Compliance

Our commitments

Sumitec supplies strapping and packaging consumables, strapping machinery and technical service to businesses. This page sets out the commitments and procedures we follow in that work. They apply to everyone who acts on behalf of Sumitec, and we ask our customers, suppliers, carriers and agents to respect them in their dealings with us. Where the law sets a stricter rule, we follow the law.

Questions about this page can be sent to dev@biosabau.com.

Export controls

We comply with the export-control and sanctions laws of the European Union and Spain, including the EU rules on dual-use items and the EU restrictive measures, and, where they apply to the goods, the transaction or the parties, with those of the United States and other countries.

Before we issue a quotation, and again before we ship goods or provide a service:

• we screen the customer, the end user and the other parties involved, such as consignees, freight forwarders and agents, against the applicable sanctions lists, including whether they are owned or controlled by listed persons;
• we check the destination against embargoes and other country restrictions;
• we check whether the goods need an export license for the destination and the end use, and we do not ship until any license required has been granted;
• we ask for end-use and end-user information, and for a signed end-use statement where appropriate. Customers must provide this information when we request it.

We do not deal with sanctioned persons or entities, or with entities they own or control, where the law prohibits it, and we do not supply goods or services for prohibited end uses, including uses related to weapons of mass destruction. Our General Terms of Sale prohibit re-export in breach of these laws, including to the Russian Federation and Belarus where EU law requires it.

We stop a transaction when warning signs cannot be resolved, for example an unusual route or destination, reluctance to give end-use information, or payment from an unrelated third party. We keep records of our checks for as long as the law requires.

Anti-bribery

We have zero tolerance for bribery and corruption in any form, whether they involve public officials or private parties.

• We do not offer, promise, give, request or accept bribes, kickbacks or any other improper advantage, either directly or through others.
• We do not make facilitation payments, meaning small unofficial payments to speed up routine official actions, even where they are customary.
• We give or accept gifts and hospitality only when they are modest, occasional, transparent and connected with a legitimate business purpose. We never give or accept cash or cash equivalents, and we decline anything that could influence, or appear to influence, a business decision, in particular during a tender or a negotiation.
• We choose agents, distributors and other intermediaries with care, pay them only fair compensation for legitimate services, and require them to follow these rules when they act for us.
• We record every transaction accurately in our books.

We comply with the Spanish Criminal Code and, where they apply, with other anti-corruption laws, such as the U.S. Foreign Corrupt Practices Act and the UK Bribery Act.

Code of conduct

• Fair competition. We compete on the merits of our products and service. We do not agree on prices, customers, markets or bids with competitors, and we do not exchange commercially sensitive information with them.
• Human rights and labor standards. We respect internationally recognized human rights. We do not accept forced or compulsory labor, child labor, human trafficking or unlawful discrimination, in our own work or in our supply chain. We expect our suppliers to meet the same standards, to respect freedom of association and to comply with the law on wages and working hours, and we take this into account when we choose them.
• Health and safety in technical service work. Service personnel work only in safe conditions: they follow the safety rules of the customer’s site and the manufacturer’s instructions, use suitable protective equipment, isolate machines from their energy sources before working on them, and stop work when it is not safe to continue.
• Conflicts of interest. Anyone acting for Sumitec must avoid situations in which personal interests conflict with those of the business, disclose any potential conflict and stay out of the decisions it affects.
• Truthful information. We describe our products and services accurately, and we do not make claims, including environmental claims, that we cannot substantiate.
• Confidentiality. We protect the confidential information of our customers and suppliers and use it only for the purpose for which it was given.

Data protection

We process personal data in accordance with the General Data Protection Regulation (GDPR) and the Spanish Organic Law on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD). In short:

• we process the personal data you or your company send us, the results of our export-control and sanctions screening, and the technical data needed to deliver and protect the website;
• we use it to answer requests, prepare quotations, perform contracts and carry out the checks that export-control and sanctions laws require;
• we do not use analytics, profiling, automated decisions or marketing, and the website sets no cookies;
• you can exercise your rights of access, rectification, erasure, restriction, portability and objection by writing to dev@biosabau.com.

The Privacy Policy gives the full details.

Reporting

If you are concerned about conduct connected with Sumitec that may breach the law or these commitments, such as a possible breach of sanctions, bribery, an unsafe practice or the misuse of personal data, please tell us by e-mail at dev@biosabau.com, with “Compliance” in the subject line. You do not have to give your name.

• We treat every report confidentially. The identity of the person reporting, and of anyone mentioned in the report, is shared only with those who need it to handle the report, or where the law requires it.
• We do not tolerate retaliation against anyone who reports a concern in good faith, or who helps us look into it, even if the concern turns out to be unfounded.
• We acknowledge each report, look into it promptly and impartially, and tell the person reporting what we have done, as far as confidentiality and the law allow.
• Personal data in reports is processed only to handle them, as explained in the Privacy Policy.

You can also report to the competent authorities, including through the external reporting channels provided for in Spanish Law 2/2023 of February 20, on the protection of persons who report regulatory infringements and the fight against corruption.