With the aim of strengthening a genuine culture of compliance, integrity and corporate responsibility, and acting consistently with its values and principles, Ziacom Group has implemented a confidential Internal Information System, known as the Ethics Channel.
This Channel constitutes the formal mechanism through which any individual who is part of the organisation, or maintains a professional relationship with it, may securely, confidentially and responsibly report facts or conduct that may involve:
It is further recalled that responsibility does not rest solely with the person committing an infringement, but also with those individuals who, having knowledge of improper conduct, tolerate it, approve it, or fail to report it immediately to their hierarchical superiors or to the manager of the Ethics Channel.
Features and Use of the Ethics Channel
Failure to report may be considered a very serious disciplinary offence.
Finally, we stress that the collaboration of all members of the Company is essential for the effective implementation of the criminal compliance program, whose purpose is to protect the legal entity and ensure its continuity and sound functioning, and, consequently, the well-being of all its employees.
The Ethics Channel is the Internal Information System implemented by the organisation to enable the secure, confidential and, where applicable, anonymous reporting of conduct that may constitute regulatory non-compliance or breaches of corporate principles and values.
It forms an essential part of the company’s compliance and risk prevention framework.
The Ethics Channel may be used by any person who is part of the organisation or maintains a professional relationship with it, including employees, former employees, collaborators, suppliers, clients and other associated third parties.
Yes. The Ethics Channel allows anonymous communications.
However, identification is recommended where possible, as it facilitates the investigation and ensures more effective protection against potential retaliation.
The procedure is handled within the time limits established by the applicable regulations, with an ordinary maximum period of three months to provide a response to the reporting person, except in cases of particular complexity.
Any conduct that may constitute a serious or very serious administrative offence, particularly where it involves financial harm to the Public Treasury and/or the Social Security system.
Any actions or omissions affecting the European Union, in particular in the following areas:
Actions or omissions affecting the internal market of the European Union in matters relating to competition and State aid, as well as infringements concerning corporate taxation or practices aimed at obtaining tax advantages contrary to the spirit of the applicable legislation.
Information relating to operations or practices that may be connected to money laundering and/or terrorist financing within the scope of the activities of Grupo Ziacom.