SICOMORO SERVICIOS INTEGRALES, S.L. (hereinafter SICOMORO) is a company in the Information and Communications Technology (ICT) sector, whose business activities are aimed at cultural and leisure centers. These activities include:
Management and call center services for ticket sales
Access control systems
Commercialization, development, implementation, and maintenance of software solutions
Our vision is to deliver these services in a reliable, secure, robust, flexible, and profitable manner, with a management approach that anticipates and adapts to change, learns from experience, and drives continuous innovation.
We define a set of core values that guide our approach to legal compliance, particularly in the criminal domain. These values shape our corporate culture, inform our working methods, and influence decision-making across the organization:
We demand strict compliance with all applicable criminal laws.
We act in alignment with and in support of the organization’s overall purpose.
We identify activities within which criminal offenses could potentially be committed and must be prevented.
We strictly prohibit any criminal conduct.
We seek to minimize the organization’s exposure to criminal risks.
Accordingly, SICOMORO is committed to developing, implementing, maintaining, and continuously improving its Criminal Compliance Management System (SGCP) to enhance the way we deliver our services and ensure legal compliance in all dealings with clients and within the organization itself.
Therefore, it is the policy of SICOMORO to:
Establish and annually review Criminal Compliance objectives.
Ensure compliance with business, legal, and regulatory requirements, as well as contractual obligations and the principles of this Criminal Compliance Policy.
Carry out training and awareness programs on Criminal Compliance processes for all personnel.
Provide the necessary resources to guarantee the continuity of the SGCP.
Conduct criminal risk analysis processes to detect potential non-compliance.
Define treatment plans and appropriate controls to mitigate the identified risks.
Establish employee responsibilities with regard to:
Reporting any facts or suspicious behavior related to criminal risks.
Preserving the confidentiality, integrity, and availability of whistleblowers, ensuring they do not suffer retaliation in compliance with this policy.
Adhering to all policies and procedures inherent to the Criminal Compliance Management System.
The representative of the Company’s Governing Body is directly responsible for maintaining this policy and may be supported by a Compliance Body, which shall provide guidance and advice for its effective implementation.