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    • Ethical Channel

    We are committed to fostering a culture of integrity, transparency and accountability.

    Canal ético

    Nos comprometemos a fomentar una cultura de integridad, transparencia y responsabilidad.

    We have an ethics channel, integrated into our Internal Ethics Information System (SIIE).

    Objective: to guarantee integrity in all our actions, through respect, responsibility, honesty and compliance with the law. Consult information about the SIIE:   ES    EN    PT    FR

    Principles of the Internal Ethics Information System

    • The organizational values set out in our “Code of Conduct” apply to everyone associated with the FIIAPP. Our team must also report any irregular or unlawful conduct.
    • We make a responsible use of the ethical channel, alerting in a truthful and accurate way. We reject bad faith reports, made with the purpose of harming the organization or any of its members. We will also exclude information obtained illegally.
    • Our ethics channel is accessible to all our stakeholders, allowing them to submit anonymous and confidential reports – in writing, in person or verbally. We also have a channel for submitting ethical queries.
    • Our ethics channel is secure and guarantees the confidentiality of the identity of the whistleblower and any other person involved, as well as the information related to the report. For this reason, we limit the number of people involved internally in the follow-up of each report.

    All reports are handled with the utmost care and respect for all persons involved, guaranteeing their dignity, right to privacy and equal treatment. We have the due guarantees of protection for all persons involved. Consult your rights:

    ES    EN    PT    FR

    • We handle complaints fairly, with integrity, objectivity, objectivity, independence and ethics. The ethics channel offers the possibility of referring the complaint to another person in the event of a possible conflict of interest.
    • The members of the Ethics Committee are competent to ensure that all complaints are handled professionally and without undue delay, applying the principle of proportionality and respecting the principles.
    • We inform you clearly about your rights when using the ethics channel and about the principles of the SIIE.

    How to report

    Anyone can submit an ethics query or complaint through our ethics channel, available in four languages (Spanish, English, Portuguese and French).

    For more information, please consult the “Terms of use of the FIIAPP ethics channel” :  ES   EN    PT   FR

    • Whistleblowing

    Communication of any non-compliance or irregularity committed by any person linked to the organization in the course of their professional activity. Any conduct suspected of a violation of our Code of Conduct, an infringement or a possible criminal act will be treated as non-compliance or irregularity.

    • Ethical Consultation

    Consultations or doubts of interpretation or specification in matters of ethics or ethical dilemmas.

    What happens after reporting

    In the case of ethical queries, we will respond as soon as possible. In the event that you make a report to us, these are the steps to follow:

    Once the report is registered in the ethics channel, an automatic acknowledgement message will be displayed, in which the reporter will be provided with an identifier and password to be able to follow up on the report.

    If, after reviewing the information provided, it is considered that it is not clear, relevant or complete, we may request further information through the chat enabled in the ethics channel, which allows two-way communication. You will have a maximum of 5 working days to respond.

    The objective is to analyze the relevance, based on a series of predefined internal criteria. After this analysis, the complaint may be admitted, the complaint may be dismissed or an agreed resolution may be chosen (only in the case of harassment complaints). The decision will be communicated to you through the chat, detailing the motivation in case of being discarded.

    If the complaint is admitted, an investigative team will be appointed, based on suitability criteria, and will always include management and a member of the Works Council, unless there is a potential conflict of interest.

    In any investigation, it is essential to ensure that the rights of the person(s) concerned are protected. Therefore, during the course of the investigation, the investigative team must notify the person or persons concerned of the facts reported, so that they can exercise their defense. Under no circumstances will your identity be communicated to them, nor that of the victim if you are not the same person, nor will they be given access to the complaint.

    We will communicate this decision to you through the chat, as well as to the victim (in case you are not the same person) and to the person or persons concerned, detailing the motivation in case of being discarded.

    If any of the parties involved do not agree with the decision, they will be able to argue within a maximum period of 10 calendar days from the communication of the decision, and present new evidence or arguments. After the analysis of the allegations, if received, these may lead to a modification of the previously adopted decision, resulting in the final resolution of the investigation.

    For those cases in which it is concluded that there has been a breach or irregularity, the decision will be submitted to the FIIAPP’s decision-making body, which will issue an opinion on the matter.

    We will communicate this decision to you via chat, as well as to the victim (if not the same person) and to the person or persons concerned. If any of you do not agree, you may file a written appeal within a maximum of 15 working days from the date of notification of the decision, stating the reasons for your request and the legal grounds on which it is based.

    The investigation must be concluded within a maximum period of three months from the receipt of the complaint. In cases of special complexity that require an extension of the period, it could be extended up to a maximum of three additional months.

    The FIIAPP reserves the right to take the legal action it deems appropriate against the individual and/or legal entity that has committed acts constituting a crime, giving priority at all times to the freedoms, rights and protection of the victim. In such a case, the information will be forwarded to the Public Prosecutor’s Office or to the European Public Prosecutor’s Office (if the facts affect the financial interests of the European Union), always after the Board of Trustees has been informed by the Management or the General Secretariat.