recommendations of supervisory and regulatory
bodies, stresses the necessary independence and
global nature of the function, for providing
suitable information for decision-making at all
levels.
Another one of the basic principles is the
hands-on management of the risk’s entire lifecycle,
which implies monitoring the full cycle of
operations, from prior analysis, through approval,
until the risk is discharged (continuous risk
management).
Given the current crisis scenario,
communication becomes especially important.
Accordingly, BBVA’s Risk Department has
introduced several schemes, with such highlights
as the creation of the new ‘Risk Portal’ with
area content of the utmost interest; the blog
Pasión por el Riesgo (Passion for Risk) as a
discussion tool, as well as the magazine
Visión@Riesgo, whose purpose is to both inform
and instruct.
STANDARDS
OF CONDUCT,
COMMITMENTS
AND INTER-
NATIONAL
AGREEMENTS
CODE OF CONDUCT.
A key component of the
Compliance system is the BBVA
Group’s Code of Conduct,
which defines and develops the
fundaments of ethical conduct
and the necessary operating guidelines for preserving
one of the main sources of value creation: corporate
integrity.
The Code of Conduct is applicable to all
Group entities and employees. It publicly reflects
the sum of pledges BBVA has made to its direct
stakeholders –shareholders, customers, employees
and suppliers– and to the societies in which the
company operates.
SPECIFIC CODES IN OPERATING
AREAS. Además del Código In addition to
the Code of Conduct for Group employees, the
company has furnished itself with other specific
instruments for the management of core
commitments in each operating area. The more
salient of these are:
• Internal Standards of Conduct on the Securities
Markets.
• Compliance Charter.
• Director’s Charter.
• Code of ethics for the recruitment of personnel.
• Principles applicable to those parties involved
in the BBVA procurement process.
• Basic Principles and Policies of Risk.
Management Manual.
• Audit Charter.
• Regulation on dealing with individuals or
entities of public importance in matters of
finances and guarantees.
BUSINESS CONDUCT. In 2008, as a reflection
of BBVA’s commitment to further reinforce the
principles of business ethics, the internal
framework for guidelines of conduct on securities
markets has been updated through the following:
• Approval, by the board of directors of the
BBVA Group, of a global policy on conduct
on securities markets. This policy develops the
guidelines laid down in the BBVA Group’s
Code of Conduct regarding securities
markets, and includes a series of principles
and general procedural guidelines that are
widely accepted internationally and designed
to uphold the integrity of markets.
Specifically, it contains the minimum
procedural guidelines that everyone in the
Group is to observe regarding the treatment
of privileged information, the prevention
of securities price manipulation, the
management of potential conflicts of interest
that may arise and those market operations
undertaken on their own accord by
employees. In addition, mention should also
be made here of the communication campaign
launched throughout the BBVA Group to
ensure the entire workforce is familiar with
its content.
• A fresh review of the Code of Conduct on
securities markets, renaming it as Internal
Standards of Conduct on Securities Markets
and extending its sphere of application not
only to entities involved in this activity in
Spain but also to the Group’s branches and
subsidiaries throughout the rest of the
European Union. This new version of the
document has been revised to include new
legislation forthcoming through the
transposition of the MiFID. Likewise, launch
has been made of a series of online courses for
disseminating its content, in a straightforward
and eminently practical manner.
CR PRINCIPLES AND POLICY
Corporate Responsibility Report 2008
13
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