Code of Ethics and Conduct


The Code of Ethics and conduct of PAVASAL Group is one of the strictest rules within the Group. It was approved by the Board of Directors on 10 January 2018, and is designed to formalise the Group’s commitment to the principles of corporate ethics and transparency in all fields of action, establishing a set of principles and guidelines aimed at guaranteeing ethical and responsible behaviour of all the people it is addressed to in the performance of their activity.

Furthermore, the Code of Ethics enhances PAVASAL Group’s corporate culture, insofar as it has been formulated with the purpose of unifying and reinforcing identity, culture and behavioural guidelines that orientate the action and the behaviour of our professionals.



As suppliers are considered a strategic stakeholder, PAVASAL Group has established specific principles of action for them for their area of activity, in line, in all cases, with the Group’s principles and values. These are embodied in this Suppliers’ Code of Ethics, which must be accepted by the Group’s suppliers and which shall be attached to the corresponding contracts.


n compliance with the current criminal legislation, PAVASAL Group undertakes to prepare, develop, implement and update a Criminal Risk Prevention Plan, where it analyses, in its due form, those criminal risks that could be committed, related to the Group’s business activities, by any of its members, whether owner, employee or executive.

For said purpose, an analysis of these risks will be performed, establishing a series of corrective and preventive measures, in order to avoid committing any crime.

In addition to the corrective and preventive measures adopted in the Prevention Plan, the greatest possible dissemination will be given to it among the members forming PAVASAL Group, including training plans and/or actions and continuous refreshment for the whole of the Group’s members.


Data protection

PAVASAL Group undertakes to comply with its obligation of secrecy of the personal data provided to it and its duty of handling it with confidentiality, and it assumes, for these purposes, the technical, organisational and security measures necessary to avoid its loss, unauthorised processing or access, in accordance with the provisions of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights and Regulation 2016/679, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data, and other applicable legislation.

Prevention of Money Laundering

PAVASAL group has approved a Money Laundering Prevention Manual which must be applied by those Group companies which, due to their activity, are legally obliged to comply with money laundering legislation.

Furthermore, PAVASAL Group companies will pay special attention to cash payments and collections that are unusual due to the nature of the operation, those made by bearer cheques or those made in currencies other than that previously agreed, notifying through the channels established in those Code of Ethics those they understand may be irregular.

Likewise, they will pay special attention to the payments made to people, companies or entities with accounts open in tax havens and payments made to banks where it is not possible to identify the ultimate shareholder, owner or beneficiary.