EINF governance and anti-corruption disclosures cover several of the mandatory reporting areas of Spain’s non-financial information statement. They generate less raw data than the environmental pillar, but they carry significant reputational weight, and verifiers pay close attention to whether your policies are actually applied. This guide explains what Law 11/2018 asks for, what evidence to gather, who usually owns it and where companies tend to fall short.
What the law requires
Law 11/2018 asks for disclosure on governance-related matters across several dimensions:
- Anti-corruption and bribery: measures to prevent corruption and bribery, measures to combat money laundering, and contributions to foundations and non-profit organisations
- Human rights: due diligence procedures, complaints of human rights violations, and promotion of the fundamental conventions of the International Labour Organization
- Board diversity: the diversity policy applied to the board of directors, covering aspects such as age, gender, disability, and training and professional experience
- Tax information: profits obtained country by country, income taxes paid and public subsidies received
- Political contributions and lobbying: not named in the law, but commonly reported where applicable
For each topic, describe not just the policy, but the concrete measures taken, the results obtained and the risks identified. This policy, results and risks structure applies across the whole EINF reporting requirements.
Anti-corruption and bribery
This is the core of the pillar. Your disclosure should cover the following areas.
Policies and codes of conduct
- Whether your company has a formal anti-corruption policy or code of ethics, and who approved it
- How the policy is communicated to employees, suppliers and business partners
- Training programmes and their reach (percentage of staff trained, by category where possible)
- The corruption risk assessment behind the policy, and the internal controls that follow from it
Anti-money laundering
- Measures in place to prevent money laundering, proportionate to your sector
- For regulated entities, a reference to the specific procedures and responsible bodies
Contributions to foundations and non-profits
- Amounts contributed to foundations and non-profit organisations during the year
- The approval process for donations and sponsorships, which verifiers often ask to see
Whistleblowing channels
- Description of the reporting mechanisms (online platform, email, hotline)
- Guarantees of confidentiality and non-retaliation, in line with Spain’s Law 2/2023 on whistleblower protection
- Number of reports received and how they were resolved, without compromising anonymity
Incidents and sanctions
- Confirmed 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. Verifiers expect a clear confirmation, not silence.
Human rights due diligence
The EINF asks how your company prevents and manages human rights risks:
- 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
- ILO conventions: how you promote freedom of association and collective bargaining, and the elimination of discrimination, forced labour and child labour
- Grievance mechanisms: how affected parties can raise concerns, and the complaints received
- Remediation: actions taken when violations are identified
For companies with complex supply chains, this is often the most demanding area. Document your supplier assessment process, audit results and corrective actions.
Board diversity and governance structure
Disclose the composition of your governing bodies and the diversity policy behind it:
- Gender breakdown of the board and senior management
- Age distribution and professional background
- Diversity policy, objectives, and progress against them
- Committees with responsibility for overseeing sustainability matters
Spain’s Organic Law 3/2007 on equality and the corporate governance recommendations for listed companies set clear expectations on gender balance. Your EINF should explain how your board compares with them. If no diversity policy exists, say so and explain why.
Tax transparency
Law 11/2018 asks for:
- Profits obtained per country
- Corporate income tax paid per country
- Public subsidies received
Even if your company operates mainly in Spain, report these figures clearly. Good practice is to reconcile them with the annual accounts and briefly explain significant differences between profit and tax paid, since verifiers check consistency with the financial statements.
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 carry out lobbying
- Key advocacy positions
Many Spanish companies report zero political contributions. That is perfectly acceptable, but it must be stated explicitly.
Who owns the data
| Topic | Usual owner | Typical evidence |
|---|---|---|
| Anti-corruption policy and training | Compliance or legal | Approved policy, training records |
| Whistleblowing channel | Compliance | Channel register, case summaries |
| Donations and sponsorships | Finance, communications | Accounting entries, approval records |
| Human rights and suppliers | Procurement, sustainability | Supplier assessments, audit reports |
| Board composition | Company secretary | Board records, governance report |
| Tax information | Tax or finance | Tax returns, annual accounts |
Name a single owner per topic and agree a deadline before year end. The EINF data collection guide shows how to organise this across all five pillars.
How verifiers review this pillar
The EINF must be verified by an independent assurance provider. For governance topics, verifiers typically:
- Check that policies exist, are approved and are dated within or before the reporting period
- Ask for evidence of implementation: training attendance, channel statistics, supplier assessments
- Reconcile tax figures with the annual accounts
- Confirm that “no incidents” statements are backed by an internal check, not assumed
Common pitfalls
- Generic policies without evidence: verifiers 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 that the channel exists and state the count.
- Ignoring supply chain risks: human rights due diligence must extend beyond your own operations.
- Vague diversity statements: provide actual numbers, not aspirational language.
- Forgetting donations: contributions to foundations and non-profits are an explicit requirement and are easy to overlook.
Governance pillar checklist
- Anti-corruption policy approved, with communication and training data
- Anti-money laundering measures described
- Donations to foundations and non-profits quantified
- Whistleblowing channel described, with number of reports and outcomes
- Incidents and sanctions reported, or their absence confirmed
- Human rights risk assessment, ILO commitments and grievance data
- Board composition and diversity policy disclosed
- Profits, income tax and subsidies reported by country and reconciled with the accounts
How Dcycle helps
In Dcycle’s EINF projects, each governance requirement is mapped to its GRI indicator and linked to the files that support it: the approved policy, the training register, the whistleblowing summary. With evidence traceability, every figure points to its source, so when the verifier asks for a sample, the evidence is already organised. If you want to see how this works for your next EINF, request a demo.
Frequently asked questions (FAQs)
Do we need to report if we had no corruption incidents?
Yes. State explicitly that no incidents were identified during the reporting period, and keep evidence of the internal check behind that statement.
Is tax information only required for multinational groups?
No. Law 11/2018 asks for profits, income tax paid and public subsidies by country. A company operating only in Spain reports a single country, but still reports the figures.
Do political contributions have to be disclosed?
The law explicitly asks for contributions to foundations and non-profit organisations. Political contributions and lobbying are commonly reported where they exist; if your company makes none, saying so removes any doubt.
What does the verifier look for in the whistleblowing section?
A description of the channel, its confidentiality and non-retaliation guarantees, and the number of reports received with their outcomes. Zero reports is a valid figure if it is stated.
