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Purpose of the Model

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  • The purpose of our Crime Prevention Model It is designed to mitigate the risk of the Sabadell Seguros y Pensiones entities in Spain incurring criminal liability for offences committed in the name or on behalf of the company, whether for direct or indirect benefit, by their legal representatives and de facto or de jure administrators in such cases as envisaged in the Criminal Code.
  • Legal entities These entities can also be criminally liable for offences committed in the exercise of corporate activities, whether for direct or indirect benefit, when such acts are perpetrated by individuals under the authority of other individuals who hold powers of administration and management and due to a failure to exercise due control over them.

Our Crime Prevention Model

The model includes the following preventive measures:

  • Criminal Compliance Policy, which outlines ​​​​​​the criminal offences applicable to legal entities and also includes the following details and criteria: 
    • ​​​​​Behaviours that constitute an offence
    • ​​​​​​​The commitment of the entities to preventing offences
    • What is expected of members of the Organisation and of our Business Partners.
  • A Criminal Supervisory Authority.
  • Channels of Communication and Complaints: It is compulsory to report any event potentially related to a crime through our whistleblowing channel. The whistleblowing channel currently available for Sabadell Seguros y Pensiones entities is the “Zurich Ethics Line”. This channel is shared with our partner Zurich Seguros and is also available to third parties.
  • Disciplinary System: In accordance with prevailing provisions, and as set out in the collective agreement applicable to the insurance sector published in the Official State Gazette (BOE) on 1 June 2017, a disciplinary protocol has been established with regard to breaches of compliance with the criminal prevention model that may result in disciplinary sanctions being brought against offenders.
  • Rules for business partners (third parties): Prior to contracting certain Business Partners (risk-based approach), it must be determined whether or not they have a Criminal Prevention Model. We have contractual clauses for acceptance of the principles of our Criminal Compliance Policy and Code of Conduct​​​​​​​.
  • Crime Prevention and Response Manual: this volume lists the phases in the prevention model, including the investigation process, the functioning of the Supervisory Body and the Sanctioning System.

Our commitment

Sabadell Seguros y Pensiones is committed to complying with the law and protecting its employees, customers and shareholders. The effectiveness of our Crime Prevention Model is essential in this regard, and we thus make every effort to ensure that all members comply with our Code of Conduct, internal rules, processes and monitoring environment.

How to submit reports

All members of the organisation have the duty to report inappropriate conduct to ensure the effectiveness of the entities’ criminal prevention models. Communications, whether written or oral, will be processed with strict confidentiality, and may be made anonymously. There are different Communication Channels, also available to third parties, to report irregularities:

  • 01
    Zurich Ethics Line

    Zurich Ethics Line (ZEL) - online Written channel, shared with our partner, Zurich Seguros.

  • 02
    By phone

    Calling the telephone number 900 998 446. Oral channel, this is the telephone number for the Zurich Ethics Line, shared with our partner, Zurich Seguros.

Reporting misconduct should always be done in good faith; abuse or submitting reports in bad faith, or having knowledge that the information provided is false may lead to disciplinary action against the perpetrator.

Non-retaliation policy

  • Sabadell Seguros y Pensiones does not tolerate retaliation when concerns have been reported in good faith; nor do we tolerate retaliation against the participants in an investigation conducted in good faith (e.g. witnesses) or against those who provide information/evidence during an investigation. Should such incidents occur the company will take disciplinary action.
  • If you believe you are being retaliated against for submitting a report or participating in an investigation, you should immediately report this as misconduct through any available communication channel. 
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