Source: Resolución Nº 904 de 23/09/2024 “RESOLUCION DEROGACION CE” – SEGRA 892912
Resolution nº 904, of September 23rd 2024, of the Director of the Agency for the Prevention and Fights against Fraud and Corruption of the Valencian Community, repealing the resolution number 82/2022, of February 10th, of the Director of the Agency for the Prevention and Fights against Fraud and Corruption of the Valencian Community, approving the Code of Ethics and Conduct of this agency.
Concern as newly appointed director of the Valencian Anti-Fraud Agency dismantles internal ethics safeguards, repealing its Code of Ethics and dissolving the Ethics Committee.
Eduardo Beut, the newly appointed director of the Valencian Anti-Fraud Agency – a body with a key role in the implementation of the national and EU whistleblower protection frameworks – repealed the institution’s internal Code of Ethics, disbanded the Ethics Committee and suspended its internal whistleblower reporting channel. This decision apparently occurred in the context of confrontation between the director and the Ethics Committee, following the opening of internal proceedings against him for various allegations.
Key Highlights:
- Resolution nº 904 repealed the Code of Ethics, adopted in 2020, which was a robust internal governance tool covering conflicts of interest, transparency and accountability.
- It also eliminated the Ethics Committee, an autonomous, interdisciplinary body tasked with overseeing ethical compliance and managing internal complaints.
- Lastly, it deactivated the internal reporting channel – set up in accordance with the EU Whistleblowing directive.
- The derogation was apparently carried out without a prior evaluation procedure and without consulting the Ethics Committee. Moreover, no transitional regime was established for ongoing complaints.
- In March 2025, three civil society organizations (Fundación Hay Derecho, Fundación por la Justicia y Acción Cívica contra la Corrupción) filed an appeal against the repeal of the Code of Ethics and the dissolution of the Ethics Committee, with the support of several of its former members. The appeal was admitted for processing and is now pending resolution.
Expert Commentary: –
Joan Llinares (the former director of the AVAF) said: “The AVAF Ethics Committee, like any public ethics watchdog, played a crucial role in promoting a culture of integrity and preventing unethical behavior within the institution. Its work contributed to strengthening public confidence in the institutions and ensuring that they fulfill their mission of serving the public interest”; “…ethical codes accompanied by effective governance systems are a good antidote and a means of analyzing behaviors and detecting distorting subjects at the service of corrupt schemes of their particular interests eager to take control or neutralize anti-corruption bodies” (eldiario.es I Quién teme al código ético de la Agencia Valenciana Antifraude)
Background & Context:
- The AVAF´s Code of Ethics was approved in 2022 through a participatory process that included unions and Agency staff. It established principles of good governance and rules of conduct applicable to all staff, including the obligation to submit declarations of assets and activities to avoid conflicts of interest. It also regulated the creation of an independent Ethics Committee, composed mainly of external experts, responsible for overseeing compliance and managing an internal whistleblower channel.
- The decision to repeal the Code and dismantle the Ethics Committee followed the opening of internal files against the director himself for various allegations. Around the same period, several senior officials were dismissed from their positions.
- The AVAF was founded in 2016 as one of Spain´s most advanced regional anti-corruption bodies, with broad investigative powers and an internal model aligned with international best practices. Its internal ethical governance framework was one of its key features. The abrupt dismantling of this structures left AVAF without any formal mechanism for ethical oversight, whistleblower protection, or internal complaints, directly contradicting the agency´s mission as well as Law 2/2023 and the EU Whistleblower directive.
Relevant Link to Further Reading: