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.


A multi-member COMPLIANCE COMMITTEE has been set up, composed of several Compliance Officers. 

The COMPLIANCE COMMITTEE is the body responsible for ensuring coordination and monitoring of the operation and compliance of the Crime Prevention Model implemented. 

Its roles and responsibilities are detailed in the organisation’s “Compliance Committee and Ethics Channel Protocol”. 


ARAGOGAMMA, has created an Ethics/Whistleblowing Channel as a high-level control measure, so that any direct member (administrator, employee, professional or executive) or related party (collaborator or supplier) can report any indication or suspicion of behaviour that could involve: 

• Failure to comply with the applicable regulations, protocols, procedures and internal controls.  

• Committing of acts that do not conform to ethical principles and good business practices.

• Committing of acts that could be criminal offences.

The operation of the whistleblowing channel and the processing of claims received through it are detailed in the organisation’s “Compliance Committee and Ethics Channel Protocol”. 

Aragogamma S. L.

Crta. de Granollers-Cardedeu,
(C-251 km 3,5) 08520
Les Franqueses del Vallés
+34 93 849 66 39

Offices: Salvador Mundí, 11 08017 Barcelona
+34 93 204 97 03