Purpose
The Law 2/2023 transposes what is known as the “Whistleblowing Directive”, and has the following objectives:
➜ Providing protection to those who report on behaviors contrary to a broad scope of application (serious or very serious criminal or administrative offenses).
➜ Strengthening the culture of information, as well as enhancing the integrity of organizations, to better protect the public good.
➜ Establishing the fundamental elements of the internal information system within organizations (“Whistleblowing Channel”).
Timeframe for compliance with the obligations established in the Law
June 13th, 2023
Independent Authority for the Protection of Whistleblowers
Independent administrative authority responsible for ensuring compliance with the Law (disciplinary powers)
Policy of the internal information system regarding integrity and regulatory compliance
(approved by the Board of Directors on May 17, 2023)
Objective
To establish and develop the principles of action and commitments that govern and inspire the operation of the internal information system concerning Integrity and Regulatory Compliance.
Principles of Action and Commitments
- Promote the existence of an environment and conditions that encourage communication
- Ensure proper publicity, dissemination, and visibility of internal communication channels
- Protect against any form of retaliation
- Ensure confidentiality and the protection of personal data
- Allow for anonymous reporting
- Guarantee the rights of individuals referred to in the reports (right to presumption of innocence and to honor and defense)
- Allocate the necessary resources and ensure the proper independence and autonomy in managing the System
Procedure for managing communications received through the Ethics Channel
(approved by the Board of Directors on May 17, 2023)
Objective
Develop the systematic approach for managing communications received through the Ethics Channel.
Responsibilities
- Board of Directors (with support from the Audit Committee) -> Implementation, monitoring, and supervision of the System
- Responsible Person for the System -> Diligent management of the System
Procedure
- Receipt and registration of communications and decision on their admission
- Investigation
- Resolution, closure, and adoption of measures
- Whistleblower protection measures
- Protection measures for affected individuals
- Management and preservation of information and documentation and protection of personal data
Appointment by the Board of Directors of the Responsible Person for the System
(May 17th, 2023)
Objective
Design and deployment on the Group's website of direct access from the homepage and improvement of the visibility and accessibility to the Ethics Channel through the website and "Buenos días".