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BankiaCorporate Integrity

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Code of Ethics and Conduct

The Bankia Group has a Code of Ethics and Conduct. approved by the Board of Directors on 28 August 2018. The Code sets out the rules and criteria on professional conduct that must be adhered to and applied by all the bank's staff and officers and across all the group’s activities and businesses. Its objectives are:

  1. Regulate the conducts that are permitted and prohibited by the bank.
  2. Establish the ethical principles and general rules to guide actions of the group and employees among themselves and in their relationships with customers, shareholders, suppliers and, in general, all persons and entities with which the group has direct or indirect relationships.

The Bankia Code of Ethics and Conduct consists of the following key components:

  • Ethical principles and values. Commitment, integrity, professionalism, closeness and focus on achievement.
  • Corporate ethics. The Code prevents institutional conflicts of interest by using Chinese walls to avoid misuse or unlawful use of the non-public information on investment decisions and other activities obtained through relations with customers, suppliers or privileged institutional relations.
  • Ethics and integrity in market dealings. A series of policies, procedures and controls has been defined and implemented to ensure compliance with international standards in this regard. In particular, policies have been established to prevent market manipulation and the misuse of insider information, and to encourage free competition and transparency.
  • Ethical staff. There is an express prohibition on: (a) accepting any kind of gift, gratuity, income or fee in relation to transactions carried out by the Bankia Group, and (b) influencing matters that could give rise to actual or potential conflicts of interest.

More information

Confidential Whistleblowing Channel

The Audit and Compliance Committee approved the establishment of a Confidential Whistleblowing Channel to facilitate enforcement of the code and the internal flow of information. The channel can be used to report any breach by using the digital platform itself or via email. The entire process is rule-based, from the reception of the report to its screening, classification and resolution, in accordance with the criteria of the Spanish Data Protection Agency (Agencia Española de Protección de Datos).

Its management is conducted by a specialised outside firm (currently PwC), under the oversight of the Ethics and Conduct Committee. This arrangement provides assurances of independent analysis of all reports received and that the information is only disclosed on a need-to-know basis during the investigation and resolution. What is more, the reporting process is completely confidential and full anonymity is guaranteed, except for the persons involved directly in replying to the report and/or who investigate the case.

Ethics and Conduct Committee

This committee takes on the functions associated with implementation of the Confidential Whistleblowing Channel and has authority, where necessary, to give instructions to develop the applicable regulations.

In addition to its other duties relating to compliance with the Code of Ethics and Conduct and the Whistleblowing Channel, this committee has the following functions:

  • Oversee the proper operation of the Whistleblowing Channel and prepare periodic reports on its functioning for the Audit and Compliance Committee.
  • Ensure the confidentiality of:
    • the identity of the whistleblower.
    • the investigation and its content, informing only those persons who are strictly necessary in the investigation and resolution.
  • Ensure that there are no reprisals of any kind against employees who report presumed misconduct in good faith.

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