Grupo Aluman
Whistleblowing Channel

General Information

Information regarding the existence of the Ethics Channel of Grupo Aluman

With the aim of strengthening a genuine culture of compliance and acting consistently with their values and principles, the companies that make up Grupo Aluman have implemented a common Internal Reporting System, called the Ethics Channel, in accordance with Spanish Law 2/2023, of 20 February, regulating the protection of persons who report regulatory breaches and the fight against corruption. The receipt of reports has been entrusted to an independent external manager.

Through this channel, any person who works or has worked for any of the group companies, or who has or has had a professional relationship with them, may report securely and confidentially, including anonymously:

  • Acts or omissions that may constitute breaches of European Union law under Directive (EU) 2019/1937 and Law 2/2023. This includes the areas of public procurement; financial services, products and markets; prevention of money laundering; product safety; transport safety; environmental protection; radiation protection and nuclear safety; food safety; public health; consumer protection; and protection of privacy, personal data and network security. It also includes breaches affecting the financial interests of the Union, the internal market, competition, State aid or corporate income tax.
  • Acts or omissions that may constitute a criminal offence or a serious or very serious administrative offence, including in all cases those involving financial loss to the Public Treasury or Social Security.

The channel also accepts reports on:

  • Breaches of the Code of Ethics, policies, procedures or internal regulations, or conduct that may affect the reputation, integrity or sustainability of the group.
  • Situations of workplace harassment, sexual harassment or gender-based harassment, and conduct contrary to the equality and non-discrimination of LGTBI persons. These reports will be forwarded to the competent body to be handled in accordance with Grupo Aluman's Protocol for action against workplace, sexual and gender-based harassment and for the real and effective equality of LGTBI persons.

All reports will be handled with the same confidentiality guarantees. Reports that do not relate to the facts described in the first block fall outside the protection regime of Law 2/2023, unless the facts may constitute a criminal offence or a serious or very serious administrative offence. Reports from persons with no employment or professional relationship with the group, such as customers, do not enjoy such protection either, although they will be handled with the same guarantees.

Reporting through this channel is the preferred route, provided the breach can be dealt with effectively internally and the reporting person considers that there is no risk of retaliation. However, you may also go directly to the external channels of the competent authorities, information on which is provided in the frequently asked questions section.

Grupo Aluman

Principles of the Ethics Channel

The Ethics Channel has been designed in accordance with the following characteristics and general operating principles:

  • Confidentiality: access to the information is restricted to persons authorised by law. Reports are received by an independent external manager. The identity of the reporting person is never disclosed to the persons concerned or to third parties.
  • Anonymity: you may report anonymously. However, identifying yourself facilitates the investigation and the effective application of protection measures.
  • Reasonable grounds: to be protected, the reporting person must have reasonable grounds to believe that the information is true at the time of reporting, even if they do not provide conclusive evidence. Reporting information knowing it to be false is classified as a very serious offence (Article 63.1.f of Law 2/2023).
  • Prohibition of retaliation: any retaliation is prohibited, including threats and attempts, against anyone who reports in accordance with the law and against those who assist them, their colleagues or relatives. Anyone who considers that they have suffered retaliation may report it through this channel or directly to the competent independent whistleblower protection authority.
  • Equal treatment: all reports are handled using the same criteria, regardless of who submits them.
  • Documented procedure: decisions on admission, investigation or closure are taken in a reasoned and traceable manner, in accordance with the Report Management Procedure approved by Grupo Aluman.
  • Harassment and discrimination: reports of workplace, sexual or gender-based harassment, or of discrimination against LGTBI persons, will be handled in accordance with the specific protocol, with the guarantees of confidentiality, speed and protection of the victim that it establishes.
  • Time limits: receipt will be acknowledged within a maximum of seven calendar days. A response will be given within a maximum of three months, extendable by a further three months in particularly complex cases.
  • Rights of the person concerned: the presumption of innocence, honour, the right to be informed of the facts attributed to them, to be heard and to the confidentiality of their identity are respected.
  • Referral to authorities: if the facts may indicate a criminal offence, they will be referred immediately to the Public Prosecutor's Office, or to the European Public Prosecutor's Office if they affect the financial interests of the Union.

Members of the group companies who become aware of possible breaches or non-compliance must report them through this Ethics Channel. They may also, if they prefer, use the external channels of the competent authorities. Failure to comply with this duty may give rise to the disciplinary measures provided for in employment legislation and the applicable disciplinary regime. Under no circumstances may anyone be penalised for choosing to use an external channel.

This cooperation is essential for the proper functioning of the group's crime prevention model, which aims to protect the group and all the people who work for it.

FAQs

Who can use the Whistleblowing Channel?
Any person who has obtained information about breaches in a work-related or professional context with any of the group companies. This includes current or former staff, job applicants, interns, volunteers, shareholders, members of the management body, self-employed persons, suppliers, contractors and subcontractors.

I am a customer. Can I use the channel?
Yes. Your report will be handled with the same confidentiality guarantees. However, the protection against retaliation provided by Law 2/2023 applies only to those who report in a work-related or professional context.

Which reports are not protected by Law 2/2023?
Reports concerning interpersonal conflicts or affecting only the reporting person and the person to whom the report refers. Also information already publicly available, mere rumours, facts outside the scope of Article 2 of the law, and reports that have not been admitted.

Can I report a harassment situation through this channel?
Yes. Your report will be forwarded to the competent body to be handled in accordance with Grupo Aluman's Protocol for action against workplace, sexual and gender-based harassment and for the real and effective equality of LGTBI persons, with guarantees of confidentiality and protection of the person concerned. If the facts may constitute a criminal offence or a serious or very serious administrative offence, you will also be protected under Law 2/2023.

Can I report anonymously?
Yes. The system does not record any data that could identify you, and you can follow up on your report with the tracking code. If you are later identified, you will retain the protection of the law.

How can I submit a report?
In writing using this form or, if you request it, orally at an in-person meeting to be held within a maximum of seven days.

What happens after I submit it?
You will receive an acknowledgement of receipt within a maximum of seven calendar days. The report will be assessed for admission and, where appropriate, investigated. You will receive a response within a maximum of three months, extendable by a further three months in particularly complex cases.

Who has access to my report?
Only the System Manager, the external manager and, where strictly necessary, the persons provided for in Article 32 of Law 2/2023 or in the harassment protocol, all of whom are bound by a duty of confidentiality.

What protection do I have?
Any retaliation is prohibited, such as dismissal, sanctions, changes to working conditions, negative assessments, harassment, blacklisting or reputational damage. Acts of retaliation may be punished with fines of up to €1,000,000. You may also request support measures from the competent independent whistleblower protection authority.

Can I go directly to an external authority?
Yes, either directly or after using this channel:

  • The independent whistleblower protection authority of the relevant Autonomous Community, where the facts affect only its territory and that Community has granted it competence over the private sector.
  • The Independent Whistleblower Protection Authority (Autoridad Independiente de Protección del Informante, A.A.I.) in all other cases, and in particular where the facts affect more than one Autonomous Community, through its electronic office.
  • For harassment and discrimination at work, the Labour and Social Security Inspectorate (Inspección de Trabajo y Seguridad Social).
  • Where applicable, the institutions, bodies, offices or agencies of the European Union.

What rights does the person concerned by the report have?
The presumption of innocence, the right to honour, to be informed of the facts attributed to them, to be heard, to access the file without the identity of the reporting person being disclosed, and to the confidentiality of their identity.

What happens if I report something that turns out to be untrue?
If you had reasonable grounds to believe it, you retain your protection. Reporting information knowing it to be false is a very serious offence and may give rise to disciplinary, civil or criminal liability.

I have lost my tracking code. What should I do?
For confidentiality reasons it cannot be recovered. You may submit a new report referring to the previous one.