Reporting Channel
All the necessary means to report any action or omission that may constitute breaches of European Union law, serious or very serious criminal or administrative offences or violations including well-founded suspicions of relevant violations of the company's internal regulations and of the basic principles conveyed by the Code of Ethics, are made available to all company employees, public employees, self-employed persons, shareholders, participants, directors, managers, employees under the supervision and management of contractors, subcontractors and suppliers, former employees, former civil servants, volunteers, interns, trainees and participants in selection processes or pre-contractual negotiation, provided that they have become aware of the information concerning the violation in a work or professional context.
Any known unlawful conduct, such as alleged harassment at work, actions relating to fraud or any action taken by a third party that could entail any kind of criminal liability for the company, should be reported through this channel.
This is a whistleblowing channel that is partially outsourced. When submitting communications through this whistleblowing Channel, the external provider will request the identification of the whistleblower. However, the whistleblower may request anonymity in which case no identification will be required except in the case of complaints relating to violations or well-founded suspicions of violations relevant to the entities' internal regulations and of the basic principles conveyed by the Code of Ethics, provided these do not also involve a breach of European Union law, serious or very serious administrative breaches or criminal offences.
If the complainant has chosen to identify himself/herself, the Channel provider will forward the complaint information to the company identified in the complaint, removing the complainant's identification data. Therefore, the complainant's data will remain at the headquarters of the external entity managing the channel, with no possibility of access by the reported company, except in the following circumstances: when a national regulation provides for disclosure, false reports or when requested in the framework of legal proceedings. In all cases, the confidentiality of all information is guaranteed.
Furthermore, the whistleblowing channel management model incorporates a number of whistleblower and retaliation protection measures that go beyond allowing anonymous whistleblowing as outlined above.
In compliance with Law 2/2023, of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption, the data requested from the whistleblower during the reporting process is collected solely for the purpose of obtaining the appropriate information to manage and process the report and not for identification purposes.
In order for the investigation of the communications to proceed, the informant must provide sufficient information and the complaint must be duly substantiated and reasoned with rational evidence that an infringement has taken place. If this is not the case, the case will be closed on the grounds that there is insufficient evidence for investigation.
Finally, before submitting a complaint, it is important that you carefully read the channel's rules of use, which will be presented to you before you provide the information relating to the complaint.