Compliance

ARAGOGAMMA, S.L. presents its Crime Prevention Model (CPM), which meets the legal requirements in the field of corporate criminal responsibility. The objective of this is to prevent its legal structure from being used to commit offences and, at the same time, to implement good corporate governance and a culture of compliance.

ARAGOGAMMA, S.L. has implemented a Crime Prevention/Penal Compliance Model in accordance with Article 31bis of the Spanish Penal Code.

The reform of Spain’s Penal Code in 2010 introduced corporate criminal responsibility. Then, in 2015, the need for companies to have organisational and management models for prevention of offences (Crime Prevention Models) was established.

ARAGOGAMMA, S.L has, since 2017, been implementing and developing an internal structure to prevent offences being committed in the organisation.

Scope of the CPM

ARAGOGAMMA has proceeded to implement an internal organisation for crime prevention based on:

1. Criminal risk assessment

2. Risk map.

3. Implementation of cross-cutting controls for prevention, detection and mitigation of risks.

4. Implementation of specific controls for prevention, detection and mitigation of risks.

5. Creation of a Compliance Committee.

6. Opening of a Whistleblowing Channel.

7. Internal audits.

8. External expert advice.