Ethics and Compliance
- Ethical Commitment and Regulatory Compliance Model
ALFARIVER DEFENSE S.L. maintains a strong ethical commitment, which is an essential element of its corporate compliance culture. This commitment is based on our Code of Ethics and Conduct, which guarantees and reflects our ongoing commitment to self-regulation, ethics, integrity, and transparency.
Likewise, our Criminal Compliance Policy, Competition Compliance Policy, and Anti-Corruption Policy are consolidated as fundamental pillars of our regulatory compliance model.
Furthermore, ALFARIVER DEFENSE S.L.’s Senior Management, committed to society and to the highest standards in complying with applicable regulations, has implemented its own Compliance Management System, adapted to the criminal liability regime for legal entities established in the Spanish Criminal Code and to current competition law, and certified in accordance with UNE 19601 (Criminal Compliance) and UNE 19603 (Competition Compliance) standards.
- Policies
In this section, you can consult the main corporate policies that establish the principles, rules, and commitments that guide the actions of the company and its members:
Criminal Compliance Policy Competition Compliance Policy Code of Ethics and Conduct Anti-Corruption Policy Information System Management Procedure - Complaint Channel Statistics
This section provides aggregated statistical information on the operation of the Whistleblowing Channel, in line with ALFARIVER DEFENSE S.L.’s commitment to transparency, ethics, and regulatory compliance.
The data is presented in an anonymized manner and in accordance with applicable regulations:
2025
Total number of reports received between January 1 and December 31, 2025 Classification by type of report (fraud, harassment, conflict of interest, etc.) Status of reports (investigated, archived, ongoing) 0 0 0
2026
Total number of reports received between January 1 and December 31, 2026 Classification by type of report (fraud, harassment, conflict of interest, etc.) Status of reports (investigated, archived, ongoing) 0 0 0
- Training
Competition Law Training
During 2025, the company developed a specific competition law training program aimed at employees particularly exposed to risks in this area, based on their responsibilities and level of interaction with suppliers, customers, and third parties.
The training activities included specialized sessions on antitrust regulations, prevention of anti-competitive practices, exchange of sensitive information, and management of relationships with suppliers, as well as reinforcement actions through periodic training content, designed to consolidate knowledge and strengthen a culture of compliance. The total duration of the training was two hours.
As a complementary measure to the training, the company introduced and updated internal procedures related to competition law, with the aim of reinforcing the practical application of the principles covered during the training sessions.
Participation in these training activities reached 100% of the employees invited, ensuring full coverage of the identified at-risk group.
- Complaint Channel Statistics
This section provides aggregated statistical information on the operation of the Whistleblowing Channel, in line with ALFARIVER DEFENSE S.L.’s commitment to transparency, ethics, and regulatory compliance.
The data is presented in an anonymized manner and in accordance with applicable regulations:
2025
| Total number of reports received between January 1 and December 31, 2025 | Classification by type of report (fraud, harassment, conflict of interest, etc.) | Status of reports (investigated, archived, ongoing) |
| 0 | 0 | 0 |
2026
| Total number of reports received between January 1 and December 31, 2026 | Classification by type of report (fraud, harassment, conflict of interest, etc.) | Status of reports (investigated, archived, ongoing) |
| 0 | 0 | 0 |
- Training
Competition Law Training
During 2025, the company developed a specific competition law training program aimed at employees particularly exposed to risks in this area, based on their responsibilities and level of interaction with suppliers, customers, and third parties.
The training activities included specialized sessions on antitrust regulations, prevention of anti-competitive practices, exchange of sensitive information, and management of relationships with suppliers, as well as reinforcement actions through periodic training content, designed to consolidate knowledge and strengthen a culture of compliance. The total duration of the training was two hours.
As a complementary measure to the training, the company introduced and updated internal procedures related to competition law, with the aim of reinforcing the practical application of the principles covered during the training sessions.
Participation in these training activities reached 100% of the employees invited, ensuring full coverage of the identified at-risk group.