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Ethical chanel

Ethical chane

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:

  1. Maximum confidentialit.
  2. Guarantee of the right of defence, presumption of innocence and right to honour.
  3. Guarantee of the principle of evidence and contradiction.
  4. Management of conflicts of interest.
  5. Prohibition of reprisals, including threats and attempted reprisals.
  6. Protection of personal data.

Please complete the form below to report conduct:

Personal data of the complaint
Only the fields marked with (*) are mandatory.

Only if you wish to receive notifications about the processing of your complaint, you must enter a valid email address.

Personal data of the reported person
Only the fields marked with (*) are mandatory.

Select the type of report or complaint you wish to make (you can select more than one option):

Please describe all the details about the complaint you wish to make. Try to be as specific as possible, providing the information you consider relevant for a correct resolution.

In any case, you should indicate: time and place of occurrence, possible witnesses, facts of what you consider to be the action, omission or conduct to be reported, identity of the person reported and any other information that may help in the investigation of the facts. You can attach files to complete the information.

Basic information on data protection:

Responsible: VALFONDO GESTIÓN, S.L, C/ Felipe Sanclemente, núm. 26, 3º, 50001, Zaragoza DPO Contact

Purpose: collection and processing of personal data voluntarily provided by the complainant, and those strictly necessary to process, investigate and resolve the complaints received in accordance with the Complaints Management Procedure. They will only be processed by those who carry out internal control functions at MONTEPINO in accordance with the Complaints Management Procedure. The most absolute confidentiality and custody is guaranteed under security measures appropriate to the type of data and the risk of the information processed.

Type of data: Identifying the person reported and the complainant except in anonymous complaints and, depending on what is indicated in the text of the complaint or attachments, may contain other types of data.

Legitimation: Compliance with a legal obligation in accordance with the provisions of Law 2/2023, of 20 February, regulating the protection of persons reporting regulatory and anti-corruption offences and Circular 1/2016, of the Public Prosecutor’s Office, which affects reports and communications relating to the crime of prevention of money laundering and legitimate interest in terms of complying with the requirements in terms of legal and regulatory compliance, especially those related to the possible criminal liability of the legal person, by virtue of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights.

Recipients: Your data may be transferred to third parties exclusively in the case of external legal advisors and to judicial bodies and to the State Security Forces and Corps or administrative authority, when necessary in accordance with the Public Prosecutor’s Office.

Retention: your data will be kept for the time necessary to decide whether to initiate an investigation and, where appropriate, while the investigation and resolution of complaints filed is being carried out, and always for a maximum period of 3 months from the filing of the complaint. However, the data may be processed for a longer period outside the Ethical Channel system, in the event that, as a result of the investigation process, it may be necessary to take appropriate legal action and/or which may give rise to legal proceedings.

Exercise of rights: Interested parties may exercise their rights of access, rectification, deletion, portability and limitation or opposition to processing by sending a communication to the attention of the Data Protection Delegate to indicating in any of the cases the Ref. Personal Data and the right being exercised, as well as attaching a copy of their ID card or substitute identification document.

More Information: Privacy Policy

If your rights are not satisfied, you may file a complaint with the Spanish Data Protection Agency.

The use of this form for commercial purposes is not authorised.