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Whistleblowing Channel

The purpose of the Whistleblowing Channel is to receive, record and process reports of irregularities or breaches of regulations committed by employees or companies. This is a confidential communication channel for customers, suppliers, shareholders, etc., associated with PROA SUR S.L.

The procedure aims to regulate the receipt, handling, investigation and resolution of complaints regarding alleged irregularities or breaches committed by employees, sales agents, directors or business partners, which may arise in the course of PROA SUR S.L.’s business activities, as well as risk situations arising from exposure due to links with the public administration and other public bodies.

Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, on the protection of persons reporting breaches of Union law, as well as the recent Law 2/2023 of 20 February, regulating the protection of persons reporting breaches of regulations and combating corruption, published in the Official State Gazette (BOE) on 21 February 2023, which came into force on 13 March 2023.

Scope of complaints

This channel may be used to report any conduct that may constitute a breach of current legislation, our Code of Ethics or any other internal regulations of Proasur. More specifically, this channel should be used to report serious or very serious irregularities and breaches of ethical, criminal and administrative standards relating to:

  • Dealing with third parties (conflicts of interest, gifts, fraud, corruption, bribery or confidential information)
  • Internal fraud
  • Health and safety at work
  • Quality control
  • Competition (antitrust)
  • Intellectual or industrial property
  • Protection of personal data
  • Environment and sustainability
  • Financial, accounting or tax matters
  • Retaliation of any kind, including threats of retaliation and attempts at retaliation

Workplace harassment in its various forms can also be reported via this channel. Complaints regarding sexual harassment or harassment on the grounds of gender are handled in accordance with Proasur’s specific protocol for the prevention of and response to such cases, which is available on the corporate intranet.

What cannot be communicated via this channel?

This channel is not the appropriate place for:

  • Complaints relating to employment matters (pay, performance appraisals, working hours, etc.)
  • Interpersonal disputes involving only the complainant and the respondent
  • Customer complaints or claims
  • Complaints or claims relating to non-payment
  • Rumours or manifestly unfounded allegations
  • Emergencies requiring immediate action (threat to life or property)

Protection against reprisals

Any person who makes a complaint in good faith is protected against any form of reprisal arising from that complaint, including dismissal, denial of promotion, a change of post or working conditions, or any unfavourable or discriminatory treatment. This protection also extends to those who cooperate with or assist in the complaint process.

This procedure does not cover complaints made in bad faith or with the intention of causing unjust harm, and such conduct may be subject to the appropriate disciplinary measures.

Furthermore, the rights of the person affected by the complaint are guaranteed, including their right to be heard, to the confidentiality of their identity, and to the presumption that the facts are not deemed proven until the investigation has been concluded.

Notification of the complaint

Reports should be submitted via the PROA SUR S.L. website by completing the attached form and sending it to canaletico@proasur.com. Reports will be received and handled by the Compliance Officer at PROA SUR S.L.

Content of the complaint

Reports received must contain the information necessary to carry out an analysis of the alleged facts. Accordingly, reports received must meet at least the following requirements:

  • A clear and detailed account of the facts.
    Identification of the section and location where they took place.
  • The name and contact details of the complainant and their relationship with PROA SUR S.L., to facilitate the analysis and follow-up of the complaint.
  • Identification of the individuals involved in the reported behaviour or who are aware of it.
  • El momento en el que tuvo lugar o está teniendo lugar el suceso.
  • Quantification, where possible, of the impact of the reported event on the financial statements, where applicable.
  • Provide, if deemed necessary, any documents, files or other information deemed relevant to the assessment and resolution of the complaint.

Processing times

Once the complaint has been received, an acknowledgement of receipt will be sent to the complainant within a maximum of 7 calendar days of receipt.

The maximum time limit for responding to the complaint is three months from the date of acknowledgement of receipt (or from the expiry of the seven-day period, if no such acknowledgement has been sent). This time limit may be extended to six months where the complexity of the case so requires.

Política de Privacidad del Canal de Denuncias

The processing of personal data provided via this Whistleblowing Channel is governed by our Whistleblowing Channel Privacy Policy.

Attached Form