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:
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:
In relation to conduct toward customers, in 2015, the Compliance unit continued operations aimed at protecting customers/investors:
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:
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.
BBVA is signatory to the following international initiatives:
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.
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.