The behavior of a company and of those it is composed of must be exemplary, and therefore ethics is the very cornerstone of our business. Our values and ethical principles guide us through our actions on a daily basis


In 2002 we adopted the “Rules of Management and Good Governance”, which every Director and employee were bound by, and which in 2014 became our “Code of Ethics”, as well as some “General Policies” which, among others, include Corporate Social Responsibility, Human Resources Policy and Communication Policy sections.

In 2015, new legislation surfaced concerning the prevention of felonies which made it necessary to alter our Code of Ethics and which lead to the development of other policies which will enter into force starting in 2016. This will apply to all of the other companies of the Group.

The Code of Ethics is one of our reference documents and the principles therein not only guide our conduct within the company, but also our relationship with our clients, suppliers, competitors (“Winning the Right Way), allies, Public Administrations, as well as the other companies within the Group.

Each employee receives and signs a personal copy upon admittance to the Group and must strictly obey the ethical and deontological rules therein as well as the applicable legislation. Each employee must act objectively, transparently and independently




Clarke, Modet & Cº’s legal compliance and penal risk prevention system is anchored in the values and principles present in the Code of Ethics, and governs the professional activity of all administrators, counselors, managers, shareholders and employees, as well as the relations with third parties, its subsidiaries included, regardless of the existent contractual relationship.

The Clarke, Modet & Cº subsidiaries, as independent legal entities, are charged with doing everything at their disposal to establish a legal compliance and penal risk prevention system adapted to the corresponding local legislation and based on the essential principles of the legal compliance system established by Clarke, Modet & Cº.





Our commitment to adopting an effective legal compliance and penal risk prevention system resides in the company’s wish for transparency and for a strengthening of the values and principles of Clarke, Modet & Cº.

The general principles which must be respected and which govern the relations within the company and the company’s relations with third parties, are the following:

1.     Business Ethics

The Company’s corporate ethics, which can be found in its Code of Ethics, make up the fundamental principles that govern our professional activity.

2.     Client Orientation

Our success is based on our relationship with the client. We should always treat each client as a unique individual and offer a quality service aimed at exceeding the client’s expectations.

3.     Loyalty to the Company

Analyse, ponder and weigh each of the decisions we make and which will affect the Company or any of its employees. Each and every one of us is responsible for the consequences of our actions.

4.     Trust in our Human Ressources

The trust placed in our employees is one of our core values, along with team work. Sharing our knowledge in order to achieve a common goal is one the keys to the company’s success.

5.     Constant Improvement

The Company’s permanent objective resides in the constant improvement of its human resources’ capacities and development, and in the guidance provided for the purpose of achieving the desired results while relying on past experiences. We are all part of the Company’s success.

6.     Innovation and Quality

Doing quality work and adding value with useful and efficient solutions is our commitment. Our goal is to strive to always offer the clients customised services and to anticipate their future needs in order to create more value with less resources and effort.

7.     The environement

The Company is committed to reducing the use of toxic material and residue, as well as to recycling. Respecting the environment is everyone’s duty.