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Implementing and promoting a culture of compliance and business ethics.

Compliance is the set of company policies aimed at meeting the highest standards of excellence in terms of regulatory compliance, corporate social responsibility and good governance codes.

In this context, and due to the latest reforms to the Penal Code, criminal compliance management systems have taken on special importance. The main aim of such systems is to establish preventive and reactive controls that allow the company, as well as, where appropriate, the top management and administrative bodies thereof, to be protected from possible criminal liability.

At the Compliance Area of Bartolomé & Briones, we help develop tools for managing and controlling criminal and ethical conflicts within organisations by implementing effective and adequate compliance programmes. These take into account the size of each company, given that compliance management systems must be modelled according to the features and peculiarities of each company. Standardised models that do not fulfil the purpose of removing or mitigating criminal liability, let alone contribute to the development of a proper ethical and compliant culture, are not used.

In this regard, we advise on:

  • Development and implementation of integrated compliance management systems.
  • Development and implementation of criminal risk prevention systems, in accordance with national and international standards.
  • Review of compliance models already implemented to assess their suitability and adequacy.
  • Adjustment and adaptation of international systems to local requirements.
  • Development of specific policies (Codes of Conduct, ICT Policies, Anticorruption, Money Laundering, LOPD [Spanish Data Protection Law], Whistleblowing Channels, Work Harassment Investigation Protocols).
  • Advice and external support to compliance bodies to adapt compliance models to the circumstances of the company.


Implementation of a criminal compliance management model for a group of companies in the ICT sector.

Adaptation of international group policies for a Swiss energy company.

Review of the adaptation of policies for an international software developer.