Ethics Channel
Internal Reporting System
CREM INTERNATIONAL SPAIN, S.L.U. makes an Ethics Channel available to everyone who deals with the company, set up as an Internal Reporting System in accordance with Spanish Law 2/2023 of 20 February on the protection of persons who report regulatory breaches and on the fight against corruption, which transposes Directive (EU) 2019/1937. The channel forms part of the company’s Criminal Risk Prevention and Management Programme and reflects its commitment to legality, integrity and transparency.
What is the Ethics Channel?
It is the confidential and secure means of reporting any fact, conduct or situation that may constitute a regulatory breach, a breach of the Code of Conduct or a criminal risk related to CREM’s activity. It is available twenty-four hours a day, three hundred and sixty-five days a year.
Who can use it?
Anyone who has obtained information in a work or professional context with CREM: employees and managers, members of the management body, interns and trainees, collaborators, suppliers, contractors and their staff, candidates in recruitment processes, and those whose relationship with the company has ended.
What can be reported?
Any act or omission that may constitute a breach of European Union law, a serious or very serious criminal or administrative offence, or a breach of CREM’s Code of Conduct and internal policies, including fraud, corruption or bribery, money laundering, breaches relating to health and safety, the environment, data protection, competition or product safety, as well as harassment or discrimination. The channel is not intended for ordinary commercial or consumer complaints, which should be addressed through the usual customer service channels.
How to report
Reports are submitted through the channel’s secure platform at https://canaletico.iconnexa.com/canal/crem. They may be made in writing, using the platform’s form, or verbally, by means of a voice recording made directly on the platform; an in-person meeting may also be requested and will be held within a maximum of seven days. Reports may be submitted with the reporter’s identity or anonymously and, in both cases, they are handled with the same guarantees. We recommend describing the facts as precisely as possible —what happened, when, where and who was involved— and attaching any supporting documentation available. On completion, the platform provides a tracking code that allows the reporter to check the status of the report and remain in contact with the channel managers while preserving anonymity.
How is it managed?
The receipt and initial handling of reports are entrusted to an external, independent manager, the law firm ICONNEXA Consulting Valencia, S.L., which receives and reviews them from Spain in accordance with Spanish law and CREM’s internal protocol, under the supervision of the Internal Reporting System Manager appointed by the company and registered with the Valencian Anti-Fraud Agency (Agència Valenciana Antifrau). Receipt of the report is acknowledged within a maximum of seven calendar days and, within a maximum of three months — extendable by a further three months in particularly complex cases —, the reporter is informed of the outcome of the investigation and of the measures adopted. All reports are entered in a register with the integrity and confidentiality guarantees required by law.
Guarantees
The identity of the reporter and of the persons concerned is confidential and may only be known by those responsible for managing the channel, except where there is a legal obligation to disclose it to the authorities. Any retaliation —including threats or attempts— against anyone who reports in good faith or cooperates in an investigation is prohibited: dismissal, disciplinary action, changes to working conditions, discrimination, intimidation or any other unfavourable treatment. This protection extends to anyone who has reasonable grounds to believe that the information is true, even if it is not ultimately confirmed; it does not, however, cover reports made in the knowledge that they are false, which may give rise to liability.
External channel
Independently of the internal channel, reporters may contact the competent authorities through the external channel: the Independent Whistleblower Protection Authority (Autoridad Independiente de Protección del Informante, A.A.I.) and, in the Valencian Community, the Valencian Anti-Fraud Agency (Agència Valenciana Antifrau, AVAF).
Data protection
Personal data processed through the channel is governed by Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018. Data controller: CREM INTERNATIONAL SPAIN, S.L.U. Purpose: to manage the reports received and any resulting investigations. Legal basis: compliance with the legal obligation laid down in Law 2/2023. Recipients: the external channel manager and, where appropriate, the competent authorities. Retention: data is kept only for as long as necessary to decide whether to open an investigation and, where applicable, for the duration of the investigation, within the time limits set by law. Rights: access, rectification, erasure, objection, restriction and portability, subject to the limitations provided for in Law 2/2023, by contacting the company through the means indicated in its privacy policy, which may be consulted for further information.