Suppliers´ code of ethics

01. Introduction

CreaMNN promotes the application of these standards in accordance with the International Bill of Human Rights, the UN Global Compact and the principles for actions and recommendations for business activities published by the United Nations, the Organisation for Economic Cooperation and Development and the International Labour Organisation. 

This Code must be read together with the clauses governing the legal relationship between the supplier and CreaMNN (general terms, contracts, etc.). 

CreaMNN will periodically review this Code and make any necessary changes to it. 

Suppliers must know their contents, accessible at url: https://suppliers.CreaMNN.com on the CreaMNN supplier site. 

If significant changes are made to it and the supplier does not agree or cannot comply with those changes, it must notify CreaMNN of that fact. 

02. Purpose

This Code establishes the basic principles that must be followed by all suppliers with which CreaMNN has a relation. 

We hope that our suppliers will implement the necessary policies and procedures to ensure compliance with this Code and carry out the necessary communication and training actions to ensure that their employees, and their supply chain, understand and act in accordance with the contents of this Code. The User agrees to make appropriate and lawful use of the Website and its contents, in accordance with applicable law, these General Terms of Use of the Website, generally accepted morals, good faith and public order. 

03. Scope

This Code applies to all suppliers who, when performing their business activity, have a relationship with CreaMNN when providing them with goods or providing them with services, regardless of their nationality and place where the services are provided. 

04. Basic principles

This Code applies to all suppliers who, in the course of their business, have a relationship with CreaMNN through the provision of goods or services, regardless of nationality or place of supply.

4.1 Compliance with legislation

CreaMNN suppliers agree to strict compliance with the current law applicable to them at any given time. They must also comply with the extra-territorial regulations that are binding for CreaMNN in the exercise of their activity, which will be identified in the clauses governing the relationship between them (general terms, contracts, etc.).

If any of the standards of this Code contradicts the applicable legal provisions, we expect the suppliers concerned to inform us of that circumstance and work with CreaMNN to reach a solution that complies with both the applicable legal provisions and, to the extent possible, this Code.

4.2 Human rights commitment

CreaMNN aims to promote human rights in its relations with suppliers. Therefore, CreaMNN strives to work with suppliers that have human rights policies and procedures consistent with ours, which essentially specify the following for suppliers:

The User must refrain, inter alia, from:

Ensuring that its employees are recruited in accordance with current employment and migration law, international conventions and other employment laws and regulations, regardless of the jurisdiction of origin or destination.

Ensuring that employees are treated with respect and dignity, guaranteeing a working environment in which diversity and inclusion are promoted and in which discriminatory attitudes are not tolerated.

Fostering respect for and compliance with occupational health and safety rules in accordance with current legislation, providing its workers with a safe and risk-free environment and promoting accident prevention amongst all the staff.

Providing employees with a fair salary that is at least equal to the legal minimum or that established by collective agreement if higher.

Respecting working hours such that they do not exceed the maximum hours permitted by the applicable law.

Respecting the freedom of association of its employees and particularly with regard to collective bargaining, without any adverse consequences or reprisals arising from their exercise.

Ensuring that it complies with ILO Convention No. 138, on the minimum age for employment, and with ILO Convention No. 182, on the elimination of the worst forms of child labour and ensuring that minors are not recruited in accordance with those conventions.

CreaMNN will notify the supplier when it becomes aware that it has committed serious human rights violations to ensure the prevention, mitigation and promotion of the repair of harm caused. CreaMNN must refrain from operating with those suppliers that do not demonstrate progress in this area. CreaMNN also strives to support human rights in its supply chain by promoting actions and practices that are consistent with the UN Guiding Principles on Business and Human Rights and objectives included in the CreaMNN Commitment on Human Rights.

4.3 Environmental commitment

Environmental protection, sustainability and the aspiration to "eco-efficiency" are a priority for CreaMNN. The group of which CreaMNN is a member has developed an environmental policy and has adhered to the main international commitments in this area: Environmental protection, sustainability and the aspiration to "eco-efficiency" are a priority for CreaMNN. The group of which CreaMNN is a member has developed an environmental policy and has adhered to the main international commitments in this area:

UN Global Covenant


Ecuador Principles

CDP (Carbon Disclosure Project)

Principles for Responsible Investment

CreaMNN suppliers agree not to perform environmental actions that are contrary not only to applicable law but also to those international commitments.

4.4 Supply chain (subcontracting)

Unless expressly authorised by the clauses governing the legal relationship between the supplier and CreaMNN, the use of subcontractors by the supplier is not permitted. In those cases in which this possibility is envisaged, suppliers must ensure that, when their supply chain provides products or services to CreaMNN, it is aware of, understands and complies with the standards contained in this Code. To do so, suppliers must implement the measures they consider appropriate to monitor their supply chain and mitigate any potential adverse impact on CreaMNN's reputation or integrity.

Additional controls may be established in the clauses governing the legal relationship between the supplier and CreaMNN (general terms, contracts, etc.) when relationships are maintained with higher risk suppliers (for example, suppliers that subcontract products in emerging countries).

4.5 Fight against corruption

CreaMNN does not tolerate any form of corruption or bribery in any of the activities it carries out, and we also expect this from our suppliers.

CreaMNN has adequate internal policies, procedures and controls to comply with the obligations that the different legal systems establish in relation to corruption prevention and prohibits its staff from offering, promising, directly or indirectly making any type of payment, gift, bonus, donation, job offer, sponsorship, preferential treatment or benefit of any type, that aims to influence or attempt to influence, so as to obtain an unjustified benefit or advantage, the decisions of third parties, individuals, public employees or authorities, with regard to the activity of CreaMNN, or with regard to persons working at CreaMNN. This prohibition also affects what are known as facilitation payments¹.

¹ Facilitation payments are payments of small amounts of money to public officials in exchange for ensuring or streamlining the course of an administrative process or routine action such as, for example, obtaining a permit or licence over which the institution has a right granted by law. What characterises facilitation payments of other forms of bribery is that the party making this payment does not intend to obtain a business, contract or commercial transaction but only to expedite a procedure and the fact that what is usually to be achieved with payment is something to which it is entitled.

In relation to the provision of goods and services to CreaMNN, suppliers agree to develop appropriate policies and procedures to comply with the applicable legislation in this area and not to offer, promise or make, directly or indirectly, any type of payment, gift, gratification, sponsorship, preferential treatment or benefit of any type that has the purpose of influencing, or attempting to influence, so as to obtain an unjustified benefit or advantage in the decisions of third parties, public employees or CreaMNN authorities or employees.

Not to accept gifts, payments, commissions or any other personal benefits from other third parties or CreaMNN employees.

Maintaining an adequate system of accounting records for all transactions, expenses and income, without omitting, concealing or altering any data or information, so that accounting and operating records accurately reflect the facts.

Not to make facilitation payments.

4.6 Prevention of money laundering and financing of terrorist activities

CreaMNN has the duty and legal obligation to prevent funds of illicit origin from accessing and using the financial system. To comply with this duty, CreaMNN, in the ordinary conduct of its financial activity, has developed a model to fight money laundering and the financing of terrorist activities in accordance with current law and international best practices in this field.

Suppliers should share its commitment to preventing their actions from constituting money laundering and terrorist financing. To do so, the necessary measures will be put in place to avoid this risk.

In addition, CreaMNN has procedures and systems to comply with the economic sanctions and embargoes imposed by the international community and some legislations to limit activity with certain countries, entities and individuals. Suppliers should also share this commitment by implementing any measures they consider appropriate to prevent infringement of the aforementioned sanctions and embargoes by exposing CreaMNN to these types of risks. Suppliers to which those regulations apply must implement policies and procedures to comply with the aforementioned economic sanctions and embargoes, as well as to prevent funds of illicit origin from accessing and using the financial system.

4.7 Political contributions

At CreaMNN we conduct our business activity respecting the political pluralism of the societies in which we have a presence. CreaMNN does not make contributions to election campaigns or donations to political parties. CreaMNN suppliers must comply with applicable legislation in this field and must not make political contributions on behalf of CreaMNN.

4.8 Conflict of interest

There is a conflict of interest when a personal, family, friendship or other type of external circumstance may affect the professional objectivity of CreaMNN employees related to a procurement decision.
CreaMNN has internal regulations that require its staff to notify these types of situations to their senior executives prior to any action and to abstain from taking decisions on matters affected by the conflict of interest affects or from exerting influence over the persons responsible for taking them.

Similarly, CreaMNN suppliers, in order to ensure their full independence, must maintain internal procedures for checking and verifying potential conflicts of interest and immediately inform CreaMNN of any actual or potential conflict that may arise in any procurement process that they intend to carry out with CreaMNN, due to their personal or professional relationships with customers, suppliers, competitors or CreaMNN employees.

Suppliers must notify CreaMNN, at the beginning of each process to engage services or purchase goods, if (i) any shareholder, (ii) any member of its management body or (iii) any of its employees, related to the aforementioned hiring or purchase, has maintained an employment relationship with CreaMNN within the previous three years. The same will be done if they have the collaboration of that person through a commercial relationship, when they are involved in the procurement or purchase process proposed by CreaMNN.

4.9 Free competition

The professional activity of CreaMNN suppliers must be carried out respecting free competition and avoiding any conduct that restricts it illegally or that may be considered unfair competition, including:

Negotiating or reaching agreements with competitors on prices, product offer, production level, customer distribution, markets or quotas, boycotts on certain customers or suppliers; or any other action against free competition.

Actions that may entail an abuse of a dominant position.

Denigrating the reputation of competitors.
Negociar o llegar a acuerdos con los competidores sobre precios, oferta de productos, nivel de producción, reparto de clientes, mercados o cuotas, boicots a determinados clientes o proveedores; o cualquier otro supuesto contra la libre competencia.

Actuaciones que puedan suponer un abuso de posición dominante.

Denigrar la reputación de los competidores.

4.10 Confidentiality 

The information of CreaMNN, its customers, employees or any third party is confidential. With regard to access and storage of information, the legislation in force at any given time and in the closure governing the relationship between supplier and CreaMNN (general terms, contracts, etc.) must be followed.

05. Whistleblower channel

As a CreaMNN supplier, if you see an action or situation related to CreaMNN that may be contrary to the applicable legal provisions or the standards of this Code, please report it at the email address: 


The information will be analysed objectively, impartially and confidentially. Suppliers who report facts or actions through the Whistleblower Channel in good faith will not be subject to retaliation nor will they suffer any other adverse consequences from this communication. 

All complaints will be handled diligently and promptly as well as verified, and measures will be taken to resolve them. 

06. Compliance with and monitoring of the Code

This Code is mandatory for suppliers in relation to their procurement activities for goods and services for CreaMNN. CreaMNN expects its suppliers to internally monitor compliance with this Code and to notify CreaMNN of any breach, as well as to address any request for information on compliance. 

In addition, CreaMNN may require certain higher risk suppliers to establish, in the clauses that govern their legal relationship, additional controls which, depending on the circumstances, may include the following: 

  • The right to conduct audits in relation to compliance with the commitments included in this Code. 
  • The right to make visits to the supplier’s facilities in the country in question. 

07. Questions regarding the Code

Questions regarding the interpretation or application of this Code may be sent via: