The governance and anti-corruption pillar is one of the five mandatory reporting areas of the EINF. While it generates less raw data than the environmental pillar, it carries significant reputational weight , and auditors pay close attention to the quality of your policies and procedures.
What the law requires
Spain’s Law 11/2018 mandates disclosure on governance-related matters across several dimensions:
- Anti-corruption and bribery , policies, procedures, and outcomes
- Board composition and diversity , gender, age, background
- Human rights due diligence , across your operations and supply chain
- Tax transparency , country-by-country profits and taxes paid
- Political contributions and lobbying , if applicable
Companies must describe not just their policies, but also the concrete measures taken, results obtained, and risks identified.
Anti-corruption and bribery
This is the core of the governance pillar. Your disclosure should cover:
Policies and codes of conduct
- Whether your company has a formal anti-corruption policy or code of ethics
- How the policy is communicated to employees, suppliers, and partners
- Training programmes and their reach (percentage of staff trained)
Whistleblowing channels
- Description of reporting mechanisms (hotline, email, digital platform)
- Guarantees of confidentiality and non-retaliation
- Number of reports received and outcomes (without compromising anonymity)
Incidents and sanctions
- Corruption-related incidents during the reporting period
- Legal proceedings, fines, or sanctions
- Remediation measures taken
If your company has had no incidents, state this explicitly , auditors expect a clear confirmation, not silence.
Human rights due diligence
The EINF requires disclosure on how your company prevents human rights violations:
- Risk assessment , identify sectors, geographies, and supply chain tiers with elevated risk
- Policies , commitments aligned with the UN Guiding Principles on Business and Human Rights
- Grievance mechanisms , how affected parties can raise concerns
- Remediation , actions taken when violations are identified
For companies with complex supply chains, this is often the most challenging area. Document your supplier assessment processes, audit results, and any corrective actions.
Board diversity and governance structure
Disclose the composition of your governing bodies:
- Gender breakdown of the board and senior management
- Age distribution and professional background
- Diversity policies and targets, including progress against them
- Committees with ESG oversight responsibilities
Spain’s Organic Law 3/2007 and Corporate Governance Code set specific expectations around gender parity , your EINF disclosure should reference compliance with these benchmarks.
Tax transparency
Country-by-country reporting is required for multinational groups:
- Profits obtained per country
- Corporate income tax paid per country
- Public subsidies received
- Explanation of material discrepancies between profit and tax paid
Even if your company operates primarily in Spain, include a clear statement of your tax contribution and any tax incentives applied.
Political contributions and lobbying
If your company engages in lobbying or makes political contributions, disclose:
- Amounts contributed to political parties or campaigns
- Membership of trade associations that engage in lobbying
- Key lobbying positions or advocacy activities
Many Spanish companies report zero political contributions , this is perfectly acceptable, but must be stated explicitly.
Common pitfalls
- Generic policies without evidence , Auditors want to see implementation, not just a policy document. Include training numbers, audit results, and real outcomes.
- Missing whistleblowing data , Even if you received zero reports, disclose the channel exists and state the count.
- Ignoring supply chain risks , Human rights due diligence must extend beyond your direct operations.
- Vague diversity statements , Provide actual numbers, not aspirational language.
How Dcycle helps
Dcycle’s governance module helps you structure your anti-corruption and human rights disclosures with guided questionnaires that map directly to the EINF’s legal requirements. The platform tracks policy documents, training completion rates, and whistleblowing statistics in one place , so when audit season arrives, your evidence is already organised and export-ready.
