Ethics channel

Proarcai Management Consulting, S.L. (“Proarcai”) is committed to ethical conduct, transparency and full compliance with applicable law. In line with Directive (EU) 2019/1937 and Spanish Law 2/2023 on the protection of persons who report regulatory infringements and the fight against corruption, Proarcai has established an Internal Reporting System, available to employees, clients, suppliers, collaborators and any other third party.

Scope
The Ethics Channel may be used to report, in good faith, any actual or suspected:

  • Infringement of European Union law within the scope of Directive (EU) 2019/1937.
  • Serious or very serious criminal or administrative offence under Spanish law.
  • Breach of Proarcai’s internal policies or ethical standards, including harassment, discrimination or any other conduct contrary to the law.

Guarantees

  • Confidentiality: the identity of the reporting person, and of any third party mentioned in the report, is protected at all times, and access to the information is restricted to authorised personnel.
  • Anonymity: reports may be submitted anonymously.
  • Prohibition of retaliation: any form of retaliation, including threats and attempts at retaliation, against persons who report in good faith is strictly prohibited.
  • Presumption of innocence and right to be heard: all persons concerned by a report will be treated fairly and with full respect for their rights.
  • Data protection: personal data will be processed in accordance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018, solely for the purpose of handling the report.

Procedure

  1. The report is submitted through canaletico@proarcai.com.
  1. Receipt is acknowledged to the reporting person within seven (7) calendar days of its submission, unless doing so would jeopardise the confidentiality of the report.
  2. The report is assessed and, where appropriate, investigated. The reporting person will receive a response within a maximum of three (3) months from acknowledgement of receipt, extendable by a further three (3) months in particularly complex cases.

System Manager
The Internal Reporting System is managed by the Compliance Officer designated by Proarcai.

Reporting persons may also submit information to the competent external authorities, including the Independent Authority for Whistleblower Protection (A.A.I.), either directly or after using the internal channel.

Reports must be submitted in good faith and based on reasonable grounds. Deliberately false reports may be subject to the measures provided by applicable law.