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I. 3. ISO 19600
• High level structure: (i) Context of the organization (ii) Leadership (iii) Planning (iv) Support (v)
Operation (vi) Performance evaluation (vii) Improvement
curity roles and responsibilities. The Office 365 security policies address purpose, scope, roles,
responsibilities, compliance requirements, and required coordination among the various Microsoft
organizations providing some level of support for the security of Office 365. Office 365 security policies
contain rules and requirements that must be met in the delivery and operation of Office 365. Office 365
employees and contingent staff are accountable and responsible for complying with these guiding principles
in their designated roles.
ISO 37001

II. 3. ISO 37001

• Common framework for a management system for the risks of corruption and bribery.
• Important for companies with international commercial activity.
• It includes risk management as an essential part of a compliance management system and is based on
the principle of Risk-Based Approach (RBA).
• It focuses on Compliance as part of the organization's culture and emphasizes that compliance is the
responsibility of the governing body rather than simply an internal function.
• Essential in jurisdictions with extraterritorial legislations (USA, United Kingdom) to be able to operate
with companies in your country.
• Establishes a specific management system, which can be included in a general compliance
management system.
II. 3. ISO 37001
II. 3. ISO 37001
• It incorporates requirements and, therefore, is certifiable.
• It is applicable to organizations of any size and sector.
• Presents the structure of High Level, common to all international ISO standards of management
systems, which is integrated in other management systems.
II. 3. ISO 37001
• Specific controls designed to prevent bribery (gifts and invitations, facilitation and extortion payments,
hiring procedures, due diligence measures, etc.)
• It contains practical annexes with concrete and specific examples and recommendations.
UNE 19601
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II. 4. UNE 19601
• Has a high level structure
curity roles and responsibilities. The Office 365 security policies address purpose, scope, roles,
responsibilities, compliance requirements, and required coordination among the various Microsoft
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organizations providing some level of support for the security of Office 365. Office 365 security policies
contain rules and requirements that must be met in the delivery and operation of Office 365. Office 365
employees and contingent staff are accountable and responsible for complying with these guiding principles
in their designated roles.
• Ease to synchronize with different standards
• Possibility of integrating management systems, eliminating duplicities
II.4. UNE 19601
• Certifiable standard
• Practical standard: commitment to the structure of the cycle DEMING P-D-C-A, it is not a project with
an end date
• Security in the legal traffic within the supply chain
• Assessment in a judicial procedure of the need for a culture of compliance
Leadership
to. Leadership
•Chapter 5
•Art. 5.1.1 Governing Body
•Art. 5.1.2 Criminal Compliance Body
•Art. 5.1.3 Senior management
• 5.2 Compliance policy
• 5.3 Roles, responsibilities and authorities in the organization
to. Leadership
5.1.1: GOVERNMENT ORGAN: 20 REQUIREMENTS - LEADERSHIP and COMMITMENT (executive decisions
that ensure the approval, application and effectiveness of the SGCP) - MUST:
• VALUES OF THE ORGANIZATION: Promote a culture of Criminal Compliance and act according to the
Legal Order
• PENAL COMPLIANCE MANAGEMENT SYSTEM: ADOPT, IMPLEMENT, MAINTAIN, IMPROVE
• GIVE OF FINANCIAL, material and human RESOURCES
• APPROVE COMPLIANCE POLICY
• ENSURE SGCP EFFICACY: periodically review and modify as necessary
• PENAL COMPLIANCE ORGAN: Establish and endow it with autonomous powers of initiative and control
- WILL OF THE ORGANIZATION: Ensure procedures for:
• Specify the formation of the will
•Take decisions
• Execute decisions to. Leadership
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ORGAN OF COMPLIANCE: 28 REQUIREMENT + 5 RECOMMENDATIONS RELATED TO 4 AREAS -

FUNCTIONS: - RISK MANAGEMENT (identify and manage)
• JOBS POSITION: include responsibilities of Compliance and performance evaluation
• TRAINING: ensure formative support
• DOCUMENTED EVIDENCE: Promote an information and documentation system
• INFORMATION MANAGEMENT: adopt and implement processes
• OPERATION: Ensure employees access to resources Compliance, inform the OdG
• EVALUATION PERFORMANCE: Establish indicators, measure / analyze performance
• SGCP REVIEW: Ensure periodic review
• CONTINUOUS IMPROVEMENT: Promote and supervise - CAPABILITIES: EVIDENCE COMMITMENT
• Absence of conflict of interest
•Integrity
• Communication skills, ability to influence
• Capacity and prestige
• Competence - GUANTE SGCP: supervision, surveillance and control + resources and personnel -
INDEPENDENCE: access to the OGD and adequate position in the organization
to. Leadership
5.1.3: 15 REQUIREMENT RELATED TO EXECUTION AND SUPPORT FUNCTIONS
-SGCP:
• Ensure implementation
• Effectively deal with criminal risks
• Guarantee the incorporation of the SGCP in the processes of the Organization - RESOURCES: -
Guarantee availability - PERSONAL:
• Comply and make them comply
• Communicate internally importance
• Direct and support
-GOOD CONTINUES:
• Promote it
• Support management roles - REPORT COMMUNICATION:
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• Encourage the use of reporting and reporting procedures

• Guarantee protection and indemnity of communicants
HIGHLY DIRECTED DELEGATIONS IN PENAL RISK AREAS> LOW DEMAND PROCEDURES AND CONTROLS
THAT GUARANTEE DECISIONS FREE OF CONFLICT OF REAL OR POTENTIAL INTEREST
to. Leadership
CULTURE AND FUNCTION OF COMPLIANCE
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b. C
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Compliance policy
• Compensation systems for compliance achievements
• Evaluations to employees before hiring
•Continuous training
• Communication continues, open and adequate
• Visible recognition of the achievements of compliance management
• Ethical leadership. "Tone at the top"
• As the hierarchical responsibility of a person in an organization increases, it increases their visibility and
ability to influence the behavior of others.
b. Compliance Culture
• The way of acting (behavior) of the members of Senior Management moves the way of acting of the
rest of the individuals that make up the organization: visible, consistent and sustained commitment over
time with a standard of common behavior
b. Compliance Culture
• The business culture must be an element that positively influences the behavior and attitude of all
those who make up the organization: culture of compliance
b. Compliance Culture
b. Compliance Culture
Change perception detection and punishment
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Reduce / eliminate behavior bias

Improve the role of moral considerations
Improve culture (eliminate undue environmental influences / group pressure)
• Application of fast and proportionate disciplinary measures
• Consistency in treatment regardless of position
• Clear criminal compliance policy
• Compensation systems that assess achievement of criminal compliance objectives
• An appropriate initiation or orientation program that emphasizes criminal compliance and the values
of the organization
• Tone in the direction (respect and application from above) • Recognition achievements in compliance •
Continuous, open and adequate communication
The SGCP: Context and Planning
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c. The SGCP - Context
• The SGCP must be appropriate to the circumstances of the organization in which it operates.
• Chapter 4 deals with aspects related to it (design the management system and maintain it and
continuous improvement).
c. The SGCP - Context
• Understand the organization and its context
• Understand the needs and expectations of the groups of interest
• Determine the scope of the SGCP
c. The SGCP - Context
•Art. 4.1: adequate knowledge of the internal and external circumstances of the organization, as they
condition the design, maintenance and improvement of its management system.
• A criminal compliance management system is only adequate when it is proportional to the
circumstances of the organization and is projected on risks that truly threaten it.
c. The SGCP - Context
• Size and structure of the organization
• Locations and sectors in which it operates or plans to operate
• Nature, scale and complexity of activities
• Members of the organization and business partners
c. The SGCP - Context
• The "Circular 1/2016 on the criminal liability of legal persons in accordance with the Reform of the
Criminal Code made by the Organic Law 1/2015": "the models of organization and management must be
perfectly adapted to the company and its specific risks "
c. The SGCP - Context
•Art. 4.2: necessary to determine the interest groups and their requirements to be considered within the
SGCP (for example: regulator, administrative authorities, shareholders / investors, consumers and users)
c. The SGCP - Context
•Art. 4.3: Objective and subjective scope of the SGCP.
• The scope of the SGCP is related to the criminal risks that affect the perimeter formed by the members
of the organization and the business partners.
c. The SGCP - Context
•Art. 4.4: The organization adopts, implements, maintains and continuously improves a SGCP, which
includes the necessary policies, processes and procedures as well as their interactions, in accordance with
the requirements established by the Standard.
c. The SGCP - Planning
•Chapter 6
• 6.1 Actions to deal with risks and opportunities
• 6.2 Identification, analysis and evaluation of criminal risks
• 6.3 Crime prevention objectives and planning to achieve them
Section 6.2 of the UNE Standard adopts the classic division of criminal risk assessment in three activities:
identification, analysis and evaluation. Identification: It consists in knowing what potentially criminal
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behaviors could entail the criminal responsibility of the juridical person, taken care of the concrete
circumstances of the organization. Analysis: It consists in analyzing what probability exists that they are
materialized and what its consequences would be, in such case. This analysis is what finally allows us to
assess criminal risks. Valuation: Consists in the prioritization of criminal risks and, therefore, of the resources
destined to their prevention, detection and management, emphasizing those that suppose a greater than
low risk.
c. The SGCP - Planning
The SGCP: Planning and operational control
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. The SGCP: Planning and operational control

HistoryWhether management authorization process is defined and implemented for any new information
processing facility within the organization.
Whether management authorization process is defined and implemented for any new information
processing facility within the organization.

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