Through the Ethics Channel, you can report or raise concerns about actions that are contrary to the law, the Ethical Codeor other internal IGEMA regulations that you may have become aware of. This includes any information related to potential violations that should be properly investigated and, if necessary, addressed with appropriate measures.

Additionally, you can also use this channel to seek clarification or raise questions about IGEMA’s internal regulations or policies.

Anyone, both internal and external to IGEMA, can make a report or raise concerns through the Ethics Channel . This includes all members of IGEMA and individuals with whom the organization has business relationships.

Therefore, this Ethical Channel is accessible to any person, internal or external to IGEMA.any person, internal or external to IGEMA.

You can make a communication or complaint securely by filling out the form available in this section of the IGEMA website.

Informants may also choose to use the external channel offered by the anti-fraud office of Catalonia or the corresponding A.A.I. to provide information related to IGEMA.

The informant must provide as much available information as possible regarding the subject of the report, including the following details:

• Specific question about IGEMA’s internal regulations that needs clarification.
• Description of the facts being reported, if applicable.
• Identification of the individuals involved and their positions.
• Date of the incident.
• If applicable, names of potential witnesses.
• Any supporting documentation related to the reported facts.
• If the report is not anonymous, the informant should provide their full name, email address, postal address, and phone number.

1. This Ethics Channel guarantees:
– The possibility to report verbally or in writing.
– The option to remain anonymous by providing a non-identifiable email address.

2. IGEMA guarantees the informant’s right not to suffer retaliation for providing information in good faith.

3. This Ethics Channel allows the informant to be informed of the status of their report and whether the investigation concludes whether or not a violation has occurred. Therefore, an email address from the informant is required, even if it is non-identifiable for cases where anonymity is chosen.

4. The information provided will be confidential, and the informant’s identity will not be disclosed to third parties except upon request by the Judicial Authority, the Public Prosecutor, or the competent administrative authority within the framework of a criminal, disciplinary, or sanctioning investigation. All communications will be treated with the utmost confidentiality.

5. In order to ensure the confidentiality of data and the subject of the communication, the documentation contained in this Ethics Channel will be protected according to the requirements established by Data Protection regulations.

After information is submitted through the Ethics Channel, an acknowledgment of receipt will be sent within a maximum of 7 calendar days following the receipt of the communication, unless sending the acknowledgment could jeopardize the confidentiality of the communication.

The Ethics Channel Manager will assess the plausibility of the information received and its potential infringing nature within a maximum of 15 days from receiving the information. If the report is deemed implausible, it will be communicated that the case is closed, along with any additional measures taken.

If the provided information is insufficient, further details may be requested.

When a received report is deemed plausible, an internal corporate investigation will be initiated, ensuring that the individuals implicated have the rights of presumption of innocence, defense, and contradiction. Under no circumstances will the identity of the Informant be disclosed to the individuals under investigation.

If you want to proactively check the status of your report or complaint at any time, you can request an update through the same Ethics Channel by providing the necessary details for proper identification.

Tracking your communications can be important for several reasons:

1. To verify if your report has been properly received and an investigation is underway.
2. System managers may request additional information from you to help resolve the issue or take appropriate action.
3. To provide supplementary information related to your initial communication.