1.- Introduction / Regulatory framework

The Whistleblower Channel is a fundamental tool for promoting transparency, ethics and responsibility within our organisation. The purpose of these regulations is to establish the guidelines and procedures for the proper use of the Whistleblower Channel, ensuring confidentiality and fair treatment of all complaints received.

This regulation aims to comply with the Organic Law 5/2010 and 1/2015 amending the Criminal Code, as well as the EU Directive 2019/1937.

The law governing the whistleblowing channel in Spain is Law 2/2023, which regulates the protection of persons who report regulatory infringements and the fight against corruption.

2.- Scope of application

This regulation applies to all employees, contractors, suppliers and any other person who is part of the organisation, as well as to third parties who have business relations with our company.

3. Confidentiality

All reports received through the Whistleblowing Channel will be treated confidentially. Only persons directly involved in the investigation and resolution of the complaint will have access to the information provided.

The person responsible for handling the complaint will be Mr. Alejo Truyols.

4.- Rights and duties of the complainant and the respondent

The right to be informed about the existence of the channel.

Right to confidentiality

The right to anonymity of the whistleblower.

The right to the protection of personal data

Right to non-retaliation

Right to be informed of the resolution or closure of the complaint.

Duties of the complainant:

Act in good faith

To provide data and documents related to the facts reported.

Duty of confidentiality

Rights of the complainant

The rights of the reported person should also be envisaged and specified:

To be notified as soon as possible of the fact that he/she is under investigation, as a consequence of a complaint lodged against him/her. This communication should contain information on:

Body in charge of management

Reported facts

Rights to which he/she is entitled

Procedure for dealing with the complaint

Right of access to the data recorded, with the exception of the identity of the complainant and of other persons affected by the file. Right to rectify personal data which may be incorrect or incomplete.

Right to be informed of the resolution or closure of the complaint.

5. Requirements of the complaint

Identification of the complainant

Irregularity or infringement complained of

Provision of documents or evidence (if possible)

Identification of those responsible for the irregularity or infringement, if known


Anonymous submission of reports will be permitted through the established Reporting Channel. However, whistleblowers are encouraged to provide contact information so that additional information can be requested or to enable communication if necessary.

6. Types of complaints

The Whistleblower Channel will accept reports relating to conduct that is inappropriate, illegal or contrary to the policies and values of our organisation. This includes, but is not limited to, harassment, discrimination, fraud, theft, conflicts of interest, corruption, and information security breaches, among others.

7. Complaint process

Complaints should be sent via the form at the following link

It is also available through the company’s website

An email address has also been set up for the management of complaints, as well as for receiving all kinds of documentation.

A clear and detailed description of the facts reported will be required, including names, dates, places and any other relevant information.

8. Investigation and follow-up

All complaints received will be investigated in a timely and fair manner. The investigation team, under the responsibility of Mr Alejo Truyols, will assess the seriousness of the complaint and take appropriate action for its resolution. In addition, the complainant will be informed of the progress of the investigation and the actions taken, to the extent possible without compromising the confidentiality or privacy of the parties involved.

9. Protection against retaliation

Any form of retaliation or discrimination against good faith whistleblowers is prohibited. Those who make good faith reports will not be subject to retaliation and will be afforded protection in accordance with the law and the organisation’s policies.

10. Proper use of the Whistleblowing Channel

The Whistleblower Channel should not be used to make false, malicious or defamatory reports. Any misuse of the channel may result in disciplinary action, including termination of employment or termination of the business relationship.

11. Record keeping and documentation

The organisation shall maintain a record of all complaints received and actions taken in response to them. Relevant documentation of each complaint, including evidence and results of the investigation, shall be maintained in accordance with applicable legal provisions.

12. Collaboration with competent authorities

In the event that the allegations involve possible legal violations, full cooperation with the competent authorities shall be ensured.