Whistleblower Channel

Internal reporting system for the communication of irregularities, in accordance with Law 2/2023 of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption.

What is the whistleblower channel?

The Whistleblower Channel of [PENDIENTE_RAZON_SOCIAL] is the internal tool that allows employees, collaborators, clients and third parties to confidentially report any conduct that may constitute an infringement of EU law, national law, or the internal rules and policies of the firm.

What can be reported?

• Infringements of EU Law in the areas of art. 2 of Directive 2019/1937 (financial services, anti-money laundering, product safety, transport, environmental protection, public health, consumer protection, privacy and personal data, etc.).
• Actions or omissions constituting serious or very serious criminal or administrative infringement, particularly in tax or economic matters.
• Non-compliance with the internal rules of [PENDIENTE_RAZON_SOCIAL] (code of ethics, anti-money laundering policy, conflicts of interest, etc.).

How to report?

The whistleblower can submit the communication in writing to the head of the internal reporting system at the address whistleblowing@[PENDIENTE_DOMINIO], or by requesting an in-person meeting at any of the firm’s offices. Anonymous communications are accepted provided they provide sufficient elements for their assessment.

Guarantees for the whistleblower

• Confidentiality of the identity of the whistleblower and of any third party mentioned in the communication.
• Prohibition of reprisals against the whistleblower for having reported in good faith.
• Data protection in accordance with the GDPR and applicable national regulations (LOPDGDD).
• Acknowledgement of receipt within a maximum of 7 calendar days and reasoned response within a maximum of 3 months.

External channels

Without prejudice to the internal channel, the whistleblower may go directly to the Independent Whistleblower Protection Authority (A.A.I.) or to the competent autonomous authorities, as well as to the institutions, bodies or agencies of the European Union.

Need to report an irregularity?

Your communication will be treated with the utmost confidentiality and in accordance with current regulations.