The Code of Ethics of the Teatre Nacional de Catalunya is developed by the regulations of the Code of Ethics in Spain and aims to report on the conduct that this Spanish Code of Ethics not only attributes to legal persons but also to companies.
As its Code of Ethics proclaims, the Teatre Nacional de Catalunya rejects and combats any corrupt conduct that is harmful to the company and its reputation.
Next we highlight the controls that we have designed to prevent and detect crime, which form part of the Programme for the Prevention of Crimes implemented by the TNC:
1. Preparation of the Code of Ethics
• The TNC has a Code of Ethics approved by its Board of Directors on 28 June 2017.
• The Code of Ethics constitutes and defines a statement of general action principles and rules of conduct that must guide the behaviour of the people related to the TNC in carrying out their professional activity.
• The Code of Ethics comprises, moreover, the appropriate rules of conduct to prevent the materialisation of criminal risks and, consequently, minimise or exempt the company from any possible criminal liability.
• Its field of application encompasses all the company's department and binds all of its employees as well as any other person or organisation related to the TNC when, because of the nature of the relationship, their action may affect the company's reputation.
• The principles of the TNC's Code of Ethics are applicable, for all purposes, to all the employees and to all the members of the Board of Directors.
• The company's Code of Ethics stipulates that non-fulfilment can involve employment law sanctions, without prejudice to any administrative or criminal sanctions that may derive.
2. Preparation of the Anticorruption Guide
The TNC advocates the development of a responsible, sustainable and successful activity free of any corruption. Thus, it rejects and combats any corrupt conduct, harmful to the company and its reputation, as set out in its Code of Ethics.
With the Anticorruption Guide, the company clearly states its commitment to values such as integrity, equality, sustainability and camaraderie. All the company's employees must respect, unreservedly, the principles and values of the TNC so as to contribute to the protection of their environment faced with any corrupt practice.
With the aim of helping to identify and avoid corrupt practices, the Anticorruption Guide acts, for example, in situations that any employees may encounter in their day-to-day routine while making recommendations about how to deal with them.
3. Guidelines for the prevention of money laundering
The aim of these guidelines is to establish the rules and procedures necessary for the fulfilment of what is provided for in the legislation in force on the prevention and detection of money laundering as well as to prevent the TNC being used in funding terrorism or other criminal activities. The main legislation to which it is subject is Law 10/2010 of 28 April on Prevention of Money Laundering and Terrorism Funding, Royal Decree 925/1995 of 9 June approving the Regulations of Law 19/1993, and Law 12/2003 of 21 May on Prevention and Freezing of Terrorism Funding.
4. Protocol for the prevention of workplace harassment
Workplace harassment directly compromises the dignity of the person. Thus, the TNC states that it will not tolerate these types of conduct within the institution. To this end, it commits to creating, maintaining and protecting all the measures within its reach to achieve a work environment free of all harassment, in which the dignity and sexual freedom of all the people working within the TNC is respected.
The TNC has set up an Ethics Mailbox as a channel to report such conduct, available to all the company's employees as well as suppliers and third parties.
The Ethics Mail Box comprises the figure of the ombudsman, who receives, studies and processes the information submitted concerning corruption, fraud and potentially harmful conduct that may affect the TNC.
The e-mail of the external lawyer taking on the role of ombudsman is the following: firstname.lastname@example.org