Integrity and Conduct

What may be reported through the Ethics Channel?

Information on infringements or failure to fulfil in an ample sense, that is, reasonable suspicion, real or potential infringements, that have taken place, or that may probably arise. Reports must always be made in good faith and with the greatest degree of detail and possible evidence.

For the purposes of illustration, and notwithstanding what is set forth in the Ethics Channel Operating Policy, the following are some of the possible subjects to be reported:

• Cases of bribery and corruption.
• Conduct against health and safety in the workplace.
• Conflicts of interest in any action related to professional development.
• Discriminatory conduct.
• Sexual and labour harassment.
• Internal fraud.
• Cases of unfair competition.
• Breaches in matters of defence of competition.
• Conduct contrary to the health and safety of our users.

Who will process the information reported?

It is important for you to know that the information reported, including personal data gathered in the context of a report, may be processed or notified to the following parties when necessary:

• Navex Global, the independent third party acting as data processor, that manages the digital reporting, or so-called alternative channels.
• Members of the CLECE Technical Compliance Unit, as well as the Compliance Committee (Compliance Body) of the company.
• Authorised representatives of the company who intervene in the investigation, if the nature or scope of the facts denounced require their participation.
• Any investigator, advisor or external advisor who has been hired to support the company in evaluating the notification, in investigating the matter, or to advise the organisation on points related to such matters.
• The police and/or other regulatory or law enforcement bodies.

All parties concerned are encouraged to submit information regarding possible infringements of our Code of Ethics, as well as to request guidance regarding the policies available below. We thank you in advance for your valuable collaboration.