This is an informative translation. In the event of any discrepancy, the Spanish version prevails.
Alberich’s commitment to business ethics
Francisco Alberich, S.A. declares its opposition to any unlawful act and its firm resolve to comply with the legislation in force, and to this end undertakes to combat and prevent fraudulent acts or conduct within the scope of its business.
In this context, the Whistleblowing Channel is established as a means of detecting suspected irregularities or acts contrary to the law, the investigation of which also makes it possible to take appropriate measures to remedy their consequences and to prevent such situations from recurring in the future.
The body responsible for the Whistleblowing Channel of Francisco Alberich, S.A. is the Compliance Unit, a body made up of the Corporate Management and set up specifically for this purpose.
Reports must be made in good faith and must be truthful; that is, they must be based on reasonable indications that an irregularity, offence, unlawful act or act contrary to the Code of Ethics has been committed. Making false reports may constitute the offences of false accusation and insult (calumnia and injuria) defined in Article 205 et seq. of the Spanish Criminal Code.
Queries or complaints of a commercial nature will not be handled through the Whistleblowing Channel; they must be submitted through the customer service channels set up in each of the companies.
The Whistleblowing Channel has two means of communication:
- Query Channel, through which doubts, dilemmas or questions may be raised regarding the application of the Code of Ethics, corporate policies or any of the procedures established by Francisco Alberich, S.A.
- Confidential Reporting Channel, through which any irregularity and/or regulatory breach that is known or suspected on well-founded grounds may be reported.
Communication with the whistleblower
The Whistleblowing Channel allows secure communication with the whistleblower, including those who have chosen to remain anonymous. To this end, a communication channel is enabled once the report has been registered.
Notwithstanding the above, the Whistleblowing Channel allows the whistleblower to expressly waive receipt of any communication about the actions taken by the Compliance Unit as a result of the information provided.
Whistleblower protection and external channels
‘Law 2/2023 of 20 February regulating the protection of persons who report regulatory breaches and the fight against corruption’ grants a protection regime to persons who report acts or omissions that may constitute certain breaches of European Union law, or a serious or very serious criminal or administrative offence, including in all cases those that involve financial loss to the Spanish Treasury and to Social Security, and of which they have become aware in a work-related context.
In addition, these persons may report such matters to the Independent Whistleblower Protection Authority (AAI) or to the relevant regional authorities or bodies.
For further information, please consult the General Policy on the Internal Reporting System of Francisco Alberich, S.A..