1. Internal Information System and Whistleblower Protection Policy
The Communication Channel, established in accordance with Law 2/2023 of 20 February, on the protection of persons who report regulatory breaches and the fight against corruption, as well as Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law, aims to strengthen the culture of reporting, reinforce the integrity framework of organisations, and promote the use of reporting and communication as a mechanism for preventing and detecting threats to the public interest.
In this regard, the organisation considers it a priority to obtain relevant information that may affect its Compliance System, whether in the form of reports concerning non-compliance with the system or enquiries regarding the appropriate course of action in accordance with it.
The organisation’s Compliance System is based on the provisions of Article 31 bis of the Spanish Criminal Code, together with its related and subsequent regulations, introduced through Organic Law 5/2010 of 22 June and Organic Law 1/2015 of 30 March. These reforms established the obligation for companies to implement an organisational, management and control model designed to prevent criminal offences. Consequently, breaches of the Compliance System include those relating to the prevention, detection and rejection of conduct that may give rise to the criminal liability of legal entities, including, but not limited to, matters concerning corruption, trade secrets, privacy, fraud against individuals or within the public sector, smuggling, public health, land-use planning, and similar offences.
Furthermore, the organisation rejects any unlawful behaviour and, in particular, any conduct falling within the scope of the aforementioned regulations. The organisation firmly believes that obtaining any information that may help prevent, address or report legal breaches to the competent authorities is essential to ensuring compliance with applicable legislation.
To obtain such information and promote good governance and lawful conduct within the organisation, the Communication Channel has been established.
The Communication Channel has been designed to enable users to submit information relevant to the purposes described above.
Accordingly, the channel guarantees a secure, independent and confidential reporting system. Only those individuals directly involved in the handling of reports, in accordance with the applicable legal provisions, will have access to the information submitted, including any personal identification data. Access by unauthorised personnel is prevented throughout both the reporting process and the subsequent handling of the information.
The organisation also seeks, through the implementation of this channel, to consolidate reporting mechanisms wherever possible, enabling communications to be submitted through both written and verbal means.
The Communication Channel incorporates appropriate safeguards to ensure that users who submit information in accordance with the law are protected against retaliation. This protection is provided while maintaining a firm rejection of knowingly false reports and fully respecting the presumption of innocence of all individuals involved in the process.
2. Management Procedure
The organisation has allocated the necessary resources for the implementation of its Communication Channel and provides those legally entitled to use it with an intuitive online reporting platform for the submission of written reports.
This platform guarantees the confidential use of the Communication Channel and complies with all procedural requirements established by Law 2/2023 of 20 February on the protection of persons who report regulatory breaches and the fight against corruption.
Users of the Communication Channel are reminded that they also have the right to submit reports directly to the competent public authorities whenever appropriate.