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Corporate Integrity

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The Code of Ethics and Conduct includes the principles of corporate integrity and is the framework for the prevention of inappropriate conduct

CODE OF ETHICS AND CONDUCT

The Bankia Group has a Code of Ethics and Conduct, approved by the Board of Directors on 28 August 2013, which contains rules and criteria for professional action that are mandatory for all employees and executives of the bank, in all the activities and businesses of the Bankia Group.

Bankia's Code of Ethics and Conduct is based on several principles:

  • Ethical principles and values: commitment, integrity, professionalism, closeness and goal-oriented approach.
  • Corporate Ethics: the Code prevents institutional conflicts of interest through barriers aimed at preventing non-public information about its investment decisions and other activities, obtained as a result of relations with customers, suppliers or privileged institutional relations, to be abused or used for illegal purposed.
  • Market ethics and integrity: to enforce this ethical commitment, a series of policies, procedures and controls have been designed and implemented to ensure compliance with international standards on the subject. In particular, policies to prevent manipulation of markets and the use of insider information and encourage free competition and transparency in market information.
  • Personal ethics: the following are expressly forbidden: (a) accepting any type of gift, donation, deposit or commission derived from operations carried out by the Bankia Group; and (b) influencing issues in which either potential or actual conflicts of interest may arise.

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ETHICS AND CONDUCT COMMITTEE

Bankia's Ethics and Conduct Committee is responsible for ensuring compliance with the Code, as well as for promoting ethical conduct within the company.

This committee assumes the duties derived from the implementation of the Confidential Whistleblower Channel and is empowered to, if necessary, give instructions for the development of these regulations.

In addition to other duties, related to compliance with the Code of Ethics and Conduct and the Whistleblower Channel.

Duties of this committee

Ensure the proper functioning of the Whistleblower Channel and prepare periodic reports on its results for the Audit and Compliance Committee.

Guarantee the confidentiality of:

  1. the identity of the complainant.
  2. the investigation file and its contents, only informing the persons strictly necessary for the investigation and resolution process.

Ensure that no type of retaliation is carried out on employees who report suspected irregularities in good faith.

CONFIDENTIAL WHISTLEBLOWER CHANNEL

The confidential whistleblower channel is managed by a third-party company supervised by the Ethics and Conduct Committee.

The Audit and Compliance Committee approved the establishment of a confidential Whistleblowing channel to facilitate application of the code and the internal flow of information. Any breaches can be reported through this channel using the digital platform itself or by e-mail. The entire process is regulated: reception, filtering, classification and resolution of complaints received, in accordance with the criteria of the Spanish Data Protection Agency.

It is managed by a specialised third-party company (currently PwC), under the supervision of the Ethics and Conduct Committee. Its management ensures that all complaints received are independently analysed and that the information is communicated only to the people required for the investigation and resolution process.

Furthermore, the communication process is completely confidential and the anonymity of the communication is ensured, except for everyone directly involved in the response and/or the verification of the facts.

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