CEOE Code of Ethics and Good Governance

Internal Communication System. Ethical Channel

To this end, CEOE has an Internal Information System which, in accordance with the applicable regulations, is based on the following general principles:

• Right to anonymity: CEOE's Internal Reporting System admits the possibility for information to be transmitted in writing and anonymously, thus ensuring the confidentiality of the identity of the informant and of any third party mentioned in the communication. However, CEOE encourages informants to identify themselves, as this allows for greater fluidity and rigour in the processing of the information.
   
• Confidentiality: The Internal Information System is designed, established and managed securely. The actions carried out in the management and processing of the information will be confidential, preventing access by unauthorised personnel.
   
• Prohibition of retaliation: Acts constituting retaliation, including threats of retaliation and attempts of retaliation against persons who submit information in accordance with the provisions of Law 2/2023, regulating the protection of persons who report regulatory infringements and the fight against corruption, are expressly prohibited.
   
• Guarantee of the rights of the affected person: The person to whom the information received refers shall have the right to be heard at any time and the presumption of innocence and the right to honour shall be respected in all cases.
   
• Respect for the Protection of Personal Data: Compliance with the provisions on the protection of personal data is guaranteed in accordance with the provisions of Law 2/2023, regulating the protection of persons who report regulatory infringements and the fight against corruption.
   
• Processing guarantee: The communications submitted will be effectively processed by CEOE. The maximum period for responding to the investigation will be three months from the receipt of the communication, except in cases of particular complexity that require an extension of the deadline, in which case, this may be extended up to a maximum of three additional months.
   
• System Manager: CEOE has a Compliance Officer, responsible for the internal information system, who acts according to the management and response procedure approved by CEOE in accordance with the provisions of the Law.
   
• Ethical Channel: Information to be sent through the Ethical Channel should be sent in writing using the following form, to the e-mail address canal.etico@ceoe.es or to the postal address: C/Diego de León, 50. 28006. Madrid. Att: Compliance Officer.