{"id":3500,"date":"2026-09-28T08:02:29","date_gmt":"2026-09-28T06:02:29","guid":{"rendered":"https:\/\/cebollasmarchite.com\/ethics-channel-policy\/"},"modified":"2026-10-02T12:45:29","modified_gmt":"2026-10-02T10:45:29","slug":"ethics-channel-policy","status":"publish","type":"page","link":"https:\/\/cebollasmarchite.com\/en-2\/ethics-channel-policy\/","title":{"rendered":"Ethics Channel Policy"},"content":{"rendered":"\t\t
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Ethics Channel Policy<\/h2>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
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  1. 1. PURPOSE<\/strong><\/h5><\/li><\/ol>

    <\/strong>The purpose of this document is to set out the guidelines for the Ethics Channel and the procedures for managing, investigating and acting upon any irregular, unlawful or criminal conduct that may occur at CEBOLLAS MARCHITE<\/strong>, as well as the safeguards and rights of the parties involved.<\/p>

    This Procedure is intended to gather information on events relating to risks that have materialised, are close to materialising, or are suspected of having materialised.<\/p>

    To this end, and in compliance with Law 2\/2023 of 20 February on the protection of persons who report regulatory infringements and on the fight against corruption, this Ethics Channel has been created to provide the necessary information on the possible commission of a criminal offence, a serious or very serious infringement of European Union or national law, or the materialisation of a risk.<\/p>

    This Ethics Channel is intended to be the preferred and primary means of reporting, ahead of any external reporting channel established by law, so that the company can immediately adopt the most effective and appropriate measures for the time and situation, whether to prevent the commission of a criminal or administrative offence, thereby avoiding the risk, or to mitigate its negative consequences if the unlawful conduct has already occurred, while also preventing it from happening again.<\/p>

    The operation of this Ethics Channel is based on the following principles, derived from its purpose:<\/p>

    \u2013 Protection of and advice for the whistleblower.<\/p>

    \u2013 Integration into the company’s procedures.<\/p>

    \u2013 Simplicity for the person reporting.<\/p>

    \u2013 Ease of access.<\/p>

    \u2013 Maximum awareness of its existence.<\/p>

    \u2013 Reliability of information.<\/p>

    \u2013 Confidentiality.<\/p>

    Of these principles, the last deserves special mention, as it has the greatest influence on the channel’s characteristics and use. Confidentiality is the cornerstone of the Ethics Channel, as it assures whistleblowers that the information they provide, as well as their personal data, will be treated in the strictest confidence. <\/p>

    Confidentiality does not necessarily mean anonymity. Submitting a report simply triggers an inquiry or investigation by the Ethics Channel Manager, who will seek to gather as much information as possible to verify the facts reported. It is therefore important that both the whistleblower and the channel manager are able to contact each other to expand on or clarify the information sent or received, as required by the investigation. Nevertheless, to encourage the reporting of facts that may be relevant to preventing regulatory non-compliance, anonymous reports may also be submitted, as provided for by law. <\/strong><\/p>

    1. 2. MATERIAL SCOPE OF THE ETHICS CHANNEL<\/strong> <\/strong><\/h5><\/li><\/ol>

      The Ethics Channel must allow the receipt of reports concerning facts that may constitute:<\/p>

      Acts or omissions that may constitute breaches of European Union law, provided that they:<\/p>

      1. Fall within the scope of the Union acts listed in the Annex to Directive (EU) 2019\/1937, regardless of how they are classified under national law. In this regard, it should be noted that the Directive lays down common minimum standards for the protection of persons reporting the following breaches of Union law: (i) public procurement; (ii) financial services, products and markets, and prevention of money laundering and terrorist financing; (iii) product safety and compliance; (iv) transport safety; (v) protection of the environment; (vi) radiation protection and nuclear safety; (vii) food and feed safety, animal health and welfare; (viii) public health; (ix) consumer protection; (x) protection of privacy and personal data, and security of network and information systems. <\/p>

      2.- Affect the financial interests of the European Union, as referred to in Article 325 of the Treaty on the Functioning of the European Union (TFEU); or<\/p>

      3.- Affect the internal market, as referred to in Article 26(2) TFEU, including breaches of Union competition and State aid rules, as well as breaches relating to the internal market in connection with acts that breach corporate tax rules or arrangements whose purpose is to obtain a tax advantage that defeats the object or purpose of the applicable corporate tax law.<\/p>

      4.- Acts or omissions that may constitute a serious or very serious criminal or administrative offence. In all cases, this includes any serious or very serious criminal or administrative offences that result in financial loss to the Tax Authoritiesor the Social Security system. <\/p>

      5.- Breaches of employment law and occupational health and safety law reported by employees, without prejudice to the provisions of the specific regulations governing such matters.<\/p>

      CEBOLLAS MARCHITE hereby states that persons who submit reports, provide information and\/or make complaints that are malicious, in bad faith or knowingly false, or for the sole purpose of damaging the reputation and standing of the company or any of its professionals, managers, collaborators, customers or suppliers, may be subject to the corresponding sanctions, without prejudice to any civil and\/or criminal liability that may arise under current legislation.<\/p>

      Furthermore, the following are EXCLUDED from this Ethics Channel: any information outside the material scope of the Law, such as mere COMPLAINTS, QUALITY CLAIMS OR SUGGESTIONS, for which CEBOLLAS MARCHITEprovides other communication channels, separate from the Ethics Channel, accessible through other sections of its website.<\/p>

      1. 3. PERSONAL SCOPE OF THE ETHICS CHANNEL <\/strong><\/h5><\/li><\/ol>

        <\/strong>Reports will be received, processed and followed up when submitted by whistleblowers working in the private or public sector who have obtained information on breaches affecting the organisation, including:<\/p>

        • Public employees or employees working for others.<\/li>
        • Self-employed persons.<\/li>
        • Shareholders, partners and members of the administrative, management or supervisory body of a company, including non-executive members.<\/li>
        • Any person working for or under the supervision and direction of contractors, subcontractors and suppliers.<\/li>
        • Whistleblowers who report or publicly disclose information on breaches obtained in the context of an employment or statutory relationship that has ended; volunteers, interns and trainees, whether paid or unpaid; and persons whose employment relationship has not yet begun, where the information on breaches was obtained during the recruitment process or pre-contractual negotiations.<\/li><\/ul>
          1. 4. GENERAL PRINCIPLES OF THE INTERNAL REPORTING SYSTEM<\/strong><\/h5><\/li><\/ol>

            <\/strong>To ensure that the Ethics Channel is effective, the company will ensure that it meets all the requirements set out in Law 2\/2023 of 20 February on the protection of persons who report regulatory infringements and on the fight against corruption.<\/p>

            These include:<\/p>

            1. Enabling all persons concerned to report information on the breaches covered by the Law.<\/li>
            2. Guaranteeing the confidentiality of the identity of the whistleblower and of any third party mentioned in the report, as well as of the actions taken in managing and processing it, together with data protection, preventing access by unauthorised personnel.<\/li>
            3. Accepting anonymous reports.<\/li>
            4. Allowing reports to be submitted in writing, verbally, or both.<\/li>
            5. Integrating any other internal reporting channels that may exist within the company.<\/li>
            6. Ensuring that reports can be dealt with effectively within the company, so that the company is the first to become aware of any possible irregularity.<\/li>
            7. Being independent from, and clearly distinguished from, any other communication channels that may exist within the company (e.g. suggestion box, complaints box). <\/li>
            8. Having a Head of the Internal Reporting System, as provided for in Article 8 of Law 2\/2023 of 20 February.<\/li>
            9. Having a policy on the Internal Reporting System and whistleblower protection.<\/li>
            10. Having a procedure for managing the reports received.<\/li>
            11. Establishing safeguards for the protection of whistleblowers in accordance with Law 2\/2023 of 20 February.<\/li><\/ol>
              1. 5. GENERAL PRINCIPLES OF WHISTLEBLOWER PROTECTION<\/strong><\/h5><\/li><\/ol>

                <\/strong>In accordance with Title VII, “Protection measures”, of Law 2\/2023 of 20 February, the Reporting System shall ensure that persons who report regulatory infringements and corruption benefit from the following protection measures:<\/p>

                5.1. Conditions for protection<\/em><\/h6>

                <\/strong>Persons who report or disclose breaches covered by section 2 shall be entitled to protection provided that:<\/p>

                1. They have reasonable grounds to believe that the information was true at the time of reporting or disclosure, even if they do not provide conclusive evidence, and that the information falls within the scope of the law.<\/li>
                2. The report or disclosure was made in accordance with the requirements set out in the law.<\/li><\/ol>

                  The following are expressly excluded from the protection provided for in this law: persons who report or disclose:<\/p>

                  1. Information contained in reports that have already been [rejected].<\/li>
                  2. Information that is already fully available to the public or that amounts to mere rumour.<\/li>
                  3. Information relating to acts or omissions not covered by section [2].<\/li><\/ol>

                    Persons who have reported or publicly disclosed information on acts or omissions anonymously but who are subsequently identified and meet the conditions set out in the law shall be entitled to the protection it provides.<\/p>

                    Persons who report breaches falling within the scope of Directive (EU) 2019\/1937 of the European Parliament and of the Council of 23 October 2019 to the relevant institutions, bodies, offices or agencies of the European Union shall be entitled to protection under the law on the same terms as a person who has reported through external channels.<\/p>

                    5.2. Prohibition of retaliation<\/em><\/h6>

                    Acts of retaliation, including threats of retaliation and attempted retaliation, against persons who submit a report in accordance with the law are expressly prohibited.<\/p>

                    Retaliation means any act or omission that is prohibited by law or that, directly or indirectly, results in unfavourable treatment placing the persons affected at a particular disadvantage compared with others in the employment or professional context, solely because of their status as whistleblowers or because they have made a public disclosure.<\/p>

                    For the purposes of the law, and by way of example, the following are considered retaliation:<\/p>

                    1. Suspension of the employment contract, dismissal or termination of the employment or statutory relationship, including non-renewal or early termination of a temporary employment contract after the probationary period; early termination or cancellation of contracts for goods or services; imposition of any disciplinary measure; demotion or denial of promotion and any other substantial change to working conditions; and failure to convert a temporary employment contract into a permanent one where the employee had legitimate expectations of being offered permanent employment; unless these measures were taken in the regular exercise of management authority under employment law, owing to proven circumstances, facts or breaches unrelated to the submission of the report.<\/li>
                    2. Intimidation, harassment or ostracism.<\/li>
                    3. Negative performance assessments or references.<\/li>
                    4. Blacklisting or dissemination of information within a particular sector that hinders or prevents access to employment or to contracts for works or services.<\/li>
                    5. Refusal or cancellation of a licence or permit.<\/li>
                    6. Refusal of training.<\/li>
                    7. Discrimination, or unfavourable or unfair treatment.<\/li><\/ol>

                      A person whose rights are harmed as a result of their report or disclosure after the two-year period has elapsed may request protection from the competent authority, which may, exceptionally and with justification, extend the protection period after hearing the persons or bodies that may be affected.<\/p>

                      5.3. Measures for protection against retaliation<\/em><\/h6>

                      <\/strong>Persons who report information on the acts or omissions referred to in section 2, or who make a public disclosure in accordance with Law 2\/2023, shall not be considered to have breached any restriction on the disclosure of information and shall incur no liability of any kind in connection with such report or public disclosure, provided that they had reasonable grounds to believe that reporting or publicly disclosing such information was necessary to reveal an act or omission under that law, without prejudice to the specific protection rules applicable under employment legislation. This measure shall not affect criminal liability. <\/p>

                      The provisions of the preceding paragraph extend to reports made by employee representatives, even where they are subject to legal obligations of secrecy or non-disclosure of confidential information, without prejudice to the specific protection rules applicable under employment legislation. <\/p>

                      Whistleblowers shall not incur liability for acquiring or accessing the information reported or publicly disclosed, provided that such acquisition or access does not constitute a criminal offence.<\/p>

                      Any other possible liability of whistleblowers arising from acts or omissions unrelated to the report or public disclosure, or not necessary to reveal a breach under the law, shall be enforceable in accordance with the applicable regulations.<\/p>

                      In legal proceedings, including those concerning defamation, copyright infringement, breach of secrecy, breach of data protection rules, disclosure of trade secrets, or claims for compensation based on employment or statutory law, whistleblowers shall incur no liability of any kind as a result of reports or public disclosures protected by the law. They shall be entitled to rely, in their defence in such proceedings, on having made a report or public disclosure, provided that they had reasonable grounds to believe that it was necessary to reveal a breach under Law 2\/2023. <\/p>

                      5.4. Measures for the protection of persons concerned<\/em><\/h6>

                      <\/strong>While the case is being processed, persons concerned by the report shall have the right to the presumption of innocence, the right of defence and the right of access to the case file under the terms of Law 2\/2023, as well as the same protection established for whistleblowers, with their identity preserved and the confidentiality of the facts and data of the procedure guaranteed.<\/p>

                      1. 6. MANAGEMENT OF THE ETHICS CHANNEL<\/strong><\/h5><\/li><\/ol>

                        <\/strong>The Ethics Channel Manager shall be a collegiate body appointed for this purpose by the company’s governing body, which has delegated to one of the company’s executives the powers to manage the Internal Reporting System and to handle investigation files. This person shall be assisted, during the stage of receiving reports through the Ethics Channel, by external collaborators who will manage the IT platform set up for this purpose.<\/p>

                        1. 7. HOW TO SUBMIT REPORTS THROUGH THE ETHICS CHANNEL<\/strong><\/h5><\/li><\/ol>
                          • In writing<\/em><\/li><\/ul>

                            <\/em>Reports may be submitted in writing through the dedicated application available on the company’s website.<\/p>

                            • Verbally<\/em><\/li><\/ul>

                              You may also submit any information verbally by recording an audio file, which may not exceed 15 MB per file uploaded to the application.<\/p>

                              If necessary, you may split the recording into several audio files of less than 15 MB each, uploading them in chronological order, from oldest to newest.<\/p>

                              In the case of verbal reports, the whistleblower will be informed that the report will be recorded and will be informed about the processing of their data in accordance with Regulation (EU) 2016\/679 of the European Parliament and of the Council of 27 April 2016 and Organic Law 3\/2018 of 5 December.<\/p>

                              • Request for an in-person meeting<\/em><\/li><\/ul>

                                At the whistleblower’s request, a report may also be submitted at an in-person meeting.<\/p>

                                <\/strong>Whistleblowers wishing to submit their information at an in-person meeting must request it by using their code to access the “Messages” section, which allows them to communicate without having to identify themselves.<\/p>

                                The meeting must take place within a maximum of seven working days of the request.<\/p>

                                When submitting information through any of the above channels, the whistleblower may provide an address, email address, telephone number or safe place for receiving notifications, and may also expressly waive the right to receive any communication about actions taken as a result of the report by those responsible for handling it.<\/p>

                                In any case, whistleblowers may choose to submit their report anonymously.<\/p>

                                1. 8. EXTERNAL REPORTING CHANNELS<\/strong><\/h5><\/li><\/ol>

                                  <\/strong>In addition to the company’s Ethics Channel described in this document, anyone who wishes to do so may submit their information through the external reporting channel of the Independent Authority for Whistleblower Protection (A.A.I.).<\/p>

                                  <\/p><\/div><\/div>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t","protected":false},"excerpt":{"rendered":"

                                  Ethics Channel Policy 1. PURPOSE The purpose…<\/p>\n","protected":false},"author":1,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"footnotes":""},"class_list":["post-3500","page","type-page","status-publish","hentry"],"_links":{"self":[{"href":"https:\/\/cebollasmarchite.com\/en-2\/wp-json\/wp\/v2\/pages\/3500","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/cebollasmarchite.com\/en-2\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/cebollasmarchite.com\/en-2\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/cebollasmarchite.com\/en-2\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/cebollasmarchite.com\/en-2\/wp-json\/wp\/v2\/comments?post=3500"}],"version-history":[{"count":1,"href":"https:\/\/cebollasmarchite.com\/en-2\/wp-json\/wp\/v2\/pages\/3500\/revisions"}],"predecessor-version":[{"id":3501,"href":"https:\/\/cebollasmarchite.com\/en-2\/wp-json\/wp\/v2\/pages\/3500\/revisions\/3501"}],"wp:attachment":[{"href":"https:\/\/cebollasmarchite.com\/en-2\/wp-json\/wp\/v2\/media?parent=3500"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}