The SMC Group is committed to conducting our business ethically, in line with our RADIQUAL© approaches to work. We are committed to the highest business standards, and this policy provides an overview of our approach to corruption and bribery. For any further details, please get in touch with me.

Overview and Scope

The SMC Group, led by Sanjukta’s activist values and origins, explicitly condemns and prohibits any corruption, bribery, or unethical behaviour, directly or indirectly, from anyone operating within the team.

Corruption refers to the misuse of entrusted power for personal gain, undermining the principles of justice and equity. Bribery is a specific form of corruption involving the offer, promise, or acceptance of a benefit as an inducement for an illegal, unethical action or a breach of trust. Unethical business practices encompass a broader category, including actions compromising the integrity, fairness, and dignity of business operations and relationships. This contradicts the principles of participatory and decolonial approaches that emphasise ethical, transparent, and equitable practices.

All employees, representatives, partners, and subcontractors are prohibited from engaging in corruption.

Our Standards

Beyond the scope of individual Codes of Conduct sent to each client during the project kickoff stage, the terms of individual contracts with partners and subcontractors, and other legal documents, this policy holds The SMC Group to the following standards:

• Gifts, hospitality, and business expenses must meet their needs.
• They are not to be used to influence political or business decisions.
• All political contributions need to be transparent and compliant with relevant laws.

Whistleblowing

Given Sanjukta’s experience as a journalist, supporting whistleblowers and advocating for improved whistleblower protection, our whistleblowing approach is political and practical. We encourage whistleblowers to come forward, especially if they uncover corrupt practices at The SMC Group.

I have a secure and confidential reporting mechanism available to all clients, partners, subcontractors, and relevant vendors. This encourages them to report any unethical behaviour or corruption they witness. In alignment with the EU Whistleblower Protection Directive (Directive (EU) 2019/1937), which mandates the protection of individuals reporting breaches of EU law, The SMC Group can ensure that whistleblowers are safeguarded against retaliation, have their identities protected, and are provided with clear channels for disclosure, thereby fostering an environment of transparency and integrity.

Risk Assessment

I regularly conduct risk assessments of clients, projects, partners, contexts, and my operations. This involves thoroughly examining internal and external operations to identify areas vulnerable to unethical behaviour, corruption, or breaches in compliance with relevant laws and policies.

This includes evaluating how these risks might impact my vision, approaches, and communities. It prioritises them based on severity, and I implement controls to mitigate these risks. Practical risk assessment is dynamic, requiring regular updates and reviews to adapt to new challenges and ensure the integrity of The SMC Group’s operations.

Standards and Procedures

In establishing our standards and procedures, I focus on creating a framework that ensures all actions taken by The SMC Group and its associates align with our core values of justice, equity, diversity, and inclusion. This involves setting clear guidelines for ethical behaviour, defining processes for reporting and addressing misconduct, and implementing regular training sessions. These procedures are designed to foster a culture of transparency and accountability, ensuring that we comply with legal requirements and uphold our commitment to ethical excellence in every aspect of our work.

Training and Awareness

In establishing our standards and procedures, I focus on creating a framework that ensures all actions taken by The SMC Group and its associates align with our core values of justice, equity, diversity, and inclusion. This involves setting clear guidelines for ethical behaviour, defining processes for reporting and addressing misconduct, and implementing regular training sessions. These procedures are designed to foster a culture of transparency and accountability, ensuring that we comply with legal requirements and uphold our commitment to ethical excellence in every aspect of our work.

Monitoring and Review

In terms of monitoring and review, I actively oversee the implementation and effectiveness of our policies and procedures. This involves regular audits, feedback sessions, and reviews of our practices to identify any areas for improvement. By maintaining a cycle of continuous evaluation, I can ensure that The SMC Group not only complies with current standards but also adapts to new challenges and remains a leader in ethical business conduct.

Approvals and Reviews

This policy was formally approved by management at The SMC Group in March 2024. I will notify you of any changes by posting the new Anti-Corruption Policy on our website. Two transparency experts independently reviewed it, and though their identities are anonymised for the website, it is available to those who would like further information. Please get in touch with me for more.

[This policy was last updated in March 2024. It is reviewed semi-annually and formally updated at the end of each fiscal year in Spain].