Conduct Code

On 31 March 2017, the Imesapi Group, which includes the Sermicro Group, approved a new Corporate Compliance Programme. The aim of this Programme is to promote a true business ethics culture and reaffirms the Group’s culture of respect for the law.

An active role has been taken in the fight against crimes in business activities and, for this reason, technical, organizational and specific personnel measures have been adopted, as well as surveillance and control measures, and the appropriate sanctioning regime to prevent any type of infractions or unlawful actions from occurring.

In this context, and in order to meet this objective, the Sermicro Group has published the following documents internally:

ACS Code of Conduct.


General Protocols ACS Industrial:

  • Framework Protocol for the ACS Industrial Corporate Compliance Programme.
  • Regulatory Compliance Protocol.
  • Protocol for the Communication of Allegedly Irregular Facts.
  • Protocol for the Activation of the Corporate Defence Procedure.
  • Training Protocol for Professionals on Corporate Compliance issues.
  • Protocol on the profile, experience and organic location of the Corporate Compliance Officer.
  • Interior Regime Instructions.

Crime Prevention Plan of the Imesapi Group with attached documents:

  • Code of Conduct.
  • Computer Code of Conduct.
  • Manual on Professional Courtesies.
  • Protocol on the Prevention of Money Laundering and Financing of Terrorism.
  • Anti-corruption protocol.
  • Protocol on the Protection of Industrial and Intellectual Property Rights.
  • Protocol for the Treatment of Confidential Information.
  • Protocol on the Protection of Personal Data.
  • Protocol on Environmental Protection

The design of the Corporate Compliance Programme includes and applies good practices for the prevention of criminal risks and the promotion of ethical business behaviour, in line with the requirements of the Criminal Code.

Any person who has knowledge or reasonable suspicion of any type of infraction or unlawful action may report it through the following email address: or to the postal address, Complaints Formulation Channel, Imesapi Group, Avenida Manoteras, 26. 2ªPlanta. 28050 Madrid, Spain. The aforementioned means may also be used as a means of resolving doubts regarding the Corporate Compliance Program.