Política de Compliance de BBG

Bahía de Bizkaia Gas, hereinafter BBG, guarantees business continuity and of the company itself, through strict compliance with the Law and internal regulations. This allows for the organization to detect and manage the risk of non-compliance with legal obligations, including internal and external regulatory ones, as well as those specific to the legislation applicable to the organization (criminal compliance)

The active involvement and supervision of both its Board of Directors (Governing Body) and its General Management (Senior Management), implies the approval by the former of this Compliance Policy, which is fully aligned with the company’s Code of Ethics and the deployment to the organization through its Management Systems, promoted and guaranteed by the General Management.

The organization relies for the prevention of criminal risks on the aforementioned System, which includes the management of criminal compliance applicable to all activities and services provided by BBG. Likewise, it is based on the establishment and improvement of preventive and detective controls to mitigate any identified risks.

This policy sets out our general commitment to criminal compliance, which is to be developed and deployed at all levels of the organization, through its Management System. Our commitment can be set out as follows:

– Implement and continually improve a criminal compliance management system in order to reduce and mitigate the risk of a crime being committed.

-Design and establish adequate and effective preventive and detective controls to mitigate criminal risk.

-Inform and raise awareness levels for all our personnel, including management staff and collaborating personnel of the following issues:

– the relevance of compliance with the requirements of criminal compliance, and

– the fact that an infraction of its legal provisions implies the application of disciplinary measures.

– Leave formal and public record of BBG’s rejection of any type of illegal conduct.

BBG has at its disposal the necessary resources, both human and technical, to deploy its criminal compliance policy. Thus, the Governing Body approved on March 31, 2016 the Organizational Model (compliance) and the formal appointment of the criminal risk compliance committee (Compliance Body) and subsequently the new composition of the Compliance Body so as to guarantee its independence, as well as the appointment of the Head of Compliance.

All members of our staff have access through the intranet to all the documents that explain both the BBG Code of Ethics and the criminal compliance policy, as well as procedures and development rules. They also receive regular information and training on criminal risks, its management and how to act upon possible breaches.

Approved by the Board of Directors on September 29th, 2017