The Ethical Channel is made available to all people linked to the Organization in order to prevent or, where appropriate, detect any incident or irregularity that could occur within the Organization and that could be contrary to internal regulations and / or applicable legislation, as well as any of the principles and values ​​established in our Business Ethics Policy.

In particular, you can notify us of any irregularity that may be related to:

• Breach of internal regulations implemented in the Organization.
• Actions or omissions constituting criminal offences.
• Serious or very serious administrative actions or omissions.
• Violations of labor law in matters of safety and health at work.
• Harassment or employment discrimination.

Remember that itThe Complaints Channel is not:

• To provide suggestions, proposals or other types of considerations.
• To generate unfounded or false situations of conflict, since evidence of the behaviors or facts that are reported will be requested.

For other questions or queries, you can contact the authorized customer or employee service channels.

whistleblower protection

Any person who reports an incident, in good faith, through the Ethical Channel will have the due guarantee of protection, as established in Directive (EU) 2019/1937 of the European Parliament and of the Council, of October 23, 2019, regarding the protection of persons who report violations of Union Law and, in particular, as established in Law 2/2023, of February 20, regulating the protection of persons who report violations of regulations and of fighting corruption.

Confidentiality and anonymity

The Organization's Ethical Channel, in all its formats, allows communications to be carried out anonymously. In the case of submitting a communication providing your identification, function or relationship and contact details, the personnel responsible for the processing may contact said person to carry out a follow-up if necessary.

The Organization also guarantees that the entire process will be carried out confidentially, preserving both the identity of the participants and the information related and provided in their communications, except for cases in which the applicable legislation for that purpose provides that said Information must be made available to the competent judicial, administrative or police authorities.

Good faith

Communications made through the Ethical Channel will be carried out honestly, with conviction as to the truth or accuracy of its purpose. The communications will be considered true, complete and accurate, even if, later, it is verified that their content was equivocal.

The formulation of complaints in bad faith and proven fraud, could constitute crimes of slander and libel. Therefore, if it is demonstrated that the informant has acted in bad faith in his communication, with the purpose of undermining the reputation of the company or of any of its professionals, the corresponding disciplinary sanction measures will be adopted in this regard, in accordance with the labor legislation in force at all times and the applicable collective agreement.

Management of conflicts of interest

The management process of the communications received through the Ethical Channel is carried out by an independent, impartial and objective team.

Before the start of the instructor function, it is reviewed whether there is a conflict of interest with any of the members that are part of the body responsible for investigating the communication. In the event of a conflict, the conflicting members will be separated and different members will be appointed who can carry out the instruction, thus safeguarding their independence.

Retaliation Prohibited 

The Organization expressly prohibits acts constituting retaliation, including threats and attempts to retaliate against persons who submit a communication in accordance with the provisions of this Policy. These facts will be considered a very serious labor infraction.

The prohibition of retaliation covers any act or omission, direct or indirect, that could harm a person due to their communication, in good faith, of possible violations.

Presumption of innocence

During the processing of the file, the people affected by the communication will have the right to the presumption of innocence and the right to defense throughout the process.

Responsible use of the Ethical Channel

It is the informant's obligation to make responsible use of the Ethical Channel, so that in no case will the Channel be used to achieve objectives other than those established therein.

The Ethical Channel implemented in the Organization allows written, verbal, and even face-to-face communications, and is operational 24 hours a day, 365 days a year.

The Ethical Channel is managed by an entity external to the Organization, PRODAT, thus guaranteeing a higher level of objectivity and independence. External management offers informants a true guarantee of confidentiality and that the information will be studied by a team of people specialized in compliance external to the organization.

You can make a communication through the following means:

online communication

For communications submitted online, you must follow the following steps:

1. Accesses online form of the Ethical Channel.
2. If you wish to make an anonymous communication, check the box enabled for this purpose and you will not have to fill in the informant's personal data.
3. Correctly fill in the required data in the form. The fields that contain a * are mandatory and, therefore, without completing them, the communication cannot be sent.
4. It is necessary to identify the type of communication that you want to send. Important: If the communication is not among the drop-down options, the way to process it is likely to be different from the Channel.
5. The communication form has a section for uploading files in any format.
6. Once the communication has been sent through the system, a confirmation message will automatically appear along with a communication tracking code – whether or not anonymous -.
7. It is important that you keep this code to be able to track your communication. You will be informed at all times of the communication status and in permanent contact with the Channel Manager through a private chat.
8. At the bottom of the Channel form itself, you can review your communication by entering the tracking code. You can access the DATA section, where there is a copy of the communication sent, and the MESSAGES section to send/receive messages from the Channel manager.

Telephone communication

You can make your communication by calling 91 901 63 29

Written or face-to-face communication

You can direct your communication to the postal address:

• PRODAT – C/ Aguarón, 23, 2º ED, 28023 Madrid

To do this, download the form that you will find below.

Head of the Ethical Channel

The Ethical Channel has the active involvement of the Organization's Administrative Body and Senior Management.

For this reason, a collegiate body has been designated as Responsible for the Ethical Channel or System on May 9, 2023, made up of 5 people from Senior Management:

• Pablo Rivera Moreno. Commercial and Operations Director.
• Alfredo Gonzalez Armengod. Director of Administration, Finance and Control.
• Miguel Angel Nicolao Echevarne. Director of Corporate Systems and Infrastructures.
• Francisco Martinez Rodriguez. HR director.
• Mrs. Lucía Garrido Martínez. Director of Marketing, Communication and Quality.

The person in charge of the Ethical Channel is responsible for instructor role of the files originated as a result of the communications received, in particular from:

• File or admission for processing of the communication received, according to preliminary evaluation.
• If applicable, opening of the file and initiation of the investigation procedure.
• Preparation of a report of conclusions and proposed resolution.
• Preparation of a follow-up report on the proposed measures and the safeguarding of the principle of non-discrimination.
• Supervision of possible retaliation.

The System Manager carries out his functions independently and autonomously from the rest of the Organization's bodies and will not receive instructions of any kind in the exercise of his functions. However, in each of these functions, he may count on the advice of the external Channel Manager as an expert entity in Compliance.

External Channel Manager

To ensure the objectivity, independence, transparency and impartiality of the process, the management of communications through the Channel has been entrusted to a third party independent of the Organization, made up of a team of expert professionals in compliance.

The functions of the independent external Manager with respect to the Ethical Channel will be the following:

• Reception and registration of communications.
• Acknowledge receipt to the informant within a maximum period of seven days.
• Informing the Delegate of the internal management of the Channel of the communications received.
• Preparation of a preliminary report and referral to the Delegate with recommendations.
• Communication with informants and with the Organization.
• Where appropriate, accompaniment and advice in the instructional phase to the person in charge of the System.

Delegate of the internal management of the Canal

The person in charge of the System has delegated to one of its members, a director of the Organization as required by the regulations, the powers of operational internal management of the Chanel.

It will have all the personal and material means necessary to be able to fulfill the functions assigned for this purpose, which are:

• Control of the Ethical Channel.
• Dialogue with the external Channel Manager.
• Reception of the preliminary report of the communications received with recommendations, sent by the external Manager.
• Review of the possible conflict of interest with any of the members that are part of the bodies responsible for the Canal, before starting the instructional phase.
• Safeguard all the documentation related to the communications presented through the Channel tool.
• Keeping of the Book-registration of the files.

Administration organ

The Administrative Body of the Organization is responsible for decision-making function of the files originated as a consequence of the valid communications that have been the object of an investigation process by means of the following procedure:

• Reception and study of the Report of conclusions and proposed resolution.
• Issuance of final resolution.

PANEL SISTEMAS INFORMÁTICOS SL (hereinafter PANEL, or the Data Controller), with registered office at Calle Josefa Valcárcel, number 9, 28027 (Madrid) and CIF number B-83766485, is responsible for the treatment of the data provided by users (“ Users ”) through the Web, Social Networks, Email, or based on the commercial and / or employment relationship with PANEL.

You can contact PANEL through postal mail at the address indicated above, by email to the address dpo@panel.es, or by phone by calling 91 405 78 88.

• Responsible for treatment: Panel Sistemas Informáticos, SL
• Purpose: manage your communication, adopt the corresponding corrective measures and, if necessary, inform you about the result of the procedure.
• Legitimation: legal obligation (Art. 6.1.c GDPR).
• Conservation: The data will be kept for the period strictly necessary to clarify the facts communicated. In any case, after six (6) months, the data provided will be destroyed unless they are investigated in a different legal environment.
• Transfer of data: No data communications to third parties are foreseen, except by legal obligation. Likewise, it is reported that the data will be processed in a lawful, loyal, transparent, adequate, pertinent, limited, exact and updated manner.
• Exercise of rights: You may exercise the rights of access, rectification, limitation of treatment, deletion, portability and opposition to the treatment of your personal data, directing your request to the postal address Panel in Calle Josefa Valcárcel, nº 9, 28027 or to email: dpo@panel.es.
• Data of the Data Protection Officer: PRODAT MADRID, SL – dpo@panel.es

In the same way, you are informed that you have the right to complain to the Spanish Data Protection Agency (www.aepd.es) if you consider that the data controller has not correctly satisfied your rights.