In recent years, organisations have gone a long way in the development of their Compliance programmes. The most recent reform of Spain’s Penal Code, which came into force in 2015, ratified the introduction of criminal liability for legal entities regarding offences committed for their own benefit. Criminal Compliance Programmes must include an analysis of the risks of a criminal nature that organisations may face, with a view to the company’s implementation of management and control models for preventing criminal acts.


  • Furnishing the organisation with a Model for Preventing and Responding to Corporate Offences
    – Policy
    – Procedures
    – Criminal risk and controls matrix
  • Provision of an inventory of criminal behaviour, criminal risks and mitigating controls
  • Provision of mechanisms for reporting and investigating unlawful behaviour

Our services

  • Advice on the Model for Preventing and Responding to Corporate Offences
  • Drafting the Procedur for Preventing and Responding to Criminal Offences
  • Criminal risks maps
  • Drawing up the Code of Ethics/Conduct
  • Whistleblowing Policy