Internal information system

Secure channel to prevent, detect and report irregularities. In line with the Code of Ethics and BBK’s principles of legality and transparency and with full guarantee of confidentiality and protection for informants.

What is it

We want to strengthen the culture of information and integrity infrastructure, promoting respect for legality and the values and principles of action laid down in its Code of Ethics by members of governing bodies, the management team, employees and collaborators/suppliers in general.

To this end, we have implemented an Internal Information System to prevent and detect threats to public interest and facilitate the reporting of possible irregular behaviour or potential illegal acts or contrary to the law or the Code of Ethics.

Essential principles of the system

  • Confidentiality of the identity of the informant, of the information communicated even through unusual channels and of the actions that take place in its management and processing, as well as the secrecy of communications.
  • The possibility to make communications anonymously.
  • Compliance with the requirements set out in the personal data protection regulations.
  • Establishment of guarantees for the protection of informants, prohibiting reprisals and full access to support measures.
  • Guarantee the right of the people affected to be informed and to be heard at any time.
  • Respect for the presumption of innocence and the honour of the people affected.

What communications it allows

The System is applicable for any communication of any knowledge or motivated suspicion of irregular behaviour or that may imply a serious or very serious violation of the BBK Code of Ethics and other internal regulations.

In addition, the System shall allow reporting on any action or omission which may constitute a serious or very serious criminal or administrative infringement, or which may constitute a breach of European Union law provided that:

  • They fall within the scope of the European Union acts listed in the Annex to Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019.
  • They affect the financial interests of the European Union; or they affect the internal market.
    For all other communications (complaints, suggestions, acknowledgements, other types of contact), this channel can be used.

The features of the Internal Information System and its management process are described in the Internal Information System Policy and Information Management Procedure, which can be found below.