Ethics channel

Introduction

At the firm, we are committed to compliance, integrity, and corporate governance. Therefore, we have implemented a Whistleblower Channel that allows our employees, clients, suppliers, and related third parties to report any irregularities or misconduct in a safe and confidential manner. Our whistleblower channel is an essential tool to ensure transparency and regulatory compliance in both public and private organizations. In its design and implementation, we have considered: 1. European Legislation Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019: Known as the Whistleblower Protection Directive, it establishes minimum standards for the protection of persons reporting breaches of Union law in areas such as public procurement, financial services, anti-money laundering, product safety, transport safety, environmental protection, public health, and consumer protection, among others. 2. Spanish Legislation Law 2/2023:: This law, known as the Whistleblower Protection Law, adapts the European Directive (EU) 2019/1937 to the Spanish legal system. The law mandates that public and private sector entities implement whistleblowing channels and ensure the protection of whistleblowers against retaliation.

3. Related UNE and ISO Standards UNE 19601: Criminal compliance management systems. Requirements with guidance for use. This standard provides a framework for establishing, implementing, maintaining, and improving a criminal compliance management system in organizations, including whistleblowing mechanisms. UNE-ISO 37001: Anti-bribery management systems. Requirements with guidance for use. It provides requirements and guidance for establishing, implementing, maintaining, and improving an anti-bribery management system, which includes provisions for reporting bribery acts. ISO 37001: Similar to UNE-ISO 37001, this international standard establishes the requirements for an anti-bribery management system, including the creation of whistleblowing channels. ISO 37301: Compliance management systems. Requirements with guidance for use. This standard replaces ISO 19600 and provides a framework for establishing, developing, implementing, evaluating, maintaining, and improving an effective compliance management system within an organization, which includes the establishment of whistleblowing channels. ISO 37002: Whistleblowing management systems. This specific standard offers guidance for establishing, implementing, and maintaining a whistleblowing management system, covering the receipt and handling of reports to the protection of whistleblowers.

Principles and characteristics

  • Confidentiality

    Ensure the confidentiality of the whistleblower and the report itself, protecting their identity to prevent retaliation and foster trust in the system.

  • Whistleblower Protection

    Implement effective measures to protect whistleblowers against any form of retaliation, discrimination, or harm as a result of the report.

  • Accessibility

    The whistleblowing channel must be accessible to all employees and, in some cases, to third parties. This includes availability in multiple languages and accessible formats.

  • Anonymity

    Allow the option to make anonymous reports, although mechanisms to effectively investigate such reports must be considered.

  • Independence and Autonomy

    The whistleblowing channel should be managed independently, preferably by an entity or department without conflicts of interest in the reported matters.

  • Ease of Use

    The system should be easy to use, with clear instructions and simplified processes so that users can make reports without complications.

  • Effective Investigation

    Establish clear and efficient procedures for investigating received reports, ensuring appropriate and timely actions are taken.

  • Training and Awareness

    Provide regular training to employees about the existence and use of the whistleblowing channel, as well as the importance of ethics and regulatory compliance.

  • Follow-up and Feedback

    Provide whistleblowers with information about the status of their report and the investigation results, as much as possible and permitted by law.

  • Documentation and Record Keeping

    Maintain a detailed record of all received reports, as well as the investigations and actions taken, ensuring these records are managed in accordance with data protection regulations.

What cannot be reported?

At Celorio & Partners, we have implemented this channel to promote transparency and regulatory compliance. However, it is important to highlight that not all issues can be reported through this channel. The following situations are considered inappropriate or unsuitable for reporting through the Whistleblowing Channel: • Personal complaints or those not related to the firm • Employment issues and working conditions • Technical problems and information technology support • Customer complaints • General comments and suggestions • Prescribed, pending, or resolved issues • External legal matters

Additionally, communications that do not contain data or evidence indicating a presumed irregularity or breach of integrity will not be processed, and the initiator will be informed. Likewise, communications with implausible information, unrelated to the organization, or those made in a non-peaceful and respectful manner will not be processed by our platform. If the information provided to the Whistleblowing Channel pertains to strictly administrative, tax, labor, civil, or commercial matters, it will be redirected to the relevant department within our organization due to lack of jurisdiction.

Reporting Mechanisms


To facilitate access to and use of the Whistleblowing Channel, we offer several options:

  • Online Platform

    Available on our website, where a whistleblowing form can be completed.

  • Telephone

    A hotline available 24 hours a day, 7 days a week.

  • Email

    A specific address to receive reports.

  • Physical Mailbox

    Located in our offices for those who prefer to make a report in person.

Whistleblower Protection

At the firm, we guarantee the protection of all whistleblowers against any form of retaliation. We are committed to handling all reports with the strictest confidentiality and taking disciplinary measures against anyone who attempts to intimidate or harm a whistleblower.

This form is designed to collect detailed and specific information about the complaint, ensuring that the internal investigation team has all the necessary data to proceed efficiently and effectively: