Compliance with the law, respect, integrity, transparency, excellence, professionalism, confidentiality, and social responsibility are the basic principles that inspire the actions and govern the activity of CaixaBank.
CaixaBank's Code of Ethics and Anti-Corruption Policy seek to ensure not only compliance with applicable legislation, but also a firm commitment to its ethical principles as signatories of the United Nations Global Compact.
In accordance with CaixaBank's Code of Ethics and Business Conduct and the principle of compliance with the law, CaixaBank defines, in its Corporate Criminal Compliance Policy, the crime prevention model, which includes the set of measures aimed at preventing, detecting, and reacting to criminal conduct and identifies the risks and controls associated with the same that are established.
All employees, managers and members of its administrative body must comply with the laws and regulations in force at all times, as well as any internal regulations or circulars of CaixaBank, where, among others, the fight against money laundering and the financing of terrorism is a priority.
CaixaBank, S.A. Zweigniederlassung Deutschland, as part of the CaixaBank International Network, encourages and promotes compliance with ethical values and principles within its sphere of competence.
All information on the main responsible policies and principles in social and environmental matters can be found at Ethics and integrity policies | CaixaBank
Prevention of Money Laundering and International Financial Sanctions
CaixaBank Group is firmly committed to the prevention of money laundering and the prevention of the financing of terrorist activities, and to compliance with International Financial Sanctions and Countermeasures Programs.
CaixaBank, S.A. Zweigniederlassung Deutschland has adopted this commitment in compliance with the main laws, regulations and directives applied by the local authorities, in addition to promoting the application of the highest international standards in the field (European Banking Authority (EBA), European Central Bank (ECB), Financial Action Task Force (FATF), among others).
In this context, we are required to determine the identity of each customer and each person acting on behalf of the customer in accordance with applicable anti-money laundering, international sanctions, and tax information exchange legislation. Therefore, we may need to contact you to obtain information to enable us to complete our due diligence and know-your-customer (KYC) process prior to entering into a business relationship with you, and also to obtain additional information during the course of our business relationship.
Under any applicable anti-money laundering, international sanctions, and tax information exchange legislation, we may not be able to process transactions or transactions with you or for you, or otherwise deal with you, in the event that, in our opinion, such legislation is breached. In the event of suspected money laundering, terrorist financing and/or any other criminal activity and/or non-compliance with international sanctions, we may be required to report information about you/your bank accounts to law enforcement and/or terminate the business relationship altogether.
CaixaBank, S.A., and the CaixaBank Group undertake to comply with the obligations arising from the CRS and other tax compliance regimes, including FATCA. Such obligations arise from:
the Multilateral Competent Authorities Agreement on Automatic Exchange of Financial Account Information signed by the Federal Republic of Germany on October 29, 2014 (CRS),
the Act on the Automatic Exchange of Financial Account Information in Tax Matters (Gesetz zum automatischen Austausch von Informationen über Finanzkonten in Steuersachen),
the Council Directive 2014/107/EU of 9 December 2014 amending Directive 2011/16/EU as regards automatic and compulsory exchange of information in the field of taxation,
the Agreement between the United States of America and the Federal Republic of Germany to improve international tax compliance and with respect to the U.S. reporting and notification provisions commonly known as the Foreign Account Tax Compliance Act of May 31, 2013 (FATCA), and
the Regulation implementing the obligations arising from the agreement between the Federal Republic of Germany and the United States of America for the promotion of tax compliance in international affairs and with respect to the U.S. reporting and notification provisions commonly known as FATCA (FATCA-USAUmsetzungsverordnung) of July 23, 2014.
Therefore, depending on the circumstances, we may be required to forward information about you to German, Spanish, U.S., or other tax authorities. Such information may also be shared between tax authorities and/or other authorities worldwide.
CaixaBank, S.A., and the CaixaBank Group further comply with any export controls, trade, economic or financial sanctions, laws, regulations, directive resolutions, embargoes, programs or restrictive measures administered (hereinafter "Sanctions"), enacted or enforced by (i) the United Nations, (ii) the European Union or any of its member states, (iii) the Federal Republic of Germany, (iv) the Kingdom of Spain, (v) the United States of America, (vi) any other country relevant to CaixaBank, S.A. or the CaixaBank Group or its business or relevant to a particular payment, and/or (vii) the respective governments and official institutions or agencies of any of the foregoing, including, without limitation, the German Federal Office of Economics and Export Control (BAFA) and the German Federal Bank (Bundesbank), the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury, the U.S. Department of State, the U.S. Department of Commerce and the Office of Financial Sanctions Enforcement (OFSI) of His Majesty's Treasury in the United Kingdom (collectively, the "Sanctioning Authorities").
Subject to any European Union anti-boycott or blocking laws, regulations, or statutes in force from time to time in the Federal Republic of Germany applicable to such entity (including, without limitation, EU Council Regulation (EC) No. 2271/96 and Section 7 of the German Foreign Trade and Payments Ordinance (Verordnung zur Durchführung des Außenwirtschaftsgesetzes (Außenwirtschaftsverordnung), CaixaBank, S.A. or the CaixaBank Group may not enter into or maintain a business relationship with any person who:
A. is on a Sanctions List or (directly or indirectly) is owned or controlled by, or acts on behalf of, a person on a Sanctions List (as defined below), (b) is located, incorporated or organized under the laws of, or (directly or indirectly) is owned or controlled by, or acts on behalf of, a person located, incorporated or organized under the laws of, or (directly or indirectly) owned or controlled by, or acting on behalf of, a person located, incorporated or organized under the laws of a jurisdiction, country or territory that is, or whose government is, subject to sanctions at jurisdiction, country or territory level, or (c) otherwise subject to Sanctions (hereinafter together the "Restricted Persons", and , "Sanctions List" shall mean (i) the Consolidated Sanctions List of the United Nations Security Council, (ii) the Consolidated List of persons, groups and entities subject to EU financial sanctions maintained by the European Commission, (iii) the list of Specially Sanctioned Nationals of the European Union, (iv) the Consolidated List of Nationals of the European Union subject to EU financial sanctions maintained by the European Commission, (v) the list of Specially Designated Nationals and Blocked
Persons maintained by OFAC, or (vi) any present or future similar sanctions list maintained by, or public announcement of Sanctions designations made by, any of the above Sanctioning Authorities, each as amended, supplemented or replaced from time to time).
B. acts directly or indirectly for or on behalf of any Restricted Person or participates in or controls a Restricted Person.
C. Is incorporated, located, has its principal place of business or is resident in a jurisdiction, country, or territory subject to Sanctions.
D. Maintains any business relationship or has any trade or business activity for or with any person or with any jurisdiction, country, or territory subject to Sanctions.
E. Use the business relationship with CaixaBank to make funds available, directly or indirectly, to any Restricted Person or use such funds to finance, directly or indirectly, any activity or business with any Restricted Person or with any jurisdiction, country, or territory that, at the time the funds are used, is subject to Sanctions or otherwise in breach of Sanctions.
More information on the General Principles of the CaixaBank Group's Corporate Policy on the Prevention of Money Laundering and the Financing of Terrorism and the Management of International Financial Sanctions and Countermeasures can be found at this link: Corporate policies and other corporate documents | CaixaBank