In order to ensure that all the activities of the CSP Spain Group (the "Group") are in line with Union Law and the rest of the legal system in force, and in line with the Whistleblowing Directive (Directive (EU) 2019/1937) of the European Parliament and of the Council, of October 23, 2019 and its incorporation into Spanish Law by Law 2/2023, of February 20, 2023, this whistleblowing channel is made available to all collaborators and/or employees of the Group,
The Group is committed to improving its internal reporting channel and reserves the right to make changes to it in the future.
Our whistleblowing channel is always active (24h/365 days).
To report, which can be done anonymously, you can choose between:
The treatment procedure for all four means is the same.
If the whistleblower prefers, he/she may choose to make his/her report directly to the competent authorities. To do so, he/she can contact the external information channel of the Autoridad Independiente de Protección del Informante, A.A.I., or the regional authorities or bodies, or the corresponding institutions, bodies or agencies of the European Union-
Reports may be anonymous; however, if the whistleblower discloses his or her identity, maximum confidentiality will be guaranteed at all stages of the investigation, unless the whistleblower expressly consents or is requested to do so by the authorities.
In the event that the whistleblower does not disclose his or her identity, all interactions will be carried out using the identification number referred to below in point 1. Confirmation of receipt.
The law grants adequate protection from retaliation to natural persons who report any of the actions or omissions referred to in art. 2 of the Law 2/2023, provided that the reports are in good faith and comply with the conditions prescribed by law.
1. Confirmation of receipt
If the report was submitted through the Whistleblowing Channel, the confirmation of receipt along with the report ID is provided to the whistleblower at the time the report is sent. If the report was submitted through any of the other means, the confirmation receipt will be sent within seven calendar days - provided that the whistleblower has provided a contact mean -and it will include an identification number ("ID").
This ID will allow the whistleblower to follow up on the current status of the report using the Whistleblowing Channel and, if necessary, provide additional information.
2. Classification and evaluation
All received reports are thoroughly reviewed and analyzed by the Internal Anti-Corruption Committee ("ICAC"). If the report is credible and includes sufficient evidence, an investigation will be opened. Otherwise, it will be dismissed.
3. Investigation and confidentiality
The purpose of the investigation shall be to determine, as far as possible, the veracity of the facts reported and whether these facts constitute an infringement of Union law or of the rest of the legal system in force, always respecting the identity of the person or persons responsible for them.
The entire investigation shall be confidential. However, in the event that it is deemed necessary for a proper investigation of the facts reported, the information strictly necessary will be shared, involving as few people as possible.
In order to ensure independence and impartiality in the process, and whenever deemed necessary, the investigation of the report may be outsourced.
4. Decision and communication
Once the investigation has been completed, the ICAC will decide whether a violation has occurred and, if so, take the appropriate measures.
Finally, within a period of no more than 90 calendar days after confirmation of receipt - except in cases of special complexity where this period must be extended - the whistleblower will be informed, through the Whistleblowing Channel, of the result of the investigation carried out, unless there are circumstances that make it advisable to maintain the confidentiality of the conclusions reached.