Implementing a Crime Prevention Plan at ITV Ice Makers should be seen as a clear opportunity. On the one hand, it allows us to thoroughly analyze the behavior and operation of the organization, process by process, activity by activity to identify weak aspects and highlight them. In addition, it allows us to evaluate whether what is being done and the way it is being done is correct or not, that is, whether we are doing things right. In short, this is what it is all about: having a clear conscience and knowing that we are carrying out the mission, vision and values of the organization correctly, without exposing the company to danger.


This CRIME PREVENTION PLAN has the primary purpose of carrying out the requirements of regulatory compliance in the criminal field, which complements the ETHICAL CHANNEL, THE CODE OF ETHICS OF ITV ICE MAKERS SL, as well as its DISCIPLINARY SYSTEM, COMPLAINT CHANNEL, CRIME PREVENTION PLAN and ORGANIZATIONAL MEDIATION PLAN IN THE COMPANY, in order to confer an adequate structure to the CORPORATE SOCIAL RESPONSIBILITY adopted by ITV ICE MAKERS SL.


Any illegal conduct is expressly prohibited in ITV ICE MAKERS SL and the Principle of Compliance with the Law is the first principle included in the Ethics and Conduct Policy of ITV ICE MAKERS SL.

In developing this principle, special emphasis must be placed on the prohibition, monitoring and control of conduct that may constitute criminal offenses.

There are two possible general scenarios in which ITV ICE MAKERS may be subject to criminal liability:

  1. Offenses committed on behalf of the company by de facto or de jure administrators or legal representatives.
    administrators or legal representatives, for having breached the duties of supervision, surveillance and control of their activity.
  2. Offenses committed by workers, employees and managers, professionals or their employees subject to the control/authority of the 

However, a criminal activity is always characterized by the fact that it is committed for the benefit, either directly or indirectly, of the legal person.

A legal person may be held criminally liable only for those offenses expressly provided for in the provisions of Book II of the Criminal Code.

Here is a list of offenses for which liability of legal entities is foreseen:

  • Crimes of illegal trafficking and transplantation of human organs (art. 156 bis).
  • Crimes of human trafficking (art. 177 bis).
  • Crimes related to prostitution and corruption of minors (arts. 187 to 189).
  • Crimes of discovery and disclosure of secrets (art. 197).
  • Crimes of fraud (arts. 248 to 251).
  • Crimes of punishable insolvency (arts. 257 to 261).
  • Crimes of computer damage (art. 264).
  • Crimes relating to intellectual and industrial property to the market and consumers (art. 270 to 288).
  • Crimes of money laundering (art. 302).
  • Crimes against the Tax Authorities and against Social Security (art. 305 to 310).
  • Crimes against workers’ rights (art. 311 to 318).
  • Crimes of illegal trafficking or clandestine immigration of persons (art. 318 bis).
  • Crimes against land use and urban planning (art. 319).
  • Crimes against natural resources and the environment (art. 325).
  • Crimes of establishing toxic deposits and dumps (art. 328).
  • Crimes related to ionizing radiations (art. 343).
  • Crimes of misdemeanors (art. 348).
  • Crimes of drug trafficking (arts. 368 and 369).
  • Crimes of counterfeiting credit and debit cards (art. 399 bis).
  • Crimes of bribery (arts. 419 to 427).
  • Crimes of influence peddling (arts. 428 to 430).
  • Crimes of corruption in international commercial transactions (art. 445).
  • Crimes of fundraising for terrorism (art. 576 bis).

And it is from this catalog of offenses that we will select those that apply to ITV Ice Makers.


In order to make a catalog of crimes that could be committed within the company, we have made an analysis of different aspects and factual assumptions that could lead to the perpetration of different crimes, with the result that appears in the file for the drafting of the Crime Prevention Plan in ITV Ice Makers.

From this study, it has been concluded that the crimes listed in it may be susceptible to being committed in the company, and it is on these that we will act and have preventive policies.

In addition, the company approves and documents in writing the procedure that regulates the complaints channel, detailing the operation of the system in all aspects that may occur.