EFFIC’s Commitment

At EFFIC, we firmly believe that our company should be guided by values that define how we work and interact with our environment. To this end, our work is based on values like excellence, teamwork, results orientation and transparency. We have zero tolerance for any type of behaviour that is illegal, inappropriate, fraudulent or contrary to good practice. EFFIC makes this commitment to its clients, users, suppliers, business partners and the public authorities.

Our commitment is based on the following principles:

I. Identifying and integrating all the actions needed to prevent, detect and react to any unlawful acts that may be committed.
II. Creating a climate of compliance and transparency.
III. Maintaining and improving channels to encourage people to report possible irregularities, raise doubts and put forward suggestions.
IV. Making it a requirement to provide information about any action that may constitute a crime, fraud or irregularity through the Complaints Channel.
V. Fostering a culture of ethics and compliance by: (i) encouraging responsible behaviour; (ii) raising awareness and establishing protocols and committees in order to correctly develop the aims of the company, so that each member of the organisation takes action and makes decisions in accordance with internal and external regulations; (iii) setting up programmes to provide training and information, and to raise awareness.
VI. Investigating all complaints about supposedly illegal or fraudulent conduct, and irregularities, in accordance with the Code of Conduct.

Internal Information Channel

In order to strictly comply at all times with the rules, laws, and principles that regulate corporate life, EFFIC has a Code of Conduct that includes the ethical principles and standards that should govern the behavior of all employees of the company. Its objective is to guarantee ethics and integrity in our daily activities across all areas of the organization. Our responsibility encompasses prevention, detection, and response to ensure strict compliance with regulations and ethical standards wherever we operate.

For this reason, we provide an Internal Information Channel to all our stakeholders, which allows effective communication of any irregular, illegal, or criminal behavior that is occurring, has occurred, or will occur at EFFIC. Irregular, illegal, or criminal behavior is understood to include any type of legal violation, violation of the Code of Conduct, or inappropriate behavior contrary to market best practices.

Where to Report

If you are aware of, have evidence, or have indications of corruption, illegal, or irregular conduct by any person connected to EFFIC, you have the following communication channels available:

Electronic platform: canal-effic.i2-ethics.com
Through this platform, you can submit information about any conduct or situation that may be considered illegal or irregular. The report can be completely anonymous, but if you prefer to identify yourself, you must check the boxes indicating 'Share this information with EFFIC' located next to the fields for your personal data. In this case, the whistleblower's identity will be confidential and only known to the body responsible for the investigation.
Postal mail
By postal mail addressed to the Code of Conduct Committee, c/ Roure 6-8 4th floor, 08820 El Prat de Llobregat (Barcelona).
You can choose to make the report anonymously.
Email
By email, addressed to the mailbox denuncia@effic.es
In person
Through an in-person meeting at our offices located at c/ Roure 6-8 4th floor, 08820 El Prat de Llobregat (Barcelona). To do so, you must request an appointment by email, addressed to the mailbox denuncia@effic.es

How to File a Report

In order to analyze the reported incidents, we need you to provide as much information as possible:

Clearly and concisely explain the facts.
Identify the individuals or companies involved, as well as the area of the company to which they belong, if known.
Specify when the events occurred.
If you have any supporting documentation that substantiates the report or helps with its resolution, please send it.
Provide any other information that you consider relevant.
Provide your contact information, except in the case of anonymous reports.

Handling of Reports

Once the report is received, it will be analyzed by the Code of Conduct Committee. If there are indications of inappropriate behavior, an investigation phase will be initiated; otherwise, the case will be closed. You can track the status of your report in the follow-up section.

Use of Information

EFFIC guarantees the confidentiality of the information and content provided, as well as the whistleblower's identity. Additionally, EFFIC ensures that no reprisals are taken against individuals who have made reports in good faith or based on reasonable belief.

In compliance with the regulations on the protection of personal data, EFFIC confirms that the personal data included in the report and the corresponding case file will be processed under the responsibility of EFFIC. Their use will be limited to the processing and investigation of the reported incidents, as fulfilling a legal obligation, performing a task carried out in the public interest, and pursuing legitimate interests are the legal grounds for processing.

Subject to legally established limitations, you are guaranteed the rights of access, rectification, opposition, erasure, data portability, restriction of processing, and any other applicable rights, which can be exercised by sending a written request to the Data Protection Officer: c/ Roure 6-8 4th floor, 08820 El Prat de Llobregat (Barcelona) or by sending an email to lopd@effic.es. Personal data will be processed as long as the case is being handled and, thereafter, will be retained for the necessary period to demonstrate compliance with the Internal Information System for a maximum of 10 years.

Any complaint or request related to the protection of personal data can be filed with the Spanish Data Protection Agency.