For us, integrity means honesty and acting in accordance with non-negotiable ethical standards. It is at the core of our Responsible Business Principles and is part of the company’s culture.
The Compliance area, which reports to the Board of Directors through the Audit and Control Committee, focuses most of its policies, procedures and controls to ensure our integrity, addressing, among others, issues related to corruption and bribery.
Telefónica's commitment to our stakeholders is zero tolerance for fraud and corruption as we understand that they have a negative impact on business and society.
The Compliance unit with Telefónica Group has both preventive and reactive functions. As part of the prevention function, the Compliance Program includes, amongst others controls, risk assessments procedures, anticorruption internal policies, compliance third party due diligence processes and awareness and training initiatives. Finally, in respect of the reactive function, Telefonica has, as part of its compliance program, a whistler-blower channel, a conflict of interest reporting tool and a discipline program, among others.
For us integrity means honesty and acting in accordance with non-negotiable ethical standards
Thus, our Anticorruption Policy prohibits any type of bribery and regulates the acceptance and offering of gifts and invitations. To strengthen and expand it, we have the Rule on the Relationships with Public Entities, related to how the relationships of Telefónica Group with public entities and officials/employees should be managed from the diverse perspectives, and in particular, related to the internal rules to be complied with in connection to hospitality events with public officials.
In the same way, we have a conflict of interest rule and reporting channel to help our employees when faced with an ethical dilemma.
- 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.
In addition, we promote and encourage these behaviour patterns among our partners and suppliers, through our Policy on Responsibility in the Supply Chain.
At Telefónica we train, both in on-site and online mode, our employees regarding anti-corruption, addressing, for example, the risks of international public corruption (Foreign Corrupt Practices Act). We also have training on criminal liability.
In parallel, we are reinforcing our internal regulatory framework with new policies and regulations, as well as our third party assessment protocols.
Third Party Due Diligence
In that sense, Telefónica Group has defined a third party due diligence model from a Compliance point of view; such control is on a continuous improvement and implementation process. As part of such model, certain transactions (among others, M&A and joint venture transactions, donations, agency agreements, etc.) require individualized assessments
Communications and queries
Last year we received 912 complaints through the Complaints Channel available to employees, 404 of which were founded.
A total of 24 complaints, mainly regarding privacy and the environment, arrived through our Responsible Business Channel, available to all our stakeholders.
Telefónica has a criminal compliance management system in Spain, in accordance with Standard UNE-19601, certified by AENOR
We have specific commissions and units to ensure that our commitment to control and transparency is met.
Committees dependent on the Board of Directors:
- Audit and Control Committee.
- Regulation and Institutional Affairs Committee.
- Global Chief Compliance Officer and Compliance Officer in all countries in which the Group has significant interests.
- 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.
- Global management and local sustainability units.
- 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.