Corporate Criminal Liability. GOBERCOM

Created in 2004 by wide experience professionals in Corporate Criminal Compliance in USA multinational companies and in Spain, our partner GOBERCOM is a specialized consultant in preventive plans on Corporate Criminal Compliance.

On December 23rd, 2010. New Spanish criminal code introduced criminal liability for legal entities:

  • 31 bis article: In the circumstances provided for in this CODE, legal entities shall be criminally liable for offences committed in their name or on their behalf, an for their benefit, by the legal representatives and administrators whether the facto or de jure.

  • In the same circumstances, legal entities shall be criminal liable for offences committed, in the cause of their business and on their behalf and for their benefit, by those who, being subject to the authority of the individuals referred to in the preceding paragraph, may have committed the acts on account of not having exercised due control over them, given the specific circumstances of the case.


  • Employees and management acts within the company to gain advantage for it.

  • Criminal offences: Bribery, Embezzlement, Crimes against environment, tax obligations, I.T. damage, consumers related offences.

  • Sanctions: fines, penalties, annulment, temporary suspension, closure, court intervention.


Code of Conduct and Manual on Prevention and Crime response implementation.

Set up a preventive organ to oversee Manual Prevention compliance.

Implementation of internal controls to prevent wilful misconduct, doing a risk assessment and weak points vulnerability analysis.

We provide systems to communicate and report any misconduct or doubtful practices.

Periodic evaluation on Prevention Manual compliance (New services, organizational, change)


  • Corporate Criminal Compliance Prevention Plan.

  • Risk Map.

  • Corporate Criminal Liability Manual.

  • Code of ethics.

  • Reporting Channel.

  • Internal Control Body.

  • Training.

  • Partners like Gobercom with more than 20 years of experience.


Do you want more information?

If you have any questions about our services or if you want to request more information, you can contact us through any of our channels