Criminal Compliance Policy

The Criminal Compliance Policy, the Compliance Management System with the Crime Prevention Manual as the main element, and the rest of the internal regulations, contribute to the construction of our culture corporate compliance, based on the orderly and responsible management of the activity, integrity, honesty and respect for the rules and ethical standards.

The Criminal Compliance Policy is mandatory for all members of the organization, interested parties and business partners, demanding respect for criminal regulations in the fulfillment of its purposes own.

Failure to comply with the requirements imposed in this Policy, as well as those derived from the criminal compliance management system, will entail the pertinent disciplinary and/or sanctioning measures, in accordance with the policies HRE jobs.

Haya Real Estate establishes a commitment to permanent surveillance of the activities in which criminal risks can materialize.

The risks are defined in the criminal risk map, which will be constantly updated and managed.

The Criminal Compliance Policy and the related regulations expressly prohibit employees and business partners from committing criminal acts both in the provision of their professional services, and in the management and governance of the company.

The Criminal Compliance Policy and related regulations establish a preventive culture based on zero tolerance for conduct contrary to criminal law, promoting the process of self-control in action and decision-making by all employees and partners of business, in order to minimize the exposure of Haya Real Estate to criminal risks.

Haya Real Estate establishes in the Crime Prevention Manual, a specific section on the sanctioning and disciplinary regime, under the premise of proportionality, for fraudulent actions and conduct, poor integrity and/or criminal conduct that exposes the company to criminal risks.

In the case of infractions that constitute a crime, Haya Real Estate may report the conduct to the competent authorities.

The Criminal Compliance Policy establishes a framework for the definition, review and achievement of criminal compliance objectives, pursuant to which the processes are established in order to:

a) Identify the criminal risks that the organization can reasonably anticipate

b) Analyze the criminal risks identified

c) Assess the criminal risks identified

d) Review the criminal risks identified

To this end, Haya Real Estate provides sufficient human and material resources to the compliance function, in order to ensure the achievement of compliance objectives, once the risks have been evaluated.

For the development of these activities, the criminal compliance body, the Ethics and Regulatory Compliance Committee, has the necessary authority and independence in the exercise of its functions for the optimal achievement of the criminal compliance objectives, for which which will have the support of the company's Regulatory Compliance Department.

The Criminal Compliance Policy establishes the inexcusable obligation to inform, through the established means, particularly through the Haya Real Estate Whistleblower Channel, of suspicious acts or behaviors referring to the criminal risks that are intended to be avoided, the breach of the rules of conduct imposed in the regulations internal company, or any doubt about the interpretation of this Policy or other related regulations.

The governing body expresses its commitment to updating and improving the criminal compliance system, implementing specific measures that allow the system and its performance evaluation to be reviewed at regular intervals.