Internal Employment Policies in Spain

Clear internal rules for consistent and defensible decision-making

We advise companies on the drafting, review and implementation of internal employment policies in Spain.

Our work covers codes of conduct, working time, remote work, equality, harassment, disciplinary rules, use of technology, confidentiality, expenses and other internal standards.

We create policies that reflect the company’s culture and objectives while making internal rules easier to understand, apply and defend.

Internal policies under Spanish employment law

Internal policies provide structure, define expectations and support consistent employment decisions.

 

Their content, legal basis, communication, employee representative involvement, implementation and enforcement must be aligned before they are introduced.

 

We advise companies from the initial assessment of internal needs through drafting, consultation, implementation and ongoing review.

Core internal policy matters

We advise on:
  • Codes of conduct
  • Working time and attendance policies
  • Remote and hybrid working policies
  • Use of email, internet and company devices
  • Data protection and employee monitoring
  • Confidentiality and information security
  • Social media policies
  • Equality and anti-discrimination policies
  • Workplace harassment protocols
  • Whistleblowing and reporting procedures
  • Disciplinary rules and procedures
  • Leave and absence policies
  • Expenses and business travel
  • Benefits and flexible compensation
  • Health and safety-related internal rules
  • Conflicts of interest
  • Gifts, hospitality and ethical conduct
  • Policy updates following legal or organisational change

Codes of conduct and workplace standards

A code of conduct should provide a clear framework for professional behaviour without relying on generic language.

 

We draft and review internal standards covering conduct, conflicts of interest, confidentiality, respectful behaviour, use of company resources and compliance expectations.

Working time, attendance and flexibility

Policies on working time must be legally compliant and operationally realistic.

 

We advise on schedules, time recording, overtime, breaks, availability, flexible working, remote work and hybrid arrangements.

Technology, monitoring and confidentiality

The use of company systems requires clear rules on privacy, control and acceptable use.

 

We draft policies on email, internet, devices, remote access, monitoring, cybersecurity, confidential information and social media, taking into account employment and data protection requirements.

Equality, harassment and reporting procedures

Internal policies play a central role in preventing discrimination, harassment and retaliation.

 

We advise on equality policies, harassment protocols, reporting channels, investigation procedures, protective measures and coordination with the company’s wider compliance framework.

Disciplinary rules and enforcement

A policy is only effective if it can be applied consistently and lawfully.

 

We advise on prohibited conduct, disciplinary procedures, evidence, proportionality, sanctions and the relationship between internal rules, collective agreements and Spanish employment law.

Policy implementation and employee communication

The legal value of a policy depends not only on its wording, but also on how it is introduced and communicated.

 

We advise on employee representative consultation, acknowledgement procedures, training, internal communications, accessibility and evidence of implementation.

How we support the process

Assessment

Business needs, existing policies, legal framework and risk profile.

Drafting

Clear language, legal consistency, internal coherence and practical application.

Implementation

Consultation, communication, training, acknowledgement and rollout.

Review

Legal updates, organisational change, disputes and ongoing policy effectiveness.

When to involve employment counsel

Employment counsel should be involved before a new policy is communicated or an existing policy is materially changed.

 

Early involvement is particularly important where the policy affects working time, remote work, monitoring, disciplinary action, equality, whistleblowing, employee representation or fundamental rights.

Internal Employment Policies FAQs

What internal employment policies should a company have in Spain?

The appropriate policies depend on the company’s size, workforce and activities, but commonly include conduct, working time, remote work, technology use, confidentiality, equality, harassment, reporting and disciplinary rules.

Not always. However, certain policies or measures may require information, consultation or negotiation depending on their content, impact and the applicable legal framework.

Potentially, yes. The policy must be valid, properly communicated, consistent with applicable law and collective agreements, and the disciplinary response must be proportionate.

They should be reviewed after legal changes, organisational restructuring, new working models, incidents, litigation or whenever the existing rules no longer reflect business practice.

Corporate restructuring requires precision before action

We advise companies on the employment law strategy, negotiation, implementation and defence of restructuring processes in Spain.
Barcelona
Plaza Europa, 9-11, 15 D
Torre Inbisa
08908 Barcelona
Madrid
Príncipe de Vergara 62
1º Derecha
28006 Madrid