Code of Conduct

INTRODUCTION

For more than 30 years, Altair has built a reputation based on cultivating a beyond-compliance approach to ethics, always committing to what is right, just, and appropriate. This way of acting has been embraced over the years by employees, collaborators, and partners, becoming an essential part of Altair’s DNA and the way the company stands in the world. We strive for moral courage, understood as the strength to use ethical principles to do what one believes is right even though the results might not be the most beneficial.

This Code of Ethics is an evolving work in progress that sets the rules of conduct upon which purpose we reflect, and the values we rely on as guiding principles, and anyone working with Altair, no matter in what capacity, should abide by them. It constitutes a written expression of the principles and values that guide Altair’s performance, including the conduct of employees and executives, to ensure responsible and ethical behavior in the exercise of their professional duties with other employees, executives, freelancers, contractors, collaborators, clients, beneficiaries, etc. It does not pretend to be an exhaustive list of situations but offers general guidelines that should inform how the company and its collaborators behave.

This code of conduct bounds everybody at Altair and anyone who works for or in the representation of Altair. To ensure compliance, Altair has established mechanisms of communication, monitoring, and control.

OUR STANCE

ESG

Altair has embraced a corporate strategy based on 3 main pillars: Environmental, Social, and Governance.

Environmental: We are aware of our direct and indirect impact, considering the environment as one more stakeholder: it represents future generations and for this reason, we want to preserve and maintain an environment that they can take advantage of and enjoy.

At Altair we demonstrate it with our attitudes and consumption at the company level – responsible supplies, ecological transport, respectful nutrition… – and we extend our environmental awareness to our ecosystem: carbon footprint requests to suppliers and collaborators, sharing our impact; environmental assessment of our direct impact field projects; extension of our values to the entire supply chain.

Social: We have the heart of a social action NGO with a business mindset. We combine the best of a private entity in the capacity for analysis, strategy, prioritization of management and investment objectives, and organization with the best of a third-sector entity in terms of awareness of social justice and reduction of inequalities to achieve an environment with equal access to opportunities for all genders, social status, different abilities, religious and cultural options without neglecting the different age cohorts – 4 different generations living together in productive/working age-.

Governance: We are characterized by the good governance that we extend both to consortia and to counterparties and beneficiaries because our hallmark is transparency, collaboration, and ethics, embodied in this Code of Conduct that we comply with and enforce throughout our value chain. This includes the digital responsibility that leads us to implement a scrupulous data protection policy and guarantee the cybersecurity of all our digital relationships.

MISSION, VISION, VALUES

The mission, vision, and values that guide our performance have been developed in a collaborative process to which every single person in the team contributed, becoming the backbone of who we are and how we work. While reviewing them periodically, all of us at Altair stand for and adhere to them.

Mission: Altair Asesores is a Spanish service company, with an international scope, whose mission is to contribute to the creation of a better world, promoting good governance and development. To do this, we design, manage, and execute projects that create new opportunities and provide sustainable and tailored solutions, identifying and connecting talent with the needs of each country and institution with which we work.

Vision: To be recognized as a multifaceted company that puts people at the center. Consolidate our role as trusted partners and our prestige in international development cooperation consulting, offering innovative and creative solutions of national and global impact in projects that promote the SDGs, in regions where others do not reach, providing a solid gender approach, with the highest quality, transparency, efficiency, and flexibility.

Values:

Moral Courage: We believe in going beyond compliance in all matters related to ethics and business performance. We are committed to responsible and transparent management of the company, which allows us to offer maximum confidence to our partners, clients, and beneficiaries.

Human Approach: We believe in teamwork, the empowerment and development of all people, in generosity, closeness, and empathy, and from that approach, we develop our work.

Equality: At the heart of our projects lies the conviction that all people should have equal access to opportunities, regardless of their sex, gender identity, sexual orientation, creed, race, ethnicity, disability, or any other condition.

Excellence: We seek to bring the highest quality to everything we do.

Flexibility: We are a company capable of adapting even to the most challenging environments and circumstances.
Efficiency: We always seek to achieve the best results through the responsible use of strictly necessary resources.
Innovation: We keep an open mind, we are creative, and we bring initiative, which allows us to offer new approaches and solutions.

WHAT TO AVOID: UNACCEPTED BEHAVIOR

At Altair, we commit to avoiding unacceptable behavior such as (but not limited to):

CORRUPTION

At Altair, we have zero tolerance for any form of corruption, and everyone on the team is obliged to abstain from participating in and commit to reporting any acts of corruption.

Bribes: Every employee at Altair must follow regulations and, in no case, could accept or use bribes to or from the company in relation to third parties. It is specifically forbidden to use illicit payments, through any means, to obtain an advantage or better treatment by any third party. This includes the prohibition of making payments or contributions to political parties, unions, or similar entities beyond what’s acceptable.

Gifts: Anyone working for Altair (staff, experts, collaborators) commits to not accepting presents in any form (objects, services, etc) that could cloud their objectivity or influence a business or professional relationship. This also means that they could not offer direct or indirectly, any gifts to clients, partners, or any other person or entity with the objective of unlawfully influencing such relationships.

FRAUD

Anyone working for Altair (staff, experts, collaborators) is responsible for: ensuring the accuracy and completeness of information in any financial transaction they are involved in, ensuring the documentation in support of approvals is accurate and complete, seeking information when they come across any inaccuracy, verify the information presented in any given bidding, complying with the terms of any contract/subcontract or award, and continuously assessing risks and reviewing policies when needed.

CONFLICT OF INTEREST

Anyone working at Altair should actively avoid any act or situation that will put them in a conflict of interest regarding the organization or the projects and clients Altair works for.

Bias: Anyone working for Altair (staff, experts, collaborators) will lead with the company’s interest at heart and with loyalty, avoiding any private activity or action based on their personal interest. This will assure professional judgments or technical assistance are not influenced by any private interest of any nature (financial, or otherwise).

Anyone working for Altair (staff, experts, collaborators) has to assure that their professional judgment and/or technical assistance are not influenced by any private economic interest when having direct family relationships with a company or an employee of a company that may benefit from certain actions, owning (totally or partially) a company engaged with Altair, or serving on the board of a competitor company. In these and any similar cases, the person working for Altair who might be in a conflict of interest should discuss the situation with their immediate boss, to try to find a transparent solution.

Unfair Advantage: Everyone at Altair should refrain from seeking or obtaining information that has not been publicly released and that could give the company an unfair advantage.

For that same reason, Altair could not participate in designing terms of reference for projects the company will be competing to execute. When Altair has an interest in participating in a project, anyone working for the company should avoid participating in any pre-award activity.

During the decision-making process of a tender or bidding, Altair will avoid any contact with public officials (former or current) who might have an influence on the result.

DISCRIMINATION AND HARASSMENT

We promote a zero-tolerance policy towards any form of discrimination -understood as unfair treatment- or any form of harassment -understood as unwelcome conduct (whether verbal, physical, or visual)- that denigrates or shows hostility or aversion towards an individual based on a person’s race, color, religion, sex (including pregnancy, sexual orientation, and gender identity), national origin, age, disability, and or genetic information (including family medical history).  

We very specifically reject sexual harassment, understood as the unwelcome sexual advances, requests for sexual favors, and/or verbal or physical conduct of a sexual nature, when this conduct explicitly or implicitly affects an individual’s employment, unreasonably interferes with an individual’s work performance, or creates an intimidating, hostile, or offensive work environment.

WHAT TO PROMOTE: BEYOND-COMPLIANCE, GOOD FAITH, AND FAIR DEALINGS

 

WITH CONTRACTORS, PARTNERS, AND COLLABORATORS

Altair is committed to quality and bases its performance on the best national and international practices. Everyone working for Altair should share the common objective of reaching the highest levels of quality and excellence, seeking to develop long-term relationships based on trust and mutual respect.

Everyone working for Altair who participates in a process to select contractors, consultants, and/or partners, is obliged to act objectively applying criteria of quality and cost/benefit, avoiding any conflict of interest.

Everything in this Code of Ethics is applicable to every contractor, partner, and collaborator. A specific adherence to this code will be mentioned in every contract.

FAIR COMPETITION WHEN PARTICIPATING IN A TENDER

Whenever Altair is participating in a tender, the company and all its employees should act in an accountable and transparent manner, always focusing on serving the interest of the project for which the tender was launched and respecting all legal requirements of the tender.

EXCELLENCE

Altair strives for excellence. We are committed to selecting the best talent for our team, providing them with the best work environment possible, constant training, and the flexibility needed to achieve the best standards possible. We also apply criteria of quality and excellence to select our partners, contractors, providers, etc.

We have established processes to guarantee that all our work (inwards and outwards) is monitored and evaluated to ensure our level of excellence is met, as well as all the legal and ethical requirements are respected.

This also affects our outlook on ethics. We stand by a beyond-compliance approach that encourages moral courage across our network of influence, from our executives, to employees, contractors, partners, clients, etc.

THE WORKPLACE AS A SAFE SPACE

Altair is committed to maintaining a safe space for everyone and making sure everyone’s rights are respected and promoted.

We want to be a safe space for anyone working within the boundaries of the company’s performance, which extends to any contract and mission in which Altair participates. Our headquarters in Madrid and the offices we open in the field, our processes, and the networks we build, are all subject to constant evaluation and control to ensure that anyone working with us and/or in projects in which we participate, feels safe and respected.

It is our company’s and our staff’s duty to report any situation that might entail a threat, a risk, or a vulnerability, reporting the details to their immediate hierarchical superior and/or to the Ethics Counsel.

AVOID POLITICAL INVOLVEMENT

Altair respects its employee’s right to engage in politics in any way they see fit (by participating in activities, donating to campaigns, etc) as long as they do so in a personal capacity, not representing the company, and within the limits of what’s legal. Altair does not make political contributions or support in any way to any political party, candidate, or organization, no matter the country, scope, or ideology.

INFORMATION SECURITY AND CYBERSECURITY

At Altair, we are committed to ensuring information security and cybersecurity to protect our business and the confidentiality, integrity, and availability of our valuable information from any risk. This document includes protocols devised to protect systems, networks, and applications from internal and external threats.

Thus, Altair has approved a protocol on information security and cybersecurity that compiles policies and procedures to ensure our company is a safe space. Anyone working with Altair is bound by that protocol: employees and collaborators have to sign their commitment to collaborate in maintaining the policies in place and reporting any threats, and contractors have to sign a confidentiality agreement.

 

HOW TO ACT: PROCEDURE FOR FREE AND MANDATORY REPORTING

 

DUTY AND FREEDOM TO REPORT

Altair wants to encourage its staff, collaborators, clients, contractors, and anyone within its network of influence to maintain an alert attitude toward behaviors and performances that might go against the company’s commitment to go beyond compliance with ethics. Therefore, we promote moral courage in every individual we work with and train our teams to lead by example.

Altair should always be a safe space for anyone to speak up and stand by the values and rules contained in this Code of Ethics. The company is committed to providing the tools and mechanisms for every voice to be heard and actions to be taken to remedy any unwanted and/or unethical situation. A safe space means that, under no circumstance, no acts of retaliation would be accepted against those who, honestly and selflessly, report issues that might go against this Code.

Reporting unethical behavior especially acts of corruption, fraud, and conflict of interest is mandatory for anyone who comes across such violations. Executives and team leaders should promote moral courage in their teams, leading by example and showing zero tolerance for any type of retaliation against those who, in good faith, step up.

ETHICS COUNSEL

Altair has appointed Mr. Juan Antonio Montoro Cavero, with registration number 65.521 from the Madrid Bar Association (Ilustre Colegio de la Abogacía de Madrid) as the external Ethics Counsel to ensure independence in the investigation of any issue that might attempt against this Code.

Because of the nature of its responsibilities, the Counsel will communicate periodically with the executive team, to make sure that any threats are promptly mitigated, and any issues addressed in a timely and effective manner.

Any employee, collaborator, contractor, partner, client, and anyone within the business influence of Altair can contact the Ethics Counsel at ec@altairasesores.es. The Counsel is committed to studying in depth any reported issue and taking action accordingly.

The Ethics Counsel will receive any complaints and alerts from employees, collaborators, contractors, clients, etc, and commits to investigating all violation reports, according to this Code and the applicable law. It is Altair’s duty to maintain the confidentiality of any investigation to the extent the laws and regulations allow. When needed, Altair may report certain investigations to the appropriate authorities.

During any investigation, led by Altair’s Ethics Counsel or by any other external authority, Altair’s staff should faithfully cooperate when required to do so. Again, we commit to creating a safe space for everyone, so under no circumstance, Altair will tolerate any acts of retaliation against those who cooperate in an investigation.

In the face of an issue regarding compliance with the rules and values contained in this Code, the person/s involved in the behavior under investigation will have the chance to explain their acts. Actions that involve corruption, fraud, or go against the law will in no case be tolerated. Altair will take appropriate corrective or disciplinary action for Code violations whenever necessary.

MANDATORY ADHERENCE TO THE CODE

All Altair’s employees and anyone working with us have to sign their express adherence to this Code, specifically stating that they have reported and will report any deviation from the rules and values it contains, especially those referred to fraud, corruption, and conflict of interest. Every time the Code is reviewed and edited, the employees and anyone working with Altair will have to renew their commitment in writing. Any training sessions regarding Ethics, and specifically about this Code will be mandatory for all the staff.

Everyone at Altair is responsible for maintaining a beyond-compliance culture, leading by example, and promoting moral courage, so Altair continues to be a safe space for everyone and a reputable organization.