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:


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”.


In accordance with the provisions of Law 2/2023, dated February 20, on the protection of persons who report violations of the law and the fight against corruption, elBullifoundation, a private foundation, has implemented an internal reporting channel.

The internal reporting channel is the preferential channel for any persons with an employment or professional relationship with the foundation to report on actions or omissions that may constitute a serious, or very serious, criminal or administrative violation.

The operation of this system is outlined in the “internal information system protocol”. If you wish to bring any matter to the attention of the entity, you can do so anonymously using the following form.

Access to the internal reporting channel


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: