Professional ethics

Over the years Bankinter, S.A. has demonstrated its commitment to a zero-tolerance policy regarding crime, having adopted all measures necessary to transmit this commitment and its obligation to prevent, detect and persecute crime in all its forms and in all its ramifications to all levels of the Bank's structure.

For the purpose of bringing the criminal risk prevention model into line with the changes implemented by the reform of the Criminal Code approved by Organic Law 1/2015, of 30 March, which entered into force on 1 July 2015, on 21 October 2015 the Board of Directors of Bankinter, S.A. approved the creation of the Criminal Prevention and Professional Ethics Committee, which is responsible for overseeing the functioning of and compliance with the prevention model implemented by Bankinter, S.A. The Committee is provided with autonomous powers of incentive and control, and is also entrusted with the functions that were previously given to the Code of Professional Ethics Monitoring Committee, as it is now necessary to unify the disciplinary powers regarding irregular conduct in a single body whose main function is to prevent this conduct and to apply the corresponding penalties to all executives, employees and Group subsidiaries, as well as those, not having a relationship of dependence, that act for and on behalf of the company as agents.

This Committee reports directly to the Board of Directors on an annual basis through the Audit and Regulatory Compliance Committee.

In 2016 the Criminal Prevention and Professional Ethics Committee focused on the following activities:

• Preparation of an external expert report on the specific measures to be adopted in each area of activity to avoid irregular conduct.
• Definition of the whistleblowing channel.
• Implementation and coordination of the Criminal Prevention and Professional Ethics Subcommittee in Portugal.
• Face-to-face training on criminal liability of legal entities for the Board, the Management Committee, executives and managers.
• Review of the controls in place to prevent irregular conduct that may have criminal significance.