Ethics and compliance

Our organization has implemented an Ethical Channel with the aim of establishing a confidential communication channel that allows the reporting of inappropriate conduct, thus promoting a safe work environment, free of harassment and discrimination, and promoting an ethical business culture based on transparency and good government.

Both the Ethical Channel and the management and investigation of the communications that are carried out through this medium, are in compliance with all the requirements, guarantees and protection measures provided in laws and regulations.

Code of Ethics

The Code of Ethics is a fundamental element of the organisation and management model of our Group that provides behavioural guidelines for various situations to all its members and collaborators, considering their diverse circumstances and governed at all times by the values and principles that it promotes.

The values of the group that are established in the Code of Ethics are:

Quality

Excellence

Functionality

Simplicity

Innovation

Talent

The objective of this Code of Ethics is to establish the guidelines and basic principles that must guide the ethical behaviour of all the people who work at and make up the Dess Dental Group, their daily development within internal relations and the interactions they have with all stakeholders, managers, suppliers, customers and companies of the Group.

Through this Code of Ethics we compile our values, mission and ethical standards, which make up our corporate culture and provide all our employees with the framework for day-to-day decision-making. Complying with these guidelines will help us to be a Group that bases its management model on transparency, equality and honesty. Compliance with this Code and its rules, as well as professional management based on the principles set out in it, shall be mandatory.

The scope of the Code of Ethics

The Code of Ethics is addressed to all levels of management, as well as to individual employees, external professionals and specialists, suppliers and other stakeholders. It is public knowledge and will apply to both natural persons and legal entities at national and international level, affecting all employees, shareholders, Board members, and any other people linked to the Group, including volunteers, unpaid trainees, stakeholders: customers, suppliers, internal collaborators and other interested parties linked to the Dess Group, which comprises the following companies: Mila Bidco, S.L.U. as parent company; Sensis Invest, S.L.U.; Terrats Medical, S.L.U; Humanus Dental AB; Sensis Invest USA; Geryon Holdings LLC; and Medealis GmbH, and any other company that could join the Group in the future (hereinafter, the “Group”).

The recommendations contained in the Code of Ethics do not supersede any provision of any applicable convention, law, regulation or other applicable provision. In this sense, this Code does not replace other internal policies and must be applied in conjunction with other procedures and protocols that the Dess Dental Group has implemented in order to be able to deal with the greatest number of possible scenarios.

Our Values

The essential foundations for achieving our goals are the values that define us as a Group, which are as follows:

Functionality:

The importance of our products lies in their practicality and effectiveness, with a clear focus on ease of everyday use for our customers.

Simplicity:

Our designs are simple and precise, prioritising clear, functional, and safe solutions for professionals and customers.

Quality:

Our products are manufactured under the strictest quality controls, being accredited by the most rigorous international certifications. For us, quality is intrinsically linked to our business.

Innovation:

We are committed to continuous improvement, constantly seeking to create value in our products by pursuing the most up-to-date solutions in the field of dentistry and the technology applied to it.

Excellence:

Our aim is to provide high-quality products; therefore, all members of the Group must act diligently, responsibly and efficiently, focusing on excellence, quality and innovation, and striving at all times to achieve the best results.

Talent:

We recognise and nurture our talent, promoting and prioritising personal and collective growth in a responsible manner.

Principles of ethical conduct of the Dess Dental Group

The Group is guided by the following ethical principles, which aim to foster a culture of ethics and compliance in our dealings with all business partners and stakeholders:

Honesty: All members of the Group are committed to promoting conduct
based on honesty and mutual trust. Any failure to uphold this principle in
the communication of information, both within the company and
externally, will be contrary to the Code of Ethics. Furthermore, the information provided by the Group’s professionals to its suppliers shall be
truthful and not presented with the intention of misleading.
Transparency: The Group applies standards of transparency,
information and protection; it is committed to offering a quality of services
and products equal to or higher than that established by law, competing
in the market and carrying out marketing and sales activities based on
the merits of its products and services. Contracts with the Group’s
customers shall be drafted in a clear and straightforward manner. In pre-
contractual or contractual relations with customers, transparency shall be
promoted and information provided on the various available options,
particularly regarding services, products and rates.
Confidentiality: The Group guarantees the confidentiality of its
customers’ data, undertaking not to disclose it to third parties, except
with the customer’s consent or where required by law or in compliance
with court orders or administrative rulings.

Principles of the Compliance Management System

The principles governing the Compliance Management System are:

Protection of intellectual and industrial property
Commitment to public health
Protection of corporate resources and cybersecurity
Fight against corruption and prevention of conflict of interest management
Relations with government agencies, civil servants and the authorities
Due diligence in promotional practices
Control on gifts, hospitality and other courtesies
Respect for free competition
Due diligence in the administrative, economic and financial management of the Group
Commitment to the environmental protection
Collaboration in the prevention of money laundering.
Protection and security of our staff.

Code of ethics

Ethics Alert Channel

Protection of Reporting Persons and Interested Parties

Any reporting person shall be entitled to protection when reporting any unlawful activity of which they have become aware, provided that there are reasonable grounds to believe that the information reported is plausible. It is an essential requirement that the information provided is consistent, clear, and concise, and, where possible, accompanied by evidence supporting the reported facts.

The identity of any reporting person and of the persons involved in the reported matter shall be kept confidential as well as the information provided.

The absence of retaliation of any kind against the reporting party shall be guaranteed, provided that he/she acts in good faith, without prejudice to criminal, disciplinary or other sanctions in the event that the reporting party himself/herself has participated in the reported matter, constituting a breach or irregularity from the perspective of current legislation.

Any person who has made use of the Ethics Alert Channel through which he/she has sent any type of communication or query shall have the right to be informed by the Compliance Committee of the corresponding progress and the outcome of the investigation, in the specific case that any such internal investigation has been initiated. To this end, the reporting party will receive an identification code pertaining to his or her communication for tracking purposes.

Any reporting person shall have the right to withdraw the report if he/she does not wish to continue with the ordinary processing, allowing the report to be withdrawn once it has been made. However, if there are reasonable indications that a breach or irregularity has been committed based on the facts reported, the Compliance Committee will initiate a case ex officio through the corresponding procedure.

Reporting persons are responsible for the truthfulness of their identity and all information transmitted and for acting in good faith. Dess Dental Group reserves the right to disclose the identity of the reporting party to the authorities if the reporting person has acted in bad faith or a court order has been issued.

General principles

The Ethical Alert Channel shall be governed by the following principles:

Principle of confidentiality and data protection. The confidentiality of the identity and information provided by the reporter is guaranteed, ensuring its confidentiality and complying with data protection regulations.
Principle of non-retaliation. Any form of retaliation or discrimination against the reporter by virtue of the communication made is prohibited. The Compliance Committee shall act immediately if there are indications of retaliatory measures against whistleblowers.
Principle of proportionality. All activities shall be carried out in accordance with applicable law, in an objective and appropriate manner and respecting the principle of proportionality.
Principle of impartiality and transparency. The investigation and assessment of communications shall be carried out in an objective, impartial and transparent manner, respecting the rights of all parties involved and ensuring the proper conduct of the investigation process.
Principle of collaboration and cooperation. Active collaboration and cooperation between the entity, the reporting parties and the competent authorities is encouraged to ensure effectiveness and efficiency in the management of communications.
Principle of access to information. The parties involved have the right to access relevant information and to be informed about the progress and results of the investigation, always respecting legal and confidentiality limits.
Principle of compliance with the law. The ethical channel of the entity shall be governed by strict compliance with the applicable laws and regulations, ensuring that all actions related to communications are carried out within the legal framework.
Principle of protection of the rights of the persons involved. Throughout the investigation process, respect for and protection of the following fundamental rights shall be guaranteed:

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Right to honour.

The reputation and good name of the persons involved shall be preserved, avoiding any defamation or unjustified damage to their reputation.

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Right to the presumption of innocence.

The right to the presumption of innocence shall be guaranteed throughout the process, up to the stage of the conclusion of the investigation.

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Right to information.

The persons involved shall have the right to be informed in a clear and precise manner about the accusations and the evidence that supports them, guaranteeing their right to know the facts reported and to participate in the process.

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Right to defense.

The persons involved are given the opportunity to exercise their right to defense in an effective manner, presenting evidence, arguments and allegations to refute the accusations against them.

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Right to protection.

All necessary measures shall be taken to safeguard the integrity and security of the persons involved, avoiding any reprisal or prejudice derived from their participation in the investigation process.

Principle of remediation. The protection and, if necessary, redress of the legitimate rights and interests of the reporter and of the persons involved is ensured by taking appropriate measures to prevent or remedy any harm arising from the communications or investigations.

The entity reserves the right to impose sanctions on a reporter who makes a communication with knowledge of its falsity, in order to safeguard the veracity and integrity of the ethical channel, and to prevent misuse or abuse.

Processing of communications

The corresponding Ethics Alert Channel will be managed through an appropriate communications procedure. The Channel Managers will be in charge of receiving all communications from reporting parties, either anonymously or with corresponding provision of their personal data. These are the persons whom all reporting parties with a legitimate interest in communicating any type of irregularity or non-compliance committed (or that could potentially be committed) within the group should contact.

Channel managers

Compliance Committee

Compliance Officer: César Escribano Patón
Compliance Committee member: Carlos Jerez Fabrega, Mireia Corral Bertran

The Group will ensure the confidentiality of personal data and will comply with Data Protection regulations, and specifically with the provisions of Regulation (EU) 2016/679 of the European Parliament and the Council, General Data Protection and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights.

If you would like to visit our Ethical Alert Channel policy, click here

Ethics Alert channel