I. INTRODUCTION
This Code of Good Governance (hereinafter, the "Code") complements the Statutes of the Rafael del Pino Foundation (hereinafter, the "Foundation") and the other internal rules that the Foundation has adopted, and is the result of the decision of its Board of Trustees to adopt a set of recommendations whose objective is to improve the governance of the Foundation in order to efficiently fulfil its mission in the terms decided by its Founder.
This Code follows the principles of the Spanish Association of Foundations, as well as European and international conventions on the subject.
II. ACCOUNTING, TRANSPARENCY AND ACCOUNTABILITY
The Foundation shall keep orderly accounts appropriate to its activity. Independently of the rendering of accounts to the Protectorate, the Foundation shall publish relevant, updated and accurate economic and financial information on its website.
It shall also make its audit report publicly available on its website.
The Foundation will publish an annual Report which it will reproduce on its website. In its drafting, it shall follow the usual lines in the foundation sector and generally accepted international recommendations. The Report shall include a section on the degree of compliance with the good governance recommendations contained in this Code and the causes of any non-compliance.
Relevant information regarding the Foundation and its activities shall be made public through its website and shall be kept up to date at all times.
III. FINANCIAL CONTROL AND SUPERVISION
The Foundation has internal rules regarding the selection and management of temporary investments, in accordance with the guidelines of the Spanish Securities and Exchange Commission (CNMV).
The Foundation's accounts shall be audited annually by an independent external auditor.
The Foundation shall, at all times, maintain the value of its assets in real terms by taking appropriate action.
Annually, the Foundation shall prepare a document on investment policy, expected return, liquidity requirements, risk tolerance, tax and legal obligations and any other relevant circumstances for consideration by the Board of Trustees.
IV. CRIME PREVENTION (Corporate Compliance)
The Foundation will ensure compliance with the "due diligence" mechanisms it has adopted to prevent the commission of criminal acts within the Foundation. To this end, it has a Protocol for management, investigation and response and a Procedure for the prevention of punishable insolvencies and for the processing of official letters, notifications and seizures. It also has a Code for the use of IT tools and a Protocol for the prevention of public and private corruption offences.
The Board of Trustees appointed a person responsible for monitoring, updating and improving the Crime Prevention System. This person must prepare an annual report on Corporate Compliance.
V. INFORMATION SECURITY POLICY
The Foundation ensures that users of technological resources make appropriate, responsible and lawful use of them and act in accordance with the information security policy approved by the Foundation.
VI. GLOBAL COVENANT
The Foundation will remain faithful to its commitment to support and disseminate the 10 Principles that inspire the United Nations Global Compact.
