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Annual Report Bankia 2016 /

Corporate integrity

BANKIA’S CORPORATE INTEGRITY PRINCIPLES ARE SET OUT IN THE CODE OF ETHICS AND CONDUCT, WHICH IS THE CENTRE PIECE OF THE FRAMEWORK FOR THE PREVENTION AND DETECTION OF MISCONDUCT. THE CONFIDENTIAL WHISTLEBLOWING CHANNEL IS ANOTHER KEY TOOL.


Code of Ethics and Conduct

The Bankia Group has a Code of Ethics and Conduct, which sets out rules and criteria for professional conduct that apply to and are binding on all the bank’s professionals and directors and across all the group’s activities and businesses. Enforcement of ethical standards of behaviour and corporate integrity is essential in order to preserve trust in, and respect for, the bank.ad.

The goals of the code are as follows:

  • Specify the conduct that is permitted and the conduct that is prohibited by the bank.
  • Establish the ethical principles and general rules that must govern the behaviour of the group and its professionals towards one another and towards customers, shareholders, suppliers and all the individuals and institutions with which the group, directly or indirectly, has relations.

The code revolves around various themes:

  • Ethical principles and values
    Commitment, integrity, professionalism, proximity and achievement orientation.
  • Corporate ethics
    The code establishes the values that should guide the group’s relations with its professionals, customers, suppliers and society at large. In particular, it is intended to prevent institutional conflicts of interest by erecting barriers that will stop non-public information on its investment decisions and other activities from being used abusively or unlawfully.
  • Ethics and integrity in the markets
    Various procedures and controls have been designed and implemented to ensure compliance with international standards in this area. In particular, policies have been put in place to prevent market manipulation and misuse of inside information and to foster free market competition and transparency. Policies have also been developed to prevent corruption crimes. Bankia has various control mechanisms for this purpose and has training plans for managers and other professionals. There are also various specific recommendations to prevent corruption in supplier selection, incentives and credit risk.
  • Personal ethics
    Accepting gifts, presents, money or commissions of any kind for operations carried out by Bankia and influencing matters in which there are actual or potential conflicts of interest is expressly prohibited

The group’s professionals have an obligation to know, comply with and help to enforce the Code of Ethics and Conduct. This includes the obligation to report any evidence or proof of infringement through the channels made available for that purpose.

  • 100%
    Employees must know and folow the Code of Ethics and Conduct.
  • 29
    Reports recieved via the Whistleblowing Channel since it was created.
  • 11
    Meetings of
    the Ethics and Conduct Committee.

Confidential Whistleblowing Channel

To facilitate enforcement of the code and internal reporting, the Audit and Compliance Committee approved the establishment of a confidential whistleblowing channel, which allows employees to notify any misconduct through a special online platform or by email.

The channel has its own regulations, approved by the Audit and Compliance Committee, which establish mechanisms for the receipt, filtering, classification and resolution of reports in accordance with Spanish Data Protection Agency standards.

The channel is managed by a specialised external company (currently PwC), under the oversight of the Ethics and Conduct Committee, which is responsible for ensuring that all reports received are assessed independently and that the information is shared only with persons whose collaboration is strictly necessary to research and resolve the matter. The reporting procedure is completely confidential and the anonymity of the whistleblower is guaranteed, except for the persons directly involved in responding to the report and checking the facts.

Both the Code of Ethics and Conduct and the Confidential Whistleblowing Channel are available on Bankia’s corporate website and the employee intranet.


In the last year, six reports or inquiries were received via the Confidential Whistleblowing Channel. After internal analysis, it was found that in none of the cases was there any violation of the Code of Ethics and Conduct.

Types of reports of misconduct received 2016 2015
Market abuse    
Workplace bulliyng 2 1
Irregular conduct with suppliers 2
Misappropriation or syphoning off of resources  
Accounting and auditing aspects 1 2
Condidentialy or use of insider information  
Conflicts of interest  
Question / Suggestion 1 1
Falsification of contracts, report or records    
Infrigements regarding securities or equities trading    
Environmental protection    
Information security 1 1
Physical security    
Bribery or corruption    
Infrigement of employee rights 1
Other 1
Total reports of misconduct submitted 6 11 

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