Zaragoza Medienerco S.L.U. (hereinafter “Medienerco” or the “Organisation“) and its integrated companies and subsidiaries (hereinafter “Zaragozá Group“) are committed to conducting business with integrity. This implies avoiding any form of corruption and complying with all applicable anti-bribery and anti-corruption laws and other regulations (hereinafter “Anti-Corruption Regulations“), as well as the recommendations of International Organisations such as the OECD and the United Nations. This commitment is duly reflected in our Code of Ethics. 

THE ZARAGOZÁ GROUP rejects any  type of corruption, either  direct or indirect,  private or public.

For the purposes of this Anti-Corruption Policy, it must be assumed that these Anti-Corruption Regulations apply to all collaborators, without exception and to each party involved with the ZARAGOZÁ GROUP in their professional and business activities (clients, suppliers, subcontractors, partners, workers, etc.) regardless of where they are located in the world, as well as to all the companies that make up the Zaragozá Group.

This Anti-Corruption Policy reflects the organisation’s position of zero tolerance towards any form of corruption or unlawful conduct in the professional sphere. All employees (internal and external) of the ZARAGOZÁ GROUP, including the management committee and the CEO, are required to comply fully with the provisions of this document and the Anti-Corruption Regulations.

Understanding and complying with this Anti-Corruption Policy and associated regulations is an essential condition for maintaining an employment/commercial relationship with the ZARAGOZÁ GROUP, and under no circumstances will non-compliance in this respect be tolerated. Any case of breach will be investigated and may result in the imposition of legal and disciplinary measures.


The organisation strictly prohibits:

Offering or accepting bribes to or from public officials or private individuals.

The ZARAGOZÁ GROUP will act, in all cases, in a professional, honest, transparent and impartial manner; using objective criteria for the contracting of products and services, as well as for the achievement or obtaining of work-projects. Under no circumstances will it provide or accept economic benefits or other types of advantages that condition the free, transparent and honest commercial relationship. In other words, it does not pay bribes or tolerate the payment of bribes. The personnel of ZARAGOZÁ GROUP are prohibited from giving or offering bribes or any other type of remuneration or similar consideration, anywhere in the world, to any person or public or private entity (client or potential client, public official, political party, candidate for political office or any intermediary) for the purpose of: 

  • Unlawfully influencing the acts or decisions of that person or entity.
  • Unlawfully obtaining or retaining business for the organisation; or securing any improper advantage.

The ZARAGOZÁ GROUP’s personnel are prohibited from accepting or receiving bribes or any other form of remuneration or similar consideration, anywhere in the world, from any person or entity that is intended, or could be perceived, as an attempt to unlawfully influence the acts or decisions of the recipient, unlawfully obtain or retain business or a business advantage or secure any improper advantage for the offer related to the bribe.

Similarly, providing or receiving gifts, meals, entertainment or anything of value from any person or entity in connection with company business is prohibited, unless provided or received in accordance with the anti-corruption policy and rules.

Offering or accepting facilitation payments to initiate or expedite administrative processes or procedures.

Facilitation or expediting payments are prohibited. Facilitation payments are small payments made to Public Officials to expedite or facilitate non-discretionary actions or services, such as obtaining a regular business licence or permit, issuance of entry or exit visas, police protection, telephone, power or water services, or expediting customs clearance, among others.

ZARAGOZÁ GROUP strictly prohibits facilitation payments.

In order to guarantee compliance with the Anti-Corruption Regulations, the ZARAGOZÁ GROUP prohibits facilitation payments completely in all its areas of activity. Employees of the ZARAGOZÁ GROUP must refuse to make such payments at all times. 

Offering or accepting gifts and hospitality to or from public officials or any other third party in contravention of this Policy.

The collaborators of the ZARAGOZÁ GROUP may not offer or accept from third parties, gifts, invitations, prizes, benefits or other incentives that could affect the impartiality of any of the parties, influence a business decision or lead to a poor execution of the professional duty. Similarly, under no circumstances may payments or donations in cash or goods easily convertible into cash (bearer cheques, gift vouchers, etc.) be offered or accepted. 

Making contributions on behalf of the organisation for political purposes.

The ZARAGOZÁ GROUP follows a policy of strict neutrality; it does not make donations to any political party or candidate or foundation that serves as a vehicle for political contributions.

The organisation’s Anti-Corruption Policy does not prohibit its employees from making voluntary and personal political contributions, from participating in the political process on their own time and at their own expense, from expressing their personal views on legislative or political matters, or from otherwise personally participating in political activities.

Obtaining favourable treatment by using sponsorship or donations as a means to achieve it.

The ZARAGOZÁ GROUP contributes to the development of the areas in which it operates and allows reasonable donations to charitable organisations. However, the Group is aware of the risk of improper donations and sponsorships that may be interpreted as mechanisms for making payments or contributions with the improper purpose of obtaining favourable treatment. 

In this regard, ZARAGOZÁ GROUP must ensure that donations to charities do not disguise illegal payments to Public Officials or other persons in violation of these Anti-Corruption Regulations. Any donation or sponsorship activity made by the organisation to a charity must not give rise to the slightest doubt or appearance of impropriety or appropriateness and must certainly not involve a breach of any of the Anti-Corruption Regulations. applicable law or regulation. In any case, before any collaborator undertakes to make a donation to a charitable organisation on behalf of the ZARAGOZÁ GROUP, he or she must have the necessary internal and, where appropriate, external authorisations.

Using company business relationships and contracts to benefit themselves or a third party.

The collaborators and employees of the ZARAGOZÁ GROUP must avoid situations or transactions in which their personal interests may conflict or could be considered to be in conflict with the interests of the organisation. In this way, it is strictly forbidden to: 

  • Act by using any information obtained through your work with the ZARAGOZÁ GROUP for personal gain or for the benefit of a third party; 
  • Transmit such information to a third party for its own or the third party’s benefit; 
  • Act in any way that could be construed as insider trading. 

Conflicts of interest may arise if individuals have a personal interest in business related to ZARAGOZÁ GROUP. Personal interest can be direct or indirect, and refers not only to personal interests, but also to those of family and friends. In the event of a possible conflict, the interests of the organisation will always take precedence. 

The personnel of the ZARAGOZÁ GROUP must inform their line manager of any potential conflict of interest that may arise.

Establishing business relationships with third parties without complying with minimum due diligence duties in the knowledge of third parties.

The relations maintained by the Zaragozá Group and any of its employees or collaborators with suppliers must always be governed by the principles of honesty, integrity and transparency.

The Zaragozá group will choose its suppliers based purely on criteria of objectivity and impartiality and always safeguarding the best quality of the good or service.

In those circumstances in which relationships with third parties are necessary for professional purposes, ZARAGOZÁ GROUP employees must choose them with due diligence in accordance with the provisions of the integrated management system implemented in the organisation.  All relationships with third parties which may involve contact with Public Officials must be set out in a written contract that includes appropriate language and maintains absolute respect for the applicable anti-corruption regulations.


All employees and managers of the Zaragozá Group declare that they are aware of the existence of this Anti-Corruption Policy and are familiar with its contents, and each of them has access to a copy of it. 

Regardless of the hierarchical position of all the people who make up the Zaragozá Group, the rules, provisions and indications regulated in this Anti-Corruption Policy are inviolable and must be respected without limitation.

All employees who join any of the organisations that make up the Zaragozá Group as of the entry into force of this Anti-Corruption Policy must be informed of its existence, be given access to a copy of it and accept full compliance with its principles.


When any employee witnesses or becomes aware of any conduct or action in their work department that violates or may constitute a breach of this Anti-Corruption Policy, he or she must inform the line manager or report it through the mechanisms established by the company for the formulation of suggestions and complaints. In the event that the complaint is directed against the complainant’s line manager, the latter must report the breach of this Anti-Corruption Policy to the person responsible for the Zaragozá Group’s People Area.

Once the complaints have been forwarded to the complainant’s line manager or to the head of the People Area, as the case may be, the latter must bring them to the attention of the Medienerco Management Committee (hereinafter, the “Management Committee“). 

In this way, the Management Committee will supervise full compliance with this Anti-Corruption Policy, resolving and ruling on possible breaches of this Anti-Corruption Policy. The Management Committee meets weekly, and the resolutions and decisions adopted by it are recorded in the minutes.  

The Management Committee shall have the following powers in relation to the purpose of this Anti-Corruption Policy:

  • Promote awareness of this Anti-Corruption Policy and ensure compliance with it.
  • Propose the necessary updates or modifications to adapt the Anti-Corruption Policy to significant changes in legislation.
  • Resolve the complaints and communications that have been forwarded to it due to alleged non-compliance with this Anti-Corruption Policy. If the infringement gives rise to a labour misconduct, it will be sanctioned in accordance with the labour regulations in force.
  • Make periodic reports or when requested by Medienerco’s Management Body, regarding compliance with this Anti-Corruption Policy. 


This Anti-Corruption Policy was approved by the Board of Directors of Medienerco on 28 May 2021, coming into force on the same date.