Crime prevention model

ELBULLIFOUNDATION, FUNDACIÓ PRIVADA has implemented a Crime Prevention / Criminal Compliance Model, as per the provisions of Article 31 bis of the Spanish Criminal code.

In 2010, with the reformed Criminal Code, Spain introduced corporate criminal liability. After that, in 2015, the requirement was established for companies to have an organisation and management model to prevent criminal acts (Crime Prevention Model).

Since 2017, we have implemented and developed an internal structure to prevent the commission of crime in the company.

As such, we hereby notify you of the following:

 INTERNAL OVERSIGHT BODY / COMPLIANCE OFFICER:

The company has established a multi-member INTERNAL OVERSIGHT BODY (IOB) comprising two Compliance Officers.

The IOB is the body charged with ensuring coordination and oversight of functioning of and compliance with the Crime Prevention Model implemented.

Its functions and responsibilities are detailed in the entity’s “Internal Control Protocol”.

WHISTLEBLOWER CHANNEL

elBullifoundation, Fundació Privada has set up a channel for whistleblowers as a high-level oversight measure, so that any direct member or associate can report any indication or suspicion of behaviour that may constitute:

• A failure to comply with applicable regulations, protocols, procedures or internal controls.
• The commission of acts that are not in line with ethics and good practices of business.
• The commission of acts that could be criminal.

OVERSIGHT

elBullifoundation has developed and implemented transversal and specific oversight measures to prevent the commission of crimes.

If you have any doubts or wish to bring any matter to the attention of the entity, please contact: departamentolegal@elbullifoundation.com