Ethics and business conduct

Our reference framework and responsibilities

Discover our Code of Ethics and Business Conduct

Code of Ethics and Business Conduct

The company's Code of Ethics and Business Conduct provides minimum standards of conduct that guide our professional behavior while performing our professional activities and places special emphasis on:

  • Responsibilities with respect to information and asset protection
  • Responsibilities in the market
  • Mutual responsibilities
  • Responsibilities towards customers and business partners
  • Responsibilities as citizens

A Committee in charge of ensuring compliance with the Code of Ethics and Business Conduct

Our Ethics and Compliance Committee is made up of a multidisciplinary management team with the following responsibilities:

  • Awareness-raising: promotes knowledge and provides advice on its interpretation and application.
  • Advisory services and establishment of control mechanisms: proposes actions and control mechanisms to promote, supervise, and, where appropriate, assist in their compliance.
  • Resolving non-compliance: binding resolution on the existence of non-compliance with the Code of Ethics and Business Conduct.
  • Investigations: gathers information from Repsol, as well as opening investigations into any matters that come to its attention.
  • Freedom from reprisals: ensures that no retaliation takes place.
  • Confidentiality: adopts the necessary measures to maintain confidentiality.
  • Reporting: reports to the company's governing bodies on its activities, keeping a statistical record.

Fundamental principles of our Ethics and Compliance Channel

The Ethics and Compliance Channel admits the possibility of making anonymous communications verbally or in writing. However, we encourage whistleblowers to identify themselves, as this facilitates the processing of communications and the application of the corresponding guarantees and protections.

 

As the only internal channel for communications under this Internal Information System, we have an Ethics and Compliance Channel managed by an independent entity. This offers whistleblowers the possibility of making communications in various ways (phone, email, or electronic form) in relation to possible breaches of the Code of Ethics and Business Conduct, the Crime Prevention Model, or the possible commission of a crime or infringement of applicable regulations.

 

The Ethics and Compliance Committee is the collegiate body responsible for Repsol's Internal Information System, which has delegated its management powers to the Chief Compliance Officer.

 

Bona fide whistleblowers and persons who cooperate in an investigation will not be penalized or suffer any negative consequences or retaliation for this reason. This guarantee may be extended to persons associated with the whistleblower.

 

Persons participating directly or indirectly in the processing of communications and in the corresponding investigations must maintain strict confidentiality of the information received. In no case shall any information that would allow identification be communicated to anyone outside the receipt and processing of the communication.

 

The person under investigation has the right to be informed of the actions or omissions attributed to them and to be heard by the investigator. In addition, the person shall have the right to the presumption of innocence, the right to honor, and other rights provided for in the applicable regulations.

 

Personal data will be processed in accordance with the applicable data protection legislation and, specifically, in accordance with the provisions of the Whistleblower Protection Law.

 

Persons directly or indirectly involved in the processing of communications and investigations shall maintain strict confidentiality of the information received.

 

Ethics and Compliance Channel communications

311

communications in total

75

investigations

11

non-compliances

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Updated as of August 2026