Preventing corruption

We assume our commitment to fight against corruption in all its forms and carry out all our activities in accordance with the applicable legislation in all areas of activity and in all the countries where we operate. Our commitment to preventing corruption is reflected in the establishment of principles that govern the conduct of all our employees.

Integrity Policy

At Repsol, we are firmly committed to strictly complying with regulations that prevent and combat corruption, according to the principles outlined in the Code of Ethics and Business Conduct. We also expand compliance not only to all of the employees belonging to the companies the Repsol Group manages directly or indirectly, but also to our business partners.

With the aim of preventing corruption, Repsol is committed to performing all of its operations in accordance with the applicable laws in all areas of activity and in all the countries in which we operate by respecting their spirit and purporse. Accordingly, Repsol will:

• Not exert any influence on the will or objectiveness of persons outside the company in order to obtain a benefit or rewards through practices that are unethical or contrary to applicable laws.
• Not give, promise, or offer, directly or indirectly, anything of value to any person or entity in order to obtain undue benefits for the Company.
  
• Not allow any facilitating payment.
  
• Not finance or support directly or indirectly any political party or its representatives or candidates.
  
• Not use donations to conceal undue payments.
  
• Not request or unduly receive, directly or indirectly, commissions, payments, or rewards from third parties as a result of investments, divestments, financing, or expenditure made by the Company.
  
• Pay special attention to those cases where there appears to be lack of integrity with any person or entity with whom we deal, to ensure that Repsol establishes business relationships only with qualified and reputable persons or entities.
  
• Faithfully and accurately record all actions, operations, and transactions in the Company's books and records.

Promote internal training on preventing and combating corruption.

Crime Prevention Model

We have the appropriate mechanisms to prevent, detect, and investigate cases of corruption: our Crime Prevention Model aims to prevent and, if necessary, uncover the criminal activity of any company employee. 

This model is expressed in formalized compliance and monitoring procedures which have controls aimed at mitigating the risks of non-compliance with both internal and external regulations, including compliance with our Code of Ethics and Business Conduct. We evaluate the effectiveness of these models annually and also have due diligence processes prior to the acquisition or exchange of assets, mergers, partnerships, or joint ventures that evaluate and manage these risks.

Repsol has drafted and distributed throughout the entire organization a Crime Prevention Manual, which is meant to serve as a guide to understanding the main criminal risks the company faces and what is expected of its employees in order to prevent them.

System of Internal Control over Financial Reporting

Our System of Internal Control over Financial Reporting specifically considers fraud risk as a relevant element in the design, implementation, and evaluation of our Crime Prevention Model. To this end, we follow a methodology based on the framework of the COSO 2013 (Committee of Sponsoring Organizations of the Treadway Commission) and on the AICPA (American Institute of Certified Public Accountants) in its Statement on Auditing Standards No. 99.

Value chain

We work to extend corruption prevention throughout our value chain, including developing audit processes for non-operated assets. In activities where we are present as a company but do not carry out operations, we consider it essential that our partners maintain ethical, social, and environmental standards comparable to our own. In addition, we conduct audits to analyze the specific needs and particularities of each operation and include relevant clauses in the contracts we sign with our counterparties. 

We also conduct similar audits in the supplier and contractor rating processes and have our own Code of Conduct for suppliers and contractors which describes the conduct we expect from them in relation to corruption.