WELCOME TO THE ETHICAL CHANNEL OF BODEGAS FILLABOA
THE COMMITMENT OF FILLABOA BODEGAS WITH BUSINESS ETHICS:
Fillaboa Bodegas strongly opposes to the commission of any unlawful act and is firmly committed to complying with existing legislation, and undertakes to combat and prevent fraudulent actions and conduct in its business activity.
In this regard, the Ethical Channel is a key element for detecting suspected irregularities or illegal actions, and it enables Fillaboa Bodegas to take the appropriate measures required to remedy effects and prevent these situations from occurring again in the future.
The Regulatory Compliance Unit is responsible for the Ethical Channel corresponding to the companies that belong to the Corporación Masaveu Group. This body is chaired by Regulatory Compliance Management, together with Corporate, Industrial and Media General Management, and also the person in charge of Internal Audit and the Secretary of the Board of Management, the latter is also the Secretary of the Unit.
This body is chaired by Regulatory Compliance Management, together with Corporate, Industrial and Media General Management, and also the person in charge of Internal Audit and the Secretary of the Board of Management, the latter is also the Secretary of the Unit.
Complaints must be made in good faith and must be true, i.e., they must be based on the existence of reasonable proof of the irregularity, crime, or action that is illegal or contrary to the Ethical Code. The formulation of false complaints may result in slander and libel stipulated in articles 205 and s.s. of the Penal Code.
Inquiries and complaints of a commercial nature shall not be dealt with through the Ethical Channel, they must be processed through the customer service departments available in all of the companies.
The Ethical Channel offers two methods of communication:
- The Consultation Channel, through which queries, dilemmas, or questions related to the application of the Ethical Code, the corporative policies or any of the procedures established in the Corporación Masaveu group may be expressed.
- The Confidential Complaint Channel, through which knowledge or well-founded suspicion of any regulatory or compliance breach may be reported.
COMMUNICATION WITH THE INFORMANT:
The Ethical Channel ensures informants secure communication, even for those who have decided to remain anonymous. For this purpose, a mailbox is set up where, with a unique password and code assigned to the registered complaint, the informant can check the status of the complaint, correct formal defects and provide new information. For safety protocols the access codes and passwords shall not be retrievable, for which reason, if the informant doesn’t remember them, they will have to generate a new complaint.
Notwithstanding the foregoing, the Ethical Channel enables the informant to expressly waive receipt of any communication regarding actions carried out by the Regulatory Compliance Unit as a result of the information.
INFORMANT protection and external channels:
“Law 2/2023, 20 February, regulating the protection of persons who report regulatory violations and the fight against corruption” provides protection to those who report actions or omissions, of which they have become aware in a work setting, which may constitute certain breaches of European Union Law, or of a serious or very serious criminal or administrative offence, including amongst others, in any event, those involving financial loss to the Public Treasury and to the Social Security System.
Furthermore, such persons may report these events to the Independent Informant Protection Authority (A.A.I.) or to the relevant regional authorities or bodies.
For further information, see the “General Policy concerning the Internal Information and informant defence System”
