Anti-Corruption Policy

We are committed to:

Prohibit any of our collaborators or representatives from offering, promising, paying, giving, authorizing or accepting the delivery of any Object of Value, directly or indirectly, in exchange for improper conduct.

Implement and maintain adequate internal accounting controls, as well as require that all transactions be reported and reflected in an appropriate, accurate manner and with reasonable detail.

Refrain from conducting business with business partners when there is a risk of the latter violating applicable anti-corruption laws or prohibitions.

Involve our administrators, managers and collaborators in compliance and dissemination of this Policy, as well as provide them with the anti-corruption training they require.

Ensure compliance with the commitments set forth in this Policy and apply consequences for non-compliance.

Establish channels and reporting mechanisms for reporting any conduct that may constitute a violation of this Policy.

Have an area responsible for guiding and providing assistance to employees regarding compliance, application or interpretation of the Policy.

Invitations and Gifts

In accordance with our Anti-Corruption Policy, at Telefónica our collaborators are only allowed to receive or deliver gifts:

In compliance with external and internal laws and regulations.

Delivered or accepted without waiting for reciprocity.

Socially acceptable.

Consistent with the interests of our company and with normal business practices.

Occasional and not excessive.

Every time our collaborators receive or deliver a gift to a third party with which Telefónica interacts, including public servants, they must report it through the means that the Compliance Department has provided for it.

If you plan to give a gift to a Telefónica employee or representative, here are seven tips that can help us give and receive gifts with integrity:

  1. It considers that our collaborators cannot receive or offer excessive gifts or invitations, that are not socially acceptable or that have an expectation of reciprocity.

  2. Do not offer gifts to employees or representatives of Telefónica if it is not a general policy applicable to your clients.

  3. Refrain from offering gifts to those who decide to hire you or those responsible for supervising or evaluating compliance with the contract you have with our company.

  4. Notify our collaborators that you plan to send a gift before doing so, so that they can report it to the Compliance Department in a timely manner.

  5. Do not offer or receive gifts that could be perceived as a bribe and report any irregular situation through our reporting channels.

  6. Consult with the Compliance Department of Telefónica in case of any doubt through the email

  7. Share this communication with the members of your organization that interact directly with Telefónica.