We make available to all EDM administrators, managers, employees and interns, as well as any other professional or external provider linked to EDM by virtue of a contract for the lease of works or services, all the necessary means so that, if they detect any action or omission that may constitute criminal, administrative or European Union regulatory violations, serious violations of the basic principles of the EDM Code of Ethical Conduct or its internal regulations, fraud or workplace harassment, they can report it, provided that they have become aware of the information about the violation in a work or professional context.
Some examples of situations that fall within the scope of the channel are: possible situations of workplace harassment, actions related to fraud, use of privileged information or any action carried out by a third party that could entail any kind of criminal liability for the entity. Any known illegal conduct must be reported through this channel.
Access to the Whistleblowing Channel will be through an external whistleblowing tool managed by the entity specialized in this: i2 Ethics. All complaints submitted through the complaints channel are anonymous for the entity that is the subject of the complaint, and their confidentiality is also guaranteed. Regardless of the above, the external entity managing the complaints channel will require the identification of the complainant, except for those complaints relating to serious breaches of European regulations, serious or very serious administrative offences or offences or conduct relating to the regulations on the Prevention of Money Laundering and Financing of Terrorism, in which identification will not be required if the complainant so requests. Therefore, the identifying data of the complainant will not be transmitted to the entity that is the subject of the complaint, except in the following circumstances: cases of false or uncertain complaints; existence of a judicial request that requires knowing the complete details of the complaint; or when it is necessary for the defence in court of the entity that is the subject of the complaint in accordance with its right to effective judicial protection.
The system guarantees a fair, non-discriminatory and proportional application of the sanctioning regime in accordance with the applicable disciplinary system and is available together with all the documentation that makes up the Criminal Risk Prevention System.
People who transmit their notifications in good faith will be protected against any type of retaliation, extortion, discrimination and penalization.
This Complaints Channel may not be used for illegitimate, personal or bad faith reasons.
In order to instruct the communications received, it will be necessary for the informant to provide sufficient information and for the complaint to be duly founded, motivated and present rational indications of an infraction having occurred. Otherwise, it will be archived due to not having sufficient elements for its instruction.
Finally, before filing a complaint, it is important that you carefully read the rules for using the channel, which will be presented to you prior to providing the information related to the complaint.