Compliance and Ethical Conduct Law in Spain

Employment frameworks for consistent and responsible corporate conduct

We advise companies on the design, review and implementation of compliance and ethical conduct frameworks under Spanish employment law.

Our work covers compliance programmes, codes of conduct, training, internal investigations, whistleblowing, disciplinary procedures and the employment implications of corporate ethics policies.

We help organisations translate their culture, values and strategic objectives into clear standards of conduct that can be applied consistently and defended legally.

Compliance and ethical conduct under Spanish employment law

Effective compliance requires more than formal policies or standard procedures.

 

The company’s rules, reporting channels, investigation framework, disciplinary response, employee representative obligations and internal communications must be aligned before incidents arise.

 

We advise companies from the design of the compliance framework through implementation, investigation, enforcement and defence of subsequent disputes.

Core compliance and ethical conduct matters

We advise on:
  • Employment compliance programmes
  • Codes of conduct and ethical standards
  • Whistleblowing and internal reporting systems
  • Internal workplace investigations
  • Disciplinary procedures and sanctions
  • Conflicts of interest
  • Gifts, hospitality and anti-corruption rules
  • Confidentiality and information security
  • Use of company systems and resources
  • Equal treatment and respectful workplace standards
  • Anti-harassment and anti-discrimination measures
  • Manager and employee training
  • Governance and allocation of internal responsibilities
  • Employee representative information and consultation
  • Compliance audits and policy reviews
  • Employment litigation arising from compliance matters

Compliance programmes and codes of conduct

A compliance framework should reflect how the organisation operates in practice.

 

We draft and review programmes, codes of conduct and internal standards covering professional behaviour, conflicts of interest, confidentiality, use of resources, reporting duties and ethical decision-making.

Training and organisational awareness

Compliance rules are only effective when employees and managers understand how they apply.

 

We design and review training programmes for management teams, HR, investigators and the wider workforce, adapting the content to the company’s risk profile and internal responsibilities.

Internal reporting and whistleblowing

Internal reporting systems must protect confidentiality, support proper escalation and reduce the risk of retaliation.

 

We advise on reporting procedures, employment safeguards, coordination with whistleblowing frameworks and the management of complaints from receipt to resolution.

Internal investigations

Investigations require independence, procedural discipline and careful handling of evidence.

 

We advise on scope, interviews, documentation, confidentiality, interim measures, findings and the legal assessment of potential misconduct.

Disciplinary processes and proportionality

Where misconduct is established, the company must adopt a consistent and legally defensible response.

 

We advise on disciplinary classification, evidentiary standards, proportionality, sanctions, procedural requirements and the relationship between internal policies, collective agreements and Spanish employment law.

Compliance audits and framework reviews

Compliance systems should evolve with legal developments, organisational change and emerging risk.

 

We review existing programmes, policies, reporting procedures and disciplinary practices to identify gaps, inconsistencies and areas requiring stronger legal structure.

How we support the process

Assessment

Existing framework, organisational culture, legal obligations and risk profile.

Design

Policies, programmes, reporting channels, responsibilities and training.

Implementation

Communication, consultation, rollout, governance and internal awareness.

Enforcement

Investigations, disciplinary action, remediation and litigation defence.

When to involve employment counsel

Employment counsel should be involved when compliance frameworks are designed, reviewed or applied to specific incidents.

 

Early involvement is particularly important where the matter concerns whistleblowing, senior executives, potential retaliation, disciplinary action, fundamental rights, employee representatives or significant reputational exposure.

Compliance and Ethical Conduct FAQs

What should an employment compliance programme include?

It may include codes of conduct, reporting procedures, disciplinary rules, investigation protocols, training, governance responsibilities and controls adapted to the organisation’s activities and risk profile.

Yes. The investigation should be impartial, proportionate, confidential and respectful of employment, privacy and fundamental rights.

Potentially, yes. The rules must be valid, properly communicated and consistent with applicable law and collective agreements. Any sanction must also be proportionate and supported by evidence.

Before implementing the framework and as soon as a sensitive complaint or potential breach arises. Early advice helps preserve evidence, protect rights and ensure a consistent response.

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