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Ethics Channel
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VENAIR

VENAIR Ethics Channel

A secure and confidential channel for reporting breaches or conduct contrary to the VENAIR Code of Ethics, anonymously or identifying yourself.

Who can submit a report?

All members of VENAIR and those with whom the Group has business relationships must comply with both the law in force and the Group's own Code of Ethics.

In order to prevent, detect and penalise breaches or unlawful acts that may be committed by its members or collaborators, VENAIR has set up this channel. This system allows any person, inside or outside VENAIR, who has become aware of such breaches or unlawful acts to bring them to the attention of the person responsible for the Internal Reporting System or, in the event of a conflict of interest, of the member who replaces them.

What can be reported?

Through this page you can send information about actions that are contrary to the VENAIR Code of Ethics or that may constitute breaches or unlawful acts of which you have become aware, so that they can be properly investigated and, where appropriate, penalised.

This channel is not intended for matters relating to complaints about orders, services or products.

Rights and guarantees of reporting persons

  1. Reporting persons are provided with a secure Internal System that guarantees:
    1. The possibility of reporting verbally or in writing. To report verbally, you can request a meeting in the form itself or attach a voice note;
    2. The option of remaining anonymous.
  2. VENAIR guarantees the reporting person's right not to suffer retaliation for information provided in good faith.
  3. This Internal Reporting System allows the reporting person to check the processing status of their report and to learn whether the investigation has concluded that there has or has not been a breach of the regulations applicable to VENAIR or of the Code of Ethics.
  4. The information provided will be confidential and the identity of the reporting person will not be disclosed to third parties, except at the request of a judicial authority, the Public Prosecutor's Office or the competent administrative authority in the context of a criminal, disciplinary or sanctioning investigation.
  5. In order to ensure the confidentiality of the data and of the subject matter of the communication, the documentation will be protected in accordance with the requirements of data protection legislation.
  6. Reporting persons may also choose to use the external channel offered by the Anti-Fraud Office of Catalonia (Oficina Antifraude de Catalunya) or the relevant independent whistleblower protection authority (A.A.I.) to provide information relating to VENAIR.

How do I submit a report?

From this website you can securely create a report or follow up an existing one. When you submit your report you will receive a random access key: keep it safe, as it is the only way to access it again. If you provide your email address, you will receive the registration details there and a notice when there is news in your case; for security, replies are not sent by email: you always read them on this website with your key. If you report without any contact details, we have nowhere to send you anything: you must keep the key yourself and check this page regularly to see the replies.

Following up your reports can be important for several reasons:

  1. To check the status of your report and confirm that it has been properly received and that the appropriate investigation is being carried out.
  2. The system administrators may ask you for additional information in order to resolve the issue or take the appropriate action.
  3. To add further information to your report.

How reports are handled

After you send information through the Internal System, you will receive an acknowledgement of receipt within a maximum of 7 calendar days of receipt of the communication, unless sending the acknowledgement could jeopardise the confidentiality of the communication.

The person responsible for the Internal Reporting System will assess the plausibility of the information received and whether it may constitute a breach within no more than 15 days of receiving the information. If the report is considered implausible, you will be informed that it has been closed and of any additional measures taken.

If the information provided is insufficient, you may be asked to supply further details.

Where the report received is considered plausible, the person responsible will order an internal corporate investigation, in which the persons reported will be guaranteed their rights to the presumption of innocence, to a defence and to be heard. Under no circumstances will the persons under investigation be told the identity of the reporting person.

What information should the report include?

The reporting person should provide as much information as possible about the facts to which the communication relates. Ideally, you should use the Internal Reporting System by submitting the duly completed form, including the following information:

Submit a report Follow up my report