Overcoming compliance fatigue: Reinforcing the commitment to ethical growth 13th Global Fraud Survey - findings for Spain

1. Overcoming compliance fatigue
Reinforcing the commitment to ethical
growth
13th Global Fraud Survey - findings for Spain
June 2014

2. Survey approach and participant profile
► Between November 2013 and February 2014, our researchers conducted 2,719 interviews with
various executives in 59 countries and territories.
► Interviewees were selected from a sample of the largest companies in each country. Employees
interviewed included industry leaders – chief executive officers (CEOs), chief financial officers
(CFOs), chief compliance officers (CCOs), general counsel and heads of internal audit. Interviews
were conducted on an anonymous basis in the local language by telephone or in person. Details of
the full survey are shown below:
► 50 interviews were conducted in Spain
► Results are compared with findings for Western Europe*, developed markets*, emerging markets*
and all respondents
► Please note that, due to rounding or the omission of percentages to allow better comparison, some
figures may not sum to 100%
Job title % of respondents
CFO 28%
Other finance 23%
Head of internal audit 9%
Other audit/risk 9%
General counsel 7%
CEO 6%
Head of marketing/sales 4%
CCO 3%
Other 11%
Revenue % of respondents
More than US$5b 6%
US$1b-US$5b 18%
US$500m-US$0.99b 13%
US$100m-US$499m 30%
US$99m or less 31%
Above US$1b 24%
Below US$1b 73%
Page 1 13th Global Fraud Survey
* Details of countries categorized as Western Europe, developed markets and emerging markets can be found in the appendix.
June 2014

3. Western
Europe
Developed
markets
Emerging
markets
All
respondents
28 30 28 29
10 11 17 14
8 7 16 13
3 4 8 6
35 38 45 42
Figures 1,5&10: Unethical behavior persists
Q. Which, if any, of the following do you feel can be justified if they help a business survive an economic downturn?
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
% don't know and none of the above have been omitted to allow better comparison between responses given
18
12
10
8
36
Offering entertainment to
win/retain business
Personal gifts to
win/retain business
Cash payments to
win/retain business
Misstating company’s
financial performance
At least one of these can
be justified
Page 2 June 2014 13th Global Fraud Survey
% Agree
% Agree
Spain

4. Challenges in addressing new risks -
cybercrime

5. 26
35
34
28
31
14
13
14
20
17
42
36
33
28
30
16
14
17
20
19
How much of a risk would you say cybercrime
poses to organizations like yours?
Figure 2: Cybercrime - a real and growing risk
Q. How much of a risk would you say cybercrime poses to organizations like yours?
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
% don't know and refused have been omitted to allow better comparison between responses given
% Very/fairly
high risk
58
50
50
48
49
Page 4 June 2014 13th Global Fraud Survey
Spain
Western Europe
Developed
markets
Emerging
markets
All respondents
% Very low risk % Fairly low risk % Fairly high risk % Very high risk

6. 4
16
40
38
58
Foreign nation states
Organized crime
Employees or
contractors
Competitors
Hackers or hacktivists
Figure 3: Threats from within and without
Q. Thinking of the following sources of cybercrime, which one or two of the following, if any, concerns you the most?
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
% don't know and none of the above have been omitted to allow better comparison between responses given
Western
Europe
Developed
markets
Emerging
markets
All
respondents
7 8 5 6
27 25 25 25
33 34 33 33
33 31 35 34
47 50 47 48
% Agree
Page 5 June 2014 13th Global Fraud Survey
% Agree
Spain

7. Fraud - long-standing risks present challenges
too

8. Page 7 13th Global Fraud Survey
Figure 4: Fraud – a challenge for all economies
Q. Has your organization experienced a significant fraud in the last two years?
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
6
12
12
11
12
% Yes
Spain
Western Europe
Developed
markets
Emerging
markets
All respondents
Has your organization experienced a significant fraud in the last two years?
June 2014

9. Western
Europe
Developed
markets
Emerging
markets
All
respondents
28 28 37 33
12 11 17 14
9 9 13 11
7 7 10 8
56 57 45 50
42 41 52 47
Figure 6: Bending the rules or breaking the law?
Q. Given the pressure that often exists to meet financial targets, which, if any, of the following activities do you feel can be justified to meet those
targets?
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
% don't know and refused have been omitted to allow better comparison between responses given
12
12
4
4
72
28
More flexible product
return policies
Change assumptions
determining
valuations/reserves
Extend monthly
reporting period
Backdate a contract
None of these
At least one of these
Page 8 June 2014 13th Global Fraud Survey
% Agree
% Agree
Spain

10. Bribery and corruption - are compliance efforts
running out of steam?

11. Figure 8: Bribery and corruption unchanged
Bribery/corrupt practices happen widely in business in this country
Q. For each of the following, can you tell me whether you think it applies, or does not apply, to your country or industry or whether you don’t know?
Bribery/corrupt practices happen widely in business in this country
Base: Spain 2014 (50), 2012 (50); Western Europe 2014 (636), 2012 (652); developed markets 2014 (869), 2012 (877); emerging markets 2014 (1159),
2012 (931); all respondents 2014 (2028), 2012 (1808)
% don't know has been omitted to allow better comparison between responses given
Note that the results shown are adjusted to reflect the profile of respondents from the current survey compared to our previous survey (like for like).
% Does not apply % Applies
28
34
20
22
19
19
54
56
39
38
56
60
74
71
75
72
34
33
52
52
Spain 2014
Spain 2012
Western Europe 2014
Western Europe 2012
Developed markets 2014
Developed markets 2012
Emerging markets 2014
Emerging markets 2012
All respondents 2014
All respondents 2012
Page 10 June 2014 13th Global Fraud Survey

12. Figure 9: Cheques and balances - asked to pay
a bribe in a business situation
Q. Have you ever been asked to do any of the following? Pay a bribe in a business situation
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
% don't know and refused have been omitted to allow better comparison between responses given
Have you ever been asked to pay a bribe in a business situation?
Page 11 June 2014 13th Global Fraud Survey
0
3
3
10
7
100
96
96
89
92
Spain
Western Europe
Developed
markets
Emerging
markets
All respondents
% No % Yes

13. Page 12
Figure 9: Cheques and balances - asked to
make a charitable contribution
Q. Have you ever been asked to do any of the following? Make a charitable contribution by a customer or client
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
% don't know and refused have been omitted to allow better comparison between responses given
Have you ever been asked to make a charitable contribution by a customer or client?
4
14
15
23
20
96
84
83
75
78
Spain
Western Europe
Developed
markets
Emerging
markets
All respondents
% No % Yes
June 2014 13th Global Fraud Survey

14. Figure 9: Cheques and balances - asked to pre-or
post-date a contract
Q. Have you ever been asked pre- or post-date a contract?
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
% don't know and refused have been omitted to allow better comparison between responses given
Have you ever been asked to pre- or post-date a contract?
Page 13 June 2014 13th Global Fraud Survey
16
20
17
17
17
84
79
81
81
81
Spain
Western Europe
Developed
markets
Emerging
markets
All respondents
% No % Yes

15. Figure 11: Has compliance stalled?
Anti-bribery/anti-corruption policy
54
74
87
84
87
86
78
76
82
81
36
22
11
14
11
12
18
21
15
17
We have an anti-bribery/anti-corruption policy and code of conduct
Spain 2014
Spain 2012
Western Europe 2014
Western Europe 2012
Developed markets 2014
Developed markets 2012
Emerging markets 2014
Emerging markets 2012
All respondents 2014
All respondents 2012
Q. For each of the following, please tell me whether it applies, or does not apply, to your organization, or whether you don’t know?
Base: Spain 2014 (50), 2012 (50); Western Europe 2014 (636), 2012 (652); developed markets 2014 (869), 2012 (877); emerging markets 2014 (1159),
2012 (931); all respondents 2014 (2028), 2012 (1808)
% don't know has been omitted to allow better comparison between responses given
Note that the results shown are adjusted to reflect the profile of respondents from the current survey compared to our previous survey (like for like). Whereas, the
country breakdown on the following slide reflects the unadjusted results of all respondents.
% Does not apply % Applies
Page 14 June 2014 13th Global Fraud Survey

16. Figure 11: Has compliance stalled?
Senior management commitment
Senior management has strongly communicated its commitment to our
anti-bribery/anti-corruption policies
70
86
84
84
85
86
82
82
83
84
22
10
13
14
13
12
13
15
13
14
Spain 2014
Spain 2012
Western Europe 2014
Western Europe 2012
Developed markets 2014
Developed markets 2012
Emerging markets 2014
Emerging markets 2012
All respondents 2014
All respondents 2012
% Does not apply % Applies
Page 15 June 2014 13th Global Fraud Survey
Q. For each of the following, please tell me whether it applies, or does not apply, to your organization, or whether you don’t know?
Base: Spain 2014 (50), 2012 (50); Western Europe 2014 (636), 2012 (652); developed markets 2014 (869), 2012 (877); emerging markets 2014 (1159),
2012 (931); all respondents 2014 (2028), 2012 (1808)
% don't know has been omitted to allow better comparison between responses given
Note that the results shown are adjusted to reflect the profile of respondents from the current survey compared to our previous survey (like for like). Whereas, the
country breakdown on the following slide reflects the unadjusted results of all respondents.

17. Figure 11: Has compliance stalled?
Clear penalties
There are clear penalties for breaking our anti-bribery/anti-corruption policies
56
68
73
72
76
75
71
68
73
71
38
28
23
23
21
20
21
27
21
24
Spain 2014
Spain 2012
Western Europe 2014
Western Europe 2012
Developed markets 2014
Developed markets 2012
Emerging markets 2014
Emerging markets 2012
All respondents 2014
All respondents 2012
% Does not apply % Applies
Page 16 June 2014 13th Global Fraud Survey
Q. For each of the following, please tell me whether it applies, or does not apply, to your organization, or whether you don’t know?
Base: Spain 2014 (50), 2012 (50); Western Europe 2014 (636), 2012 (652); developed markets 2014 (869), 2012 (877); emerging markets 2014 (1159),
2012 (931); all respondents 2014 (2028), 2012 (1808)
% don't know has been omitted to allow better comparison between responses given
Note that the results shown are adjusted to reflect the profile of respondents from the current survey compared to our previous survey (like for like). Whereas, the
country breakdown on the following slide reflects the unadjusted results of all respondents.

18. Page 17
Figure 11: Has compliance stalled?
People penalized for breaching policies
People have been penalized for breaching our anti-bribery/anti-corruption policies
% Does not apply % Applies
June 2014
20
50
31
39
30
39
40
49
35
44
68
38
55
50
54
49
46
41
50
45
Spain 2014
Spain 2012
Western Europe 2014
Western Europe 2012
Developed markets 2014
Developed markets 2012
Emerging markets 2014
Emerging markets 2012
All respondents 2014
All respondents 2012
13th Global Fraud Survey
Q. For each of the following, please tell me whether it applies, or does not apply, to your organization, or whether you don’t know?
Base: Spain 2014 (50), 2012 (50); Western Europe 2014 (636), 2012 (652); developed markets 2014 (869), 2012 (877); emerging markets 2014 (1159),
2012 (931); all respondents 2014 (2028), 2012 (1808)
% don't know has been omitted to allow better comparison between responses given
Note that the results shown are adjusted to reflect the profile of respondents from the current survey compared to our previous survey (like for like). Whereas, the
country breakdown on the following slide reflects the unadjusted results of all respondents.

19. Figure 12: Demonstrating commitment, or not?
Q. Have you attended anti-bribery/anti-corruption training?
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
% don't know has been omitted to allow better comparison between responses given
Have you attended anti-bribery/anti-corruption training?
38
59
58
40
47
62
41
42
59
52
Spain
Western Europe
Developed
markets
Emerging
markets
All respondents
%No %Yes
Page 18 June 2014 13th Global Fraud Survey

20. Figure 13: Risk assessments - reflecting the
breadth of experience?
Q. In the past two years, which, if any, of the following has your company asked you to participate in? An anti-bribery/anti-corruption risk assessment
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
% don't know has been omitted to allow better comparison between responses given
In the past two years, has your company asked you to participate in
an anti-bribery/anti-corruption risk assessment
32
42
41
31
35
68
57
57
65
62
Spain
Western Europe
Developed
markets
Emerging
markets
All respondents
Page 19 June 2014 13th Global Fraud Survey
%No %Yes

21. Risks old and new require a dynamic response

22. Figure 15: Perceptions of bribery/corrupt
practices in this country
Bribery/corrupt practices happen widely in business in this country
Q. For each of the following, can you tell me whether you think it applies, or does not apply, to your country or industry or whether you don’t know?
Bribery/corrupt practices happen widely in business in this country
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
% don't know and refused have been omitted to allow better comparison between responses given
% Does not apply % Applies
28
18
17
53
38
56
75
76
33
51
Spain
Western Europe
Developed markets
Emerging markets
All respondents
Page 21 June 2014 13th Global Fraud Survey

23. Spain
Western Europe
Developed markets
Emerging markets
All respondents
Page 22
Figure 15: Perceptions of bribery to win
contracts in our sector
Q. For each of the following, can you tell me whether you think it applies, or does not apply, to your country or industry, or whether you don’t know?
In our sector, it is common practice to use bribery to win contracts
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
% don't know and refused have been omitted to allow better comparison between responses given
In our sector, it is common practice to use bribery to win contracts
June 2014 13th Global Fraud Survey
6
5
5
18
12
92
92
92
74
82
% Does not apply % Applies

24. 38
59 58
40
47
0 3 3 10 7
Spain Western Europe Developed markets Emerging markets All respondents
Figure 17: Bribery training vs. incidence of
bribery
Q. Have you attended anti-bribery/anti-corruption training?
Q. Have you ever been asked to do any of the following? Pay a bribe in a business situation
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
% Have attended anti-bribery/anti-corruption training
% Have been asked to pay a bribe in a business situation
Page 23 June 2014 13th Global Fraud Survey

25. 32
41
40
36
38
66
57
58
61
59
Figure 18: Focusing effort efficiently
Q. In the past two years, which, if any, of the following has your company asked you to participate in? An interview by an internal auditor in relation to
anti-bribery/anti-corruption compliance
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
% don't know and refused have been omitted to allow better comparison between responses given
In the past two years, has your company asked you to participate in an interview by an
internal auditor in relation to anti-bribery/anti-corruption compliance?
Spain
Western Europe
Developed
markets
Emerging
markets
All respondents
% No % Yes
Page 24 June 2014 13th Global Fraud Survey

26. 20
53
58
46
51
72
44
39
49
45
Page 25
Figure 20: Whistleblowing - issues not being
heard
Q. Which of the following systems or processes does your organization have for monitoring compliance with anti-bribery and anti-corruption laws?
Whistleblowing hotlines
Base: Spain 2014 (50); Western Europe 2014 (852); developed markets 2014 (1103); emerging markets 2014 (1616); all respondents 2014 (2719)
% don't know has been omitted to allow better comparison between responses given
Whistleblowing hotlines
Spain
Western Europe
Developed
markets
Emerging
markets
All respondents
June 2014 13th Global Fraud Survey
% No % Yes

27. Appendix

28. Page 27
Number of Spain interviews: role, sector,
revenue
June 2014 13th Global Fraud Survey
Sector
Automotive 1
Consumer products, retail, wholesale 16
Financial services 1
Government and public sector -
Life sciences 2
Manufacturing and chemicals 7
Oil, gas, and mining 1
Power and utilities 3
Professional firms and services 8
Real estate 3
Technology, communications, and
entertainment
3
Other transportation 2
Other sectors 3
Job function
Finance 27
Internal Audit and Risk 11
Legal 2
Compliance 1
Other executives 9
Base: All respondents in Spain (50)
Note: Revenue figures exclude respondents who said don’t know or refused
Revenue
More than $1 billion 10
$500 million to $1 billion -
Less than $500 million 40

29. Profile of research sample
► Western Europe results are based on 852 interviews across 17 countries – Austria, Belgium,
Denmark, Finland, France, Germany, Greece, Ireland, Italy, Luxembourg, Netherlands, Norway,
Portugal, Spain, Sweden, Switzerland, and the UK.
► Developed market results are based on 1,103 interviews across 23 countries – Australia, Austria,
Belgium, Canada, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Japan, Luxembourg,
Netherlands, New Zealand, Norway, Portugal, Singapore, Spain, Sweden, Switzerland, UK and US.
► Emerging market results are based on 1,616 interviews across 36 countries and territories –
Argentina, Brazil, Chile, China, Colombia, Croatia, Czech Republic, Egypt, Estonia, Hong Kong
SAR, Hungary, India, Indonesia, Israel, Jordan, Kenya, Latvia, Lithuania, Malaysia, Mexico,
Namibia, Nigeria, Philippines, Poland, Romania, Russia, Saudi Arabia, Serbia, Slovakia, Slovenia,
South Africa, South Korea, Turkey, UAE, Ukraine and Vietnam.
► New Zealand’s survey results are included in the Oceania regional figures but due to the low base
size no country level figures are shown.
► Baltic States include: Estonia, Latvia and Lithuania
► Middle East includes: Jordan and UAE
Page 28 June 2014 13th Global Fraud Survey

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