3.4. BME group personnel guidelines on ethics
and transparency
BME’s Board of Directors regularly updates the compa-
ny’s Internal Regulations of Conduct (IRC) which were ap-
proved at its meeting on 15 July 2006, due to the compa-
ny’s stock market listing. The IRC applies to all members
of BME’s Board of Directors, managers and employees
and members of all Group companies.
The IRC contains the basic principles to guide all employ-
ees. In performing their duties, all individuals must al-
ways act in accordance with the principles of impartiality
and good faith.
The Standards of Conduct Committee, reporting to the
Markets and Systems Operating Procedures Committee,
is in charge of applying, interpreting and monitoring
these Regulations as well as approving the instructions or
guidelines for their implementation. It is assisted in this
task by the Secretary General and the Secretary of the
Board of Directors and the Standards of Conduct Unit.
As per the IRC, and in line with the guide for the transfer
of inside information to third parties, BME’s “Policy for
the treatment and transfer of inside information”, lists the
measures and internal control procedures that should
be established at BME and its group companies to safe-
guard inside information, so preventing possible leaks.
In addition to these regulations, at its meeting on 20
November 2006, the Audit Committee included in the
Regulations of the Board of Directors the procedure
for reporting deficiencies in internal control and risk
management systems, publicly specifying the channels
which can be used by BME employees to report any ir-
regularities in the internal control and risk management
systems to the Audit Committee.
These regulations and the implementation of the pro-
cedure for reporting deficiencies in internal control and
risk management systems are an effective mechanism
for detecting and treating potential cases of corruption
and fraud.
Also, following the entry into force of the newly-re-
formed Penal Code, the Audit Committee approved the
“Bolsas y Mercados Españoles, Sociedad Holding de Mer-
cados y Sistemas Financieros, S.A. and group companies
crime prevention guidelines” which are the basis of the
prevention system.
In order to implement these principles, at its meeting
on 29 November 2012, the Board of Directors approved
the documentation which will comprise the BME Group’s
Crime Prevention System which is currently being put
into operation. This Prevention System includes a Code
of Conduct which comprises the ethical principles and
conduct to which all BME Group directors, legal repre-
sentatives, managers and employees must adhere. The
Code states that in carrying out their activities all person-
nel must act in a professional, impartial, honest manner
and abstain from taking part in illegal or immoral ac-
tivities when bringing in business to the company and
group companies.
Another feature of the Crime Prevention System is the
internal confidential whistle-blowing channel via which
employees can report any breaches of the group’s code of
conduct or any cases of malpractice within the company.
Also, in order to fully implement the System, all BME
Group employees will receive training through the publi-
cation of an action guideline and through specific issues
regarding crime prevention.
In addition to the aforementioned mechanisms, the
company’s internal audit department is responsible for
performing regular audits on those procedures that are
potentially susceptible to consideration as instances of
corruption and fraud.
These rules, bodies and procedures enable the company
to effectively fight corruption and fraud, so as to allow
BME to comply strictly with applicable legislation on this
matter.
In 2012, no cases of corruption or fraud were reported
or identified.
58
BME employees
2
3
Corporate and Social
Responsibility
Report 2012
/ BME
1...,48,49,50,51,52,53,54,55,56,57 59,60,61,62,63,64,65,66,67,68,...107