That the committing of crimes for which Málaga CF may be criminally responsible be prevented and made difficult. This, in essence, is the aim of Compliance, a prevention system that focus on the restructuring and updating of the Club.
Its implementation, headed up by MCF’s judicial administrator, José María Muñoz, is now at an advanced stage, as the initial technical report was completed before the beginning of this season. Under the instruction of the department heads (Sport - Manolo Gaspar; Medical - Juan Carlos Pérez Frías; Institutional Relations - Ana Vera; Finance - Alberto Martínez; Business - Carlos Arias; and the MCF Foundation - Lucas Rodríguez) the initiative started months ago. At this time, the team is focused on risk analysis and preparing the Code of Ethics, Policies and Protocols that will be implemented at a later date.
This measure, contemplated and regulated (essentially) in article 31 of the Penal Code, develops protection protocols in all departments. In the medical department, for example, formulas to prevent doping are set (crimes against public health in the form of illicit practice involving medicines and health products); in the financial department the crime against the Public Treasury and Social Security or money laundering; and in terms of sport, the possible use of privileged information or the payment of irregular commissions (sports corruption), etc. Moreover, should a crime be committed, it’s about being able to detect it, sanction the perpetrators internally and report the offence to the relevant authority. Consequently, this avoids the Club bearing any responsibility and the crime is only attributable to the perpetrators of the possible criminal act.
This entire process is being tutored by MCF's Supervision and Control Body (OSC), headed up by the Club's lawyer Alberto Díaz and completed by external advisers Antonio Caba Tena and Jorge Manrique de Lara Jiménez. An update of the business processes and management procedures within the Entity’s internal regulations and surveillance structures will allow it to maintain its internal core safeguarded from possible crimes.
The Club's management has a strong commitment to ethics and legality, which are the foundations and structure of its management model, working actively to develop an ethical and compliance culture and establishing a zero-tolerance policy in regard to crime and unethical behaviour within the organisation.
