The VAPF GROUP has implemented a regulatory compliance and crime prevention program (Corporate Compliance), hereinafter the "Program", whose Criminal Compliance and Risk Management Policy (approved on January 19, 2023) is specified below:



  •  Comply with all the obligations derived from this Policy and the Program.
  •  Comply with all criminal legislation that is applicable to VAPF GROUP.
  •  Continuously improve the Program and related business processes.



This Policy and the Program are applicable to all the companies of the VAPF GROUP, to its Governing Body, Senior Management, employees and any other related party.


For the purposes of establishing any type of commercial relationship, the acceptance of this Policy and the obligations derived from it will be proposed.



  • Strengthen the policy of zero tolerance regarding the commission of criminal offences.
  • Establish a model capable of identifying the most important criminal risks and establishing measures for their prevention, detection and management.
  •  Involve all the organization's staff in this system.
  • Ensure before society that the VAPF GROUP complies with the duties of supervision and control in the exercise of its activity, and that it establishes the appropriate measures to prevent the commission of crimes.
  •  Periodically review the present objectives.



  • Compliance with criminal legislation, the Code of Conduct and the rest of its internal protocols is required of all members of GRUPO VAPF, and expressly prohibits the commission of criminal acts.
  • The VAPF GROUP assumes the commitment to comply with all the obligations derived from this Policy, as well as the set of protocols, procedures and policies that are part of the Corporate Compliance Program.
  •  The obligation is imposed on the interested parties to report all those suspicious facts or behaviours related to criminal risks, guaranteeing confidentiality and the absence of reprisals to the informer, through the channel set up for this purpose (link).
  •  The existence of the Regulatory Compliance and Crime Prevention Committee ( is announced, as the body that will exercise the functions of responsible for Compliance. The Regulatory Compliance and Crime Prevention Committee is independent from the Governing Body and will act as the authority responsible for the management, implementation and verification of compliance with the Corporate Compliance program.
  • Failure by the members of GRUPO VAPF to comply with the obligations derived from this Policy and the Corporate Compliance program as a whole will give rise to the application of the disciplinary regime provided for in the Workers' Statute and the Collective Agreement resulting from application, and in the case of any business partner, those provided for in the specific procedure applicable to it.



  • An Assessment of criminal risks in the framework of the development of our activity, which is manifested in a Risk Management Policy (Rule 12) that presents 4 objectives:
  • Integrate risk management in all areas and levels of action.
  • Lead this risk management by the Governing Body and Senior Management.
  •  Clearly define the authorities, responsibilities, and obligations of the bodies responsible for implementing this risk management.
  • Involve all parties in the commitment assumed by the VAPF GROUP, allocating the necessary resources for risk management.
  • Code of Conduct that establishes a behaviour guide for the members of GRUPO VAPF.
  • A Complaint Channel (link), enabled for all members and business partners of the VAPF GROUP. Through which you can report any breach or suspicion of breach of the obligations defined herein. Confidentiality and the absence of reprisals are guaranteed for any whistle-blower who uses this channel.
  •  This Criminal Compliance Policy, as the parent document of the Corporate Compliance program.



When a conflict arises between different objectives, the Governing Body and Senior Management will analyse the conflict that has arisen and propose corrective actions to resolve it.




This document is an extract of the Criminal Compliance Policy and the Risk Management Policy.

If you wish to obtain the full version of the same, have questions about our Corporate Compliance program or want to consult any other regulation thereof, please contact us at



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