Ethical Mailbox

One of the fundamental elements of Aldesa’s Compliance System is the Ethical Mailbox. Anyone, whether or not they are part of the organization, can use it as a means of receiving information on the compliance model, expressing doubts about potential non-compliance, proposing improvements to the system and making complaints about issues related to compliance and business ethics, in a confidential manner, in accordance with applicable legislation.

Aldesa’s Compliance System is one of the bases on which the Group consolidates its institutional commitment to conduct all its activities and business in accordance with strict canons of ethical behavior. We remind you that, in addition to the Ethical Mailbox, Aldesa has its Code of Ethics as a basic element of the organization’s Compliance System, which includes the values, rules and principles of its corporate culture.

Questions that may arise when making a consultation or filing a complaint through the Ethical Mailbox:

Can I make a query or complaint anonymously through the Ethical Mailbox?

Yes, you can choose not to identify yourself. However, it is recommended that you provide your contact information in order to better follow up on the issue raised. The processing of personal data collected through the Ethical Mailbox has the sole purpose of being able to investigate those facts that have been reported, and are restricted and of confidential access, always giving priority to the protection of the informant in accordance with current legislation.

What issues can I use the Ethical Mailbox for?

The Ethical Mailbox is available for you and any internal or external person to the organization for queries about Aldesa’s Compliance System, proposals for improvement in said System, as well as internal control processes. It is also the channel for reporting breaches of the principles and values established in the Code of Ethics, the organization’s internal policies and procedures and actions or omissions involving a breach of the law and/or the commission of a crime.

What is the minimum content of a complaint?

In order to expedite the processing of the reported event, it is recommended to include, at least, the following information:

Brief description of the facts: please state, in chronological order, the facts believed to constitute a violation. Please indicate the department, company or project affected, identify the alleged violator to the extent possible, as well as individuals who may know or corroborate the facts. Attach any information and documents that you believe may help to clarify the facts. In the event that the documentation is not available to the complainant, indicate what documents they are and who has them, if any.

Indicate the type of violation:

Violation of the principles and values of the Code of Ethics and conduct policies. Please indicate which principle or principles are considered to have been violated.

Violation of an Aldesa’s internal policy or procedure. Please indicate which policy or procedure is considered to have been violated.

Violation of a law or commission of a crime. Please indicate which law is considered to have been violated or which alleged crime is being committed or is suspected of being committed.

Why should I refer to the Ethical Mailbox?

People who are part of the organization have the obligation to inform the Compliance Committee of any situation that may be contrary to the corporate Compliance System and, therefore, susceptible of generating a risk at the company. The notifications received in the Ethical Mailbox and the files that may derive from them are strictly confidential. Aldesa also ensures the protection of the whistleblower against any type of reprisal, not disclosing his or her identity except to authorized personnel.

What is NOT the Ethical Mailbox?

The purpose of the Ethical Mailbox is to improve the company’s internal control and to react as quickly as possible in relation to those actions that may be contrary to the corporate culture, to the controls or that may pose a compliance risk for Aldesa. It is important that, before making a report against a specific person in the organization, you consider the option of first making a consultation so that we can help you determine the degree of certainty with which the potential violation is being committed. In other words, it is preferable to send an inquiry first rather than an accusation.

There is no room for vendettas, defamation, fraudulent use or reputational damage. In fact, improper use of the Ethical Mailbox is considered a breach of the company’s internal processes and may result in disciplinary sanctions.

What is the contact email address?

The Compliance Department makes the Ethical Mailbox available to you through the e-mail address:* etyka@aldesa.pl

*Data protection: The personal data you provide will be included in the file that is the responsibility of the Group Aldesa, registered address at Bahia de Pollensa, 13-28042 Madrid, Spain, in order to manage your notification, conduct of the investigation of the facts reported, adopt the pertinent corrective measures, and, if necessary, inform you about the result of the procedure.

Your data will be treated confidentially, and will not be communicated to any third part, unless they are essential for the investigation of the facts reported.

In any case, in compliance with the legislation on data protection, you can exercise you rights through the email address: arcopol@aldesa.es providing the copy of you ID or equivalent document, and identifying yourself as a user of the Internal Reporting user.