GROUP SALTÓ, in respect of the culture of compliance and the ethical values that it promotes in its actions, implemented a Compliance system which was updated by Law 2/2023, of February 20, regulating the protection of persons who report regulatory violations and the fight against corruption.
Consequently, and by virtue of art. 25 of the aforementioned Law, the essential principles of this internal information system are set out below, as well as a brief user guide. In turn, we make available the regulation of the information channel itself through the following document called “Regulations of the Internal Information System” and the link to the external complaints mailbox that is enabled, with a preferential character, for the carrying out of communications.
Regulations of the Internal Information System.
GENERAL PRINCIPLES
The management procedure of the Internal Information System (SII) or “reporting channel” is governed by the following principles:
It is a channel through which anonymous communications of facts that may constitute an administrative, serious or very serious infraction, or the commission of a crime are permitted. If the facts are criminal in nature, they will be sent to the Public Prosecutor’s Office and, if they affect the financial interests of the European Union, to the European Public Prosecutor’s Office.
The right to the presumption of innocence and the honor of the affected persons will be respected at all times. In turn, the affected person has the right to be informed of the actions and omissions attributed to him, as well as to be heard at any time. This information will be provided at the time and in the manner considered appropriate to guarantee the successful completion of the investigation.
The internal company channels to which the SII is associated are: the reporting channel of the Criminal Compliance Department; the protocol against harassment, sexual harassment, gender-based harassment and discrimination of the LGTBI community; and the digital disconnection.
Once you have communicated the information, you will be sent an acknowledgement of receipt within seven calendar days, unless confidentiality may be compromised.
The maximum period for managing your communication is three months from receipt of the communication, which may be extended by another three, if the fact is particularly complex. During this period, communication with the informant may be maintained and additional information may be requested.
Respect for the personal data protection regime and confidentiality during the management of the information is guaranteed, even when the information is not made through the established reporting channels or to personnel not responsible for its processing, who will be obliged to immediately refer it to the System Manager. To this end, the loss of confidentiality is classified as a very serious violation in the Law.
Below, we indicate the different external information channels of the competent supervisory authorities, as well as those at the European level:
At the European level, there are several ways to report to different organizations, depending on the matter in question. To facilitate your complaint, the following link is provided:
https://european-union.europa.eu/contact-eu/make-complaint_es
At the state level, the existence of the Independent Whistleblower Protection Authority (A.A.I.) is contemplated, the creation of which is provided for in Law 2/2023 itself and whose Statute was regulated in Royal Decree 1101/2024, of October 29.
Despite the above, this Authority is still pending creation.
At the regional level, we find that not all Autonomous Communities have decided to create or designate an authority to perform the functions of External Channel. Those that have done so are:
Anti-Fraud Office of Catalonia (OAC)
Andalusian Anti-Fraud Office (OAAF)
Office for the Prevention and Fight against Corruption in the Balearic Islands (OAIB)
Agency for the Prevention and Fight against Fraud and Corruption of the Valencian Community (AVAF)
Office for Good Practices and Anti-Corruption of the Foral Community of Navarre (OANA)
USE OF THE INTERNAL INFORMATION SYSTEM
The following will briefly explain the use of the Internal Information System (SII), and you can consult all its regulations through the Internal System Regulations.
1.- Matters that can be reported
Any actions or omissions that may constitute infringements of European Union law, provided that:
They relate to public procurement; services, products and financial markets and the prevention of money laundering and the financing of terrorism; product safety and compliance; transport security; environmental protection; radiation protection and nuclear safety; food and feed safety, animal health and animal welfare; public health; consumer rights and protection; protection of privacy and personal data, and security of networks and information systems.
Affect the interests of financial institutions of the European Union.
Affect the internal market.
Actions or omissions that may constitute a serious or very serious criminal or administrative offence.
2.- Sending the complaint
The complaint can be submitted anonymously or by providing identifying data, as preferred by the person making the complaint, this being one of their rights.
The preferred channel for making communications is the external complaints mailbox of DESCOMPLICA’T:
Without prejudice to the above, you can contact the Internal System Manager (RSII) directly, both in writing and verbally or by requesting a face-to-face meeting that will take place within seven days of your request.
Verbal communications, including the face-to-face meeting, must be documented with prior consent, either by means of a recording or by means of a complete and exact transcription of it, which you may check, rectify and accept with your signature.
3.- Admission for processing
Once the complaint has been received, it will be assessed whether it meets the minimum requirements for it to be admitted and managed.
If the communication turns out to be on a matter completely unrelated to the SII, it will be deleted.
If the complaint is related to another channel or communication route of the company, not affecting the Internal System, it will be sent to the corresponding channel.
If the communication turns out to be on a matter affecting the SII, it will be admitted for processing, an Identification Code will be given to the file of its processing and the actions will be registered in the SII register.
4.- Receipt of receipt
Unless it is assessed that confidentiality may be jeopardized, once the complaint has been admitted for processing, a receipt of its receipt will be sent to you, within the following seven calendar days.
Failure to send the accusation does not constitute a violation of your rights, because it only affects the moment of calculating when the investigation phase begins.
5.- Investigation Phase and notification of the resolution.
Once the deadline for justifying receipt has ended, the investigation of the reported facts will begin. The maximum period for its conclusion and notification will be three months, extendable by another three depending on the complexity.
Once the investigation has been resolved and the measures to be adopted have been agreed upon, the informant and the person affected by the communication will be notified of a summary of the facts, the results of the investigation, the conclusion reached and the measures to be adopted.