Code of Ethics and Information channel
Said situations refer to any actions or omissions that are considered as infringements by EU law, or that constitute a severe or very severe criminal or administrative infringement, or that could imply financial loss for Public Finances and the Social Security. Likewise, this channel will be used for any infringements related to the Cesce Group’s principles and values as stated in its Code of Ethics.
The Internal Whistleblowing Channel has been configured as the preferred channel for reporting any infringements set forth in article 2 of the law 2/2023. For this purpose the EQS Integrity Line Tool has been developed in order to guarantee the absolute confidentiality and security of the informant. Both written or verbal communications may be submitted through this tool, and, likewise, communications may be made over the telephone or as a voice message.
The informant may request a face-to-face meeting, which may be recorded. The person who makes the communication shall be informed of the existing external channels and of the competent authorities. Verbal communications may be recorded or transcribed, and the transcription must be accepted by the informant.
When submitting their communication, the informant is required to indicate an address or email address for notification purposes, or, alternatively, they may choose to use the tool’s anonymous mailbox, which guarantees that communications are submitted and processed in an anonymous manner.
In addition, the informant may submit any relevant evidence in any format.
The Collegial Body responsible for the Internal Information System and the Prevention of Criminal Risks is formed by:
- Ms Marta Silva de Lapuente (General Secretary)
- Ms Rosa Lis de Miguel (Financial Director)
- Ms Carlota Carnal López de la Manzanara (Head of Enterprise Risk)
- Mr Carlos de Benito Álvarez (Human Resources Manager)
- Mr Jaime de Miguel Muñoz (Director of Legal Advisory Services)
The latter is authorised to manage the System and process any investigation files, acting in accordance with the Pro 238 procedure
The collegial body responsible for this system is also responsible for the Prevention of Criminal Risks.
This guarantees the confidentiality of the informant, of any individual who may be affected by the information provided, and of any other individuals who it may concern, and, likewise, it guarantees the confidentiality of the content contained therein.
Under no circumstances shall the informant be identified as the result of any of the affected persons exercising their right of access. There will be no type of reprisal for submitting any information that was presumed to be correct, based on the understanding that the cited information is within the scope of the law 2/2023. In such cases, the informant will be entitled to all of the protection measures established in article 35 of the Law 2/2023.
In accordance with the Organic Law 3/2018 on Personal Data Protection and the guarantee of digital rights, and article 29 and the subsequent articles of the law 2/2023, the processing of personal data for the application of the cited law shall be considered lawful, as shall the creation and maintenance of the whistleblowing systems used to inform the entity, even anonymously, its commission, or in the conduct of third parties under contract, of any actions or behaviours that could be in breach of the general or industry-specific regulations that are applicable to them.
