The company undertakes to investigate all reports of possible breaches or non-compliance received through the whistleblowing channel.
The company will designate a person or team to be responsible for the information system or complaints channel in charge of receiving, recording and managing the complaints received through the complaints channel.
The person in charge of the system shall carry out his or her functions independently and autonomously from the rest of the bodies of the entity or organisation, may not receive instructions of any kind in the exercise thereof, and shall have all the personal and material means necessary to carry them out.
All complaints shall be investigated impartially and confidentially with appropriate measures shall be taken depending on the results of the investigation for the protection of the whistleblower.
The company undertakes to inform the whistleblower about the status of the investigation and the measures taken, whenever possible and without compromising the confidentiality and protection of the whistleblower, and may request additional information to the facts reported through the channel. At the whistleblower’s request, a face-to-face meeting may also be held within a maximum period of seven days in order to make a communication.
Such a meeting shall be recorded in accordance with the terms laid down by law. Without prejudice to his or her rights under data protection regulations, the reporting person will be given the opportunity to verify, rectify and agree by signing the transcript of the conversation.
In addition, the company undertakes to monitor all reports received and actions taken to ensure the effectiveness of this policy and to continuously improve the process.
Communications through the reporting system may be anonymous.
Communications received will be accepted within a maximum period of 7 days and managed for a maximum period of 3 months, except in cases of particular complexity that require an extension of the period, in which case, this may be extended for a maximum of a further three months.
Any information shall be immediately forwarded to the Public Prosecutor’s Office when the facts may be indicative of a criminal offence. If the facts affect the financial interests of the European Union, it will be referred to the European Public Prosecutor’s Office.
In addition to this Internal Channel, there are other external channels set up by the competent authorities to report actions or omissions that may constitute infringements in the aforementioned areas. These channels include:
State or Autonomous Community channels:
- National Anti-Fraud Coordination Service.
- Public Prosecutor’s Office against Corruption and Organised Crime.
- National Police.
- Independent Whistleblower Protection Authority*:
*Law 2/2023 establishes the specific creation of this external information channel, and the appointment of an Independent Authority for the Protection of Whistleblowers.The aforementioned persons (“whistleblowers”) may report to this Authority, or to the corresponding regional authorities or bodies, the commission of any of the actions or omissions listed in the “communications” section, either directly, or after having made said report through this Internal Information Channel. (ACCESS INFORMATION TO THIS EXTERNAL CHANNEL NOT YET AVAILABLE)
- European Anti-Fraud Office (OLAF)