Telefónica’s commitment to its stakeholders is zero tolerance of fraud and corruption, because we understand that they have a negative impact on business and on society in the long term.

The principle of integrity is, in fact, key in our internal code of ethics, which says this:

  • We prohibit all kinds of bribery.
  • It is not allowed to promise, offer or give any benefit or advantage to anyone, in order to influence decisions of any kind (including governmental, administrative or judicial) or obtain an improper advantage for the Company. We also prohibit any sort of benefit or advantage that may result in a breach of the obligations and duties of our employees.
  • We do not offer or accept gifts, invitations or any other inducements that may reward or influence a business decision.
  • We avoid or declare conflicts of interest that may precede personal priorities to collective ones.
  • We behave with righteousness without looking in any case for any benefit for ourselves or third parties, by misusing our position or our contacts within Telefónica.

Furthermore, we have elements which comprise an environment of control in all our operations:

Internal rules of global application

Their purpose is to prevent corruption in the processes identified as being of higher risk in decisions, purchases, contracts, payments, management of warehouses, etc. Some examples:

Gifts, invitations and representation expenses
  • When traveling, we employ the services contracted by concerted agencies and only justified expenses are reimbursed.
  • We prohibit gifts and invitations that attempt to influence or reward or business decisions that violate third party rules.
  • We do not accept / provide money, gifts of a high value or special trade advantages.
  • Are approved, depending on their amount, by the Committee or by the Board of Sponsors.
  • The signature of the CEO or the one belonging to the leading manager with the highest degree of responsibility in order to approve donations (donations in kind will be valued at market price).
  • The boards are overseen by the Legal Services.
  • Negotiation and adjudication with suppliers is always the responsibility of the Purchasing Department, and is performed under the Purchasing Model, comprehensive and transparent.
  • The Purchasing Department is responsible for resolving specific situations, such as exclusion of suppliers where any irregularities or conflicts of interest or image have occurred.

Risk management

streetTelefónica performs a continuous monitoring of the most significant risks that could affect the main companies comprising its Group. To achieve this, we have a Corporate Risk Management Model based on COSO (Committee of Sponsoring Organizations of the Treadway Commission) Risk Management Model, which allows to evaluate both the impact as well as the probability of occurrence.


The most significant risks and uncertainties we face and that could affect the business, the financial condition, reputation, corporate image and brand, and the results, are included in the Annual Financial Report.


Organisational elements

We have specific committees and units to guarantee fulfilment of our commitment to zero tolerance of corruption and bribery:

Committees dependent on the Board of Directors:
  • Audit and Control Committee
  • Institutional Affairs Committee
Specific units:
  •  Internal auditing in all countries in which the Group has significant interests
  • Centralised Inspection Unit specialising in fraud prevention assignments and investigation of complaints and other allegations
  • Payment Intervention Unit at major companies
  • Sustainability Overall Management 
  • Corporate Risk Management Unit in charge of centralising and reporting risk information received from the local areas of risk management, implemented in the Group’s major operators.

Responsible Business Channel

Ask us any aspect related to sustainability of Telefónica in our Responsible Business Channel.

Best international practice

Telefónica’s Business Principles Office, the body responsible for ensuring compliance with our ethical code has been included as a success story in the “Anti-Corruption Ethics and Compliance Handbook for Business”, sponsored by the OECD, UNODC and the World Bank. According to the World Bank, corruption and bribery generate annual losses of between 20 and 40 billion dollars in developing countries.