and bribery and establishes guidelines to prevent undue influence on our activities.
Competition
Our Competition Policy promotes conduct that respects market rules and fair commercial relations.
Tax Responsibility
Our Corporate Tax Strategy Policy sets out the principles guiding compliance with tax obligations and the management of tax risks.
Reporting of Irregularities
The Internal Reporting System establishes the framework for reporting and managing potential irregularities, with the safeguards provided for in the applicable regulations and our policies.
View document_ Procedure
Our criminal compliance and anti-bribery management systems are certified by AENOR in accordance with the UNE 19601 and ISO 37001 standards. These certifications reflect our commitment to integrity, the prevention of criminal risks and the continuous improvement of our compliance systems.
UNE 19601 · Criminal Compliance
It sets out the requirements for a management system aimed at preventing offences, reducing criminal risks and promoting a culture of compliance within the organisation.
View certificate
ISO 37001 · Anti-bribery management
Sets out the requirements for a management system designed to prevent, detect and respond to bribery, both in the organisation’s activities and in its dealings with third parties.
View certificate
External assessment and regular audits help to verify the functioning of our management systems, evaluate their effectiveness and identify opportunities for improvement.
Your voice contributes to a culture of integrity
Our Ethics Hotline, which forms part of Duro Felguera’s Internal Reporting System, enables employees and stakeholders to raise queries regarding our code of conduct and report any potential irregularities relating to the Group’s activities.
It is a vital tool for promoting transparency, detecting potential breaches and strengthening our culture of integrity.
Independent management
Our Ethics Hotline involves an expert, independent third party of recognised standing, who helps to ensure that communications are handled objectively and confidentially, in accordance with the procedures set out in our Internal Reporting System.
Confidentiality
We protect the identity of whistleblowers and the information reported, in accordance with applicable regulations.
Option for anonymity
Reports may be made anonymously, without the need to provide any identifying details.
Protection against retaliation
We do not tolerate retaliation against anyone who reports irregularities under the terms protected by applicable regulations and our internal policies.
Impartial handling
Reports are analysed in accordance with established procedures, whilst respecting the presumption of innocence, confidentiality and the rights of those affected.
If you are aware of a possible irregularity or wish to raise a query regarding our code of conduct, you can use our Ethics Hotline.