MONTEPINO places this Ethical Channel at the disposal of its members and any interested party, as a channel for information, communication or denunciation of any suspicion or knowledge of conduct, actions or omissions committed by a member of MONTEPINO in the exercise of his or her functions that could constitute:
- infringement of European Union law;
- a serious or very serious criminal or administrative offence, including, specifically, those which may involve financial loss for the Public Treasury and Social Security;
- conduct contrary to MONTEPINO's internal regulations, as well as to the values, guidelines or rules of conduct set out in MONTEPINO's Code of Ethics;
- any conduct that may be considered as creating an ethical dilemma; or that may reflect a relevant exposure to risk or pose a risk to MONTEPINO's reputation.
At the informant's request, the report may be submitted by means of a face-to-face meeting with the Responsible of MONTEPINO's Internal Information System, to be held within 7 calendar days of the informant's request. In this case, after obtaining the complainant's express consent and informing him/her of the processing of his/her personal data, the conversation held shall be documented in accordance with the provisions of the applicable legislation in force.
All complaints received will be entered into a complaints register, assigning each complaint a unique reference number by which it can be identified throughout its processing.
Complaints may be anonymous, i.e. the identification of the person making the complaint is optional. Only in the event that the informant or complainant provides an address, email or safe place to receive notifications, he/she will be notified of the acknowledgement of receipt with a reference number of the complaint; MONTEPINO may request additional information if necessary and keep him/her informed of the admission or not of the complaint and the corresponding resolution.
In order to ensure the best management of the Ethical Channel, MONTEPINO's ha designado y facultado al Compliance Officer de MONTEPINOGoverning Body has appointed and empowered MONTEPINO's Compliance Officer as Responsible of the Internal Information System for the management of the Ethical Channel in accordance with the Complaints Management Procedure, which we invite you to consult for further information on the processing stages; all this, in compliance with the provisions of Law 2/2023, of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption and the commitment acquired through MONTEPINO's Internal Information System Policy.
As an alternative to this MONTEPINO Ethical Channel, complaints may be submitted through external ethical channels to the Independent Authority for the Protection of Informants, to the competent administrative authorities, where appropriate, or to the institutions, bodies and agencies of the European Union, without constituting the preferred method for the submission of complaints.
MONTEPINO states that the Ethical Channel complies with the following principles and offers the following guarantees, the specific details of which can be found in the Complaints Management Procedure:
- Maximum confidentialit.
- Guarantee of the right of defence, presumption of innocence and right to honour.
- Guarantee of the principle of evidence and contradiction.
- Management of conflicts of interest.
- Prohibition of reprisals, including threats and attempted reprisals.
- Protection of personal data.
Please complete the form below to report conduct: