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Annual Report 2014 Corporate governance system in BBVA Compliance system Internal control model Standards of conduct

Standards of conduct

A key component of the Compliance System is the BBVA Group Code of Conduct, as described in the section on the Compliance System.

Furthermore, commitments aimed at preventing corruption in the Group (relations with suppliers, anti-bribery policies, gifts, events management, prevention of money laundering, commitments regarding politically exposed persons - PEPs -, etc.) are all included in the Code of Conduct as well as in specific policies.

In 2015, BBVA Group has reviewed its anticorruption framework to adapt it to the new Code of Conduct and, at the same time, detect reinforcement opportunities, which will materialize in the coming months.

In 2015, BBVA Group continued to apply the specific reinforced precautionary measures for politically exposed persons already implemented in the past and set out in the Corporate Procedure for establishing business relationships with politically exposed persons.

Lastly, it is also worth mentioning here the Policy of Conduct in the Securities Markets, which develops the guidelines laid down in the BBVA Group Code of Conduct regarding securities markets, and includes a series of principles and general procedural guidelines that are widely accepted internationally and designed to uphold integrity in the markets. Specifically, it contains the minimum procedural guidelines that everyone in the Group is to observe regarding the treatment of privileged information, the prevention of price manipulation, the management of potential conflicts of interest and the own account trading by employees.

As well as these mechanisms, the Company has established other specific instruments for managing core commitments in each functional area. The more salient of these are:

  • Internal standards of conduct in securities markets.
  • The Compliance Statute.
  • The Code of Ethics for staff recruitment.
  • Principles applicable to parties involved in the BBVA procurement process.
  • Basic principles of risk management and the risk management Policy Manual.
  • Regulation on dealing with individuals or entities of public importance in matters of finances and guarantees.
The commitments that contribute to prevent corruption in the Group are set out in the Code of Conduct. Likewise, the Compliance unit has continued operations aimed at protecting customers/investors

Other basic commitments acquired by the Group are:

  • The Corporate Social Responsibility Policy, which establishes the principles and guidelines to comply with BBVA’s responsibility for its impact on society. This Policy is approved by the Board of Directors.
  • BBVA's Rules of Conduct in Defense: these rules have been in force since February 2012. It is applied in all countries in which the Group is present and is based on exclusion lists of companies and countries, updated quarterly by expert consultants in the area. Under these rules, BBVA does not finance, invest in or provide any financial service to companies related to the manufacture, development, maintenance or trade in controversial armaments, meaning anti-personnel mines, cluster bombs or biological and chemical weapons. Nor does BBVA participate in armament-related operations that originate in or are targeted at countries where there is a high risk of human rights violation.
  • Commitment to human rights
  • Environmental policy
  • Responsible Procurement policy

In relation to conduct toward customers, in 2015, the Compliance unit continued operations aimed at protecting customers/investors:

  • Assessing the risks for customers associated with the Group products, services and activities and promoting or implementing measures for their mitigation. The Compliance unit is represented on the various New Product Committees, thus ensuring that this side of product sales is taken into account at all times. In 2015, these committees have reviewed 190 new activities, products or operations. In addition, control procedures and routines have been strengthened.
  • Coordinating action plans to adapt to any new requirements and criteria regarding the protection of investors or banking users that are issued, chiefly by the Spanish National Securities and Investment Board (CNMV) and the Bank of Spain.
  • Working closely with product and business development units on a permanent basis, both for retail and wholesale markets, and focusing on digital banking initiatives, with the aim of instilling the concept of customer/investor protection into its projects from the outset.
  • Keeping the internal regulatory framework fully up-to-date at all times to ensure that all product and service sales made at the Bank are compliant with requirements.
  • Participating in improvement projects and updating sales processes, as well as the Bank's supporting IT systems, seeking to ensure their consistency with best practices in terms of protecting customer interests.
  • Promoting communication and training initiatives for the sales network and support departments.
  • Carrying out specific reviews of the information made available to the public and the sales forces, as well as the promotional campaigns and sales of investment products.
  • Strengthening the compliance risk monitoring metrics and indicators to promote a proactive approach.
  • Evaluating measures in force at the Bank in the light of customer complaints, internal and independent audit reviews and regulatory inspections and requirements.

Whistleblowing channels

Another key mechanism for managing conduct risk in the Group is its whistleblowing channels. As set out in the Code of Conduct, BBVA employees have the obligation not to tolerate any conduct that is contrary to the Code or any conduct in the performance of their professional duties that may harm the reputation or good name of BBVA. This whistleblowing channel is a means for enabling employees to report any breaches they observe or are notified by their collaborators, customers, suppliers or colleagues.

The following channels are available for employees to report activities or situations related to BBVA they observe or are notified, which may be against regulations or the values and guidelines of the Code of Conduct, even if they are not included as part of their responsibility:

  • Discuss the case with their supervisor or contact at Talent & Culture (BBVA's current human resources area).
  • Report the case through the whistleblowing channel of the geography or area where they work.
  • Make use of the whistleblowing channel, reporting the case to the Compliance unit at the email address canaldenuncia@bbva.com or the phone number: (34) 91 537 7222. 

Those who report facts or acts in good faith to the whistleblowing channel will not be subject to reprisals or any other adverse consequence for this reason.

The Compliance unit processes the reports received diligently and quickly, checking the circumstances and pushing through measures to resolve them, in accordance with the whistleblowing's management procedures. The information is analyzed in an objective, impartial and confidential manner. Since 2015, the whistleblowing channel is open to the Group's suppliers.

International initiatives endorsed

BBVA is signatory to the following international initiatives:

  • United Nations Global Compact.
  • The United Nations Environment Program Finance Initiative (UNEP FI).
  • Equator Principles.
  • United Nations Principles for Responsible Investment.
  • International Integrated Reporting Council.
  • Carbon Disclosure Project.
  • Thun Group on Banks and Human Rights.
  • Natural Capital Declaration.
  • Global Initiative for Sustainability Ratings.
  • Green Bond Principles.
Whistleblowing channels enable employees to report breaches of the Code of Conduct

Likewise, BBVA publicly manifests its respect for the UN Universal Declaration of Human Rights, the basic employment legislation of the International Labor Organization and the OECD Guidelines for Multinational Enterprises.

Legal compliance

As of December 31, 2015, BBVA Group has not recorded any fines or penalties for breaches of legislation related to environmental issues or the supply of products and services that might be significant in terms of the Group's equity, financial situation or consolidated results and that are not provisioned in the Group's consolidated financial statements.

The companies making up BBVA Group in Spain have not received any relevant convictions in the employment courts between January 1 and December 31, 2015, inclusive, in cases affecting gender equality or discrimination filed by employees, nor have they been served any penalties due to very serious breaches of employment regulations.