Good Governance and Compliance
Our good governance and compliance system
The Capital Energy Group has a Compliance Model which applies to all its subsidiaries. The Compliance Model was approved by its Governing Body in September 2019.
The Compliance Model is based on a commitment to national and international best practices in good corporate governance, compliance, business ethics and corporate social responsibility in all areas of activity.
At Capital Energy we strive to build a model that reflects the principles of the organisation and helps create relationships of trust with our stakeholders.
It is based on the principles of ethics, behaviour and transparency set out in the General Compliance Policy, the Code of Ethics and Conduct, the Anti-Corruption Policy, as well as the organisation’s other rules and procedures.
Its purpose is to guarantee our commitment to compliance with the legislation and ethical principles established by our Governing Body in our relations with our stakeholders and in the activities carried out by the organisation, thus ensuring the long-term sustainability of our business model.
Corporate Rules and Policies
- General Compliance Policy. Expresses the commitment of the organisation and its subsidiaries to an ethical business culture and to the active management of regulatory compliance in general and the prevention of corporate crime in particular.
- Code of Ethics and Conduct. Defines the culture, values and principles of action that should guide the behaviour of all members of the organisation.
- Code of Conduct for Suppliers and Partners. In order to extend Capital Energy's commitment to our entire value chain, we have drawn up the Code of Conduct for Suppliers and Partners.
- Anti-Corruption Policy. To reinforce our commitment to legal compliance and anti-corruption, Capital Energy has approved the Anti-Corruption Policy, which is mandatory for all members of the organisation and also governs our relationships with third parties in all areas of our business.
- Competence Matrix and delegated authority. Establishes the enterprise's organisational structure, the framework for action in accordance with the key figures and the principles governing decision-making.
Capital Energy has a Compliance Committee, an independent body that has sufficient authority and responsibility to supervise the proper implementation of the Compliance Model.
The Capital Energy Group has set up a specific complaints channel available to all the members of the organisation, as well as its suppliers and partners. This channel guarantees the confidentiality of the complainant.
Information concerning Personal Data Protection
Who is the Data Controller?
Capital Energy Holding Company, S.A.U. (Hereinafter “Capital Energy”).
Tax ID: A-88514724.1
Address: Calle Marqués de Villamagna, número 3, Planta 5, 28001 Madrid, Spain.
Telephone: +34 91 401 77 44
Data Protection Officer: firstname.lastname@example.org.
Why do we process your data, on what grounds and for how long will we keep it?
To manage any complaints and queries received through the complaints channel, to detect crimes and prevent criminal liability for Capital Energy and to avoid conduct contrary to the organisation’s internal regulations as well as any other applicable regulations in force.
The grounds for processing is the consent of the data subject when voluntarily submitting their information, as well as the legitimate interest of the enterprise to investigate facts that may contravene criminal law or other applicable regulations and, where appropriate, to comply with a legal obligation (exercise or defence of claims).
The data pertaining to the complainant, the respondent or third parties and other information shall be kept for such time as is necessary to determine whether to initiate an investigation into the events alleged to have taken place. If the complaint is closed and no action is taken, the complaint and related information will be anonymised, and the obligation to block the data shall not apply. Three months after the communication of the data, the information shall be deleted from the complaints system, unless the purpose of storing it is to provide evidence of the operation of the model for preventing the commission of offences by the legal person. The data will only be kept by those persons empowered with the duties of internal control and compliance or, where appropriate, external third parties acting as data processors.
With whom do we share your data? Do we carry out international data transfers?
The identity of the complainant shall not be disclosed to third parties, with the exception of relevant persons involved in the investigation or judicial proceedings initiated as a result of the investigation.
Facts that may constitute a criminal or administrative offence, including personal data, shall be reported to the competent authorities, whether they are located in Spain or abroad, which could involve carrying out an international data transfer for reasons of public interest and/or for the formulation, exercise or defence of claims, and personal data may also be communicated to Group companies if necessary for the investigation, processing and/or resolution thereof. To consult which companies belong to the group of companies of which Capital Energy is a member, send an email request to email@example.com.
What are my rights?
You may exercise your rights of access, rectification, erasure, portability and restriction or your right to object and, where appropriate, withdraw your consent by contacting us at the addresses indicated above.
Similarly, Data Subjects are entitled to file a claim with the Supervisory Authority (Spanish Data Protection Agency: www.aepd.es).
Capital Energy guarantees the confidentiality of the complainant, respondent and any other third parties that may be involved, and of content of the complaint. There will be no adverse consequences of any kind for making a complaint, provided that the complaint is made in good faith.