Third-party lifecycle management for Spain operations
Last updated: August 19, 2026
Verdana is a third-party lifecycle management platform that helps companies operating in Spain manage the compliance and documentation obligations tied to suppliers, contractors, and business partners, in one system built around Spanish requirements and audit review.
Article 31 bis of the Spanish Criminal Code makes a company criminally liable for offenses committed on its behalf by employees or representatives, and lets an organization-and-management model — a compliance program with a defined risk map, decision-making protocols, a reporting duty, a disciplinary system, and periodic review — mitigate or exempt that liability. Verdana runs the third-party side of that model: risk-based supplier and contractor classification, documented due diligence at onboarding, and continuous monitoring with a dated audit trail of every check. Separately, Real Decreto 171/2004 (Coordinación de Actividades Empresariales) requires a company whose contractors work at its facilities to coordinate safety information and instructions with them; Verdana tracks each contractor's safety induction, training records, and site-access authorization by worker, not just by company.
Article 42 of the Estatuto de los Trabajadores makes a company jointly and severally liable for a subcontractor's wage obligations for the year following the engagement, and for its Social Security obligations during the contract and the three years after — liability tied directly to whether the subcontractor's registration, insurance, and Social Security standing were current at the time. Verdana keeps that documentation current with expiration alerts before a gap opens, instead of a file that goes stale the day it is collected.
Spain sits alongside the rest of Europe, Latin America, and the United States in the same platform: document requirements are configured per jurisdiction, and headquarters gets one consolidated view of every supplier and contractor regardless of where they operate.
Frequently asked questions
What does Article 31 bis of the Criminal Code require regarding third parties?
It makes a company criminally liable for crimes committed on its behalf, and lets a documented compliance program — risk mapping, protocols, a reporting duty, and periodic review — reduce or exempt that liability. The program has to reach how the company screens and monitors the suppliers and contractors acting for it, not only its own staff.
What is Coordinación de Actividades Empresariales (CAE) and does it apply to us?
It is the legal regime, under Real Decreto 171/2004, requiring companies whose contractors work at their facilities to coordinate safety information and instructions with those contractors. If contractors work on your site, it applies, and the obligation runs to each worker sent, not just to the contracting company.
Are we liable for a contractor's unpaid wages or Social Security debt in Spain?
Article 42 of the Estatuto de los Trabajadores can make the contracting company jointly and severally liable — for wages during the year after the engagement, and for Social Security obligations during the contract plus the following three years — when the subcontracted work forms part of the company's own activity.