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The fight against corruption

We have mechanisms to prevent, detect and investigate any possible fraud.

The ISO 26000 international guidelines on Social Responsibility, published in 2010 define corruption as the abuse of entrusted power for private gain. Corruption can take many forms, including soliciting, offering or accepting bribes in cash or in kind involving public officials or persons from the private sector, conflict of interest, fraud, money laundering, embezzlement, concealment and obstruction of justice and trading in influence.

Measures to prevent corruption in Repsol

The company has mechanisms to prevent, detect and investigate cases of corruption. The Audit and Control Division assesses the efficiency of company control systems and monitors control and compliance models through its teams for audit projects, internal control of financial reporting, control of partnerships, systems audits, legislative compliance, crime prevention model and online audit.

  • The crime prevention model in Spain includes the analysis and evaluation of penal risks related to corruption, as well as the corresponding mitigation controls. We have developed procedures to continuously monitor and assess the crime prevention model as well as protocols to investigate possible irregular actions related to corruption, among other issues.
  • The Internal Control System on Financial Reporting (ICSFR) has a model for preventing fraud risks in financial reporting based on the framework established by the American Institute of Certified Public Accountants (AICPA) and by the Public Company Accounting Oversight Board (PCAOB). This model identifies a significant number of controls aimed at covering the fraud risks in financial reporting.
  • Similarly, we have a model for the separation of functions in order to prevent and reduce the risk of fraud in the financial reporting process and have implemented this in the information systems under the ICSFR incompatibility matrices defined for each relevant process, allowing us to continuously and routinely monitor existing conflicts and detect cases in which the functions are not executed appropriately.
  • The Audit and Control Division assesses fraud risk in our internal audits through use of the methodology developed by the Committee of Sponsoring Organizations of the Treadway Commission (COSO), an international body that provides leadership on risk management, internal controls and fraud prevention. Our audits review the possibility of fraud within each unit, by means of partnership audits, information system audits and audit projects.

    In cases where a potential incident of corruption is detected, the Audit and Control Division launches an investigation, which is reported at the appropriate levels so that the relevant disciplinary steps can be taken and necessary remediation actions taken to solve existing internal control problems. Subsequently, the action plan is monitored to ensure that the agreed measures have been properly implemented.
  • The Online Audit Unit has designed indicators that alert us to the possibility of fraud or anomalous situations. Of these indicators, 35% are focused, at least to a certain degree, on fraud. In 2011, these indicators have been implemented in 27 Repsol companies, representing 12%.
  • We also conduct detailed audits on non-operated assets that include reviewing the accounting records of the associations in which the Group participates on a sampling basis. Part of this review involves analyzing the possibility of corruption, including violations of the US Foreign Corrupt Practices Act (FCPA) and unsupported payments. Furthermore, before entering new businesses, we ensure that any unsupported expenditure or undue payment is rejected and reported at the correct level.