Integrity and behaviour

All our activity at CLECEVITAM is backed by a corporate culture that goes beyond strict compliance with the law. It is a way of acting that articulates relations with all our interest groups, from which we also require spotless behaviour to contribute jointly, and sustainably, to economic and social progress.

To that end, CLECEVITAM provides a Code of Ethics that records our principles, values, general rules of conduct and principles for action required of all members of the company.

In order to ensure that all members of CLECEVITAM comply with those guidelines, we have set up an Ethics Channel through which the different groups with which we interact (employees, clients, providers, etc.) may submit their reports concerning specific behaviour, or their doubts regarding our compliance system.

Ethics channel

At CLECEVITAM, we have made all the necessary decisions to effectively implement a Compliance System that guarantees that we act pursuant to the legislation in force and also according to ethical conduct. Our Ethics Channel is configured as one of the main tools of the compliance system.

The aim of this channel is to effectively receive and process notifications regarding behaviour that is essentially in breach of the principles considered in our Code of Ethics.

To facilitate its knowledge and use, we make our Ethics Channel Operating Policy available to any person who intends to report in good faith on a possible infringement in a professional context with CLECEVITAM.

The information they provide us shall be managed in a completely confidential, anonymous – if they wish-. You have our commitment that your remarks shall be taken into account.

Remember that this channel is not the appropriate place to manage complains and claims related, for example, to the quality of the service, or to specific aspects of labour matters, treatment of which must be processed separately, for which we recommend you access the “Contact” section on this web, or address the relevant branches of the company.

What may be reported through the Ethics Channel?

Information on infringements or failure to fulfil in an ample sense, that is, reasonable suspicion, real or potential infringements, that have taken place, or that may probably arise. Reports must always be made in good faith and with the greatest degree of detail and possible evidence.

For the purposes of illustration, and notwithstanding what is set forth in the Ethics Channel Operating Policy, the following are some of the possible subjects to be reported:

Cases of bribery and corruption.
Conduct against health and safety in the workplace.
Conflicts of interest in any action related to professional developmen.
Discriminatory conduct.
Sexual and labour harassment.
Internal fraud.
Cases of unfair competition.
Breaches in matters of defence of competition.
Conduct contrary to the health and safety of our users.
Etc.

What channels exist to communicate possible irregular conduct?

Without prejudice to other channels within the Ethics Channel Operating Policy, we recommend that, for greater security and confidentiality, as well as the possibility of anonymous submission – if you wish-, through the digital channel Ethicspoint, by our provider Navex Global.

You can access that channel by clicking HERE.

You also have the following telephone numbers available to you 24 hours a day, 7 days a week, as part of the Ethicspoint, channel by our provider Navex Global:

Country	Telephone number
Spain	900 876 439
United Kingdom	0800 048 5851
Portugal	800 181 376

Who will process the information reported?

It is important for you to know that the information reported, including personal data gathered in the context of a report, may be processed or notified to the following parties when necessary:

Navex Global, the independent third party acting as data processor, that manages the digital reporting, or so-called alternative channels.
Members of the CLECEVITAM Technical Compliance Unit, as well as the Compliance Committee (Compliance Body) of the company.
Authorised representatives of the company who intervene in the investigation, if the nature or scope of the facts denounced require their participation.
Any investigator, advisor or external advisor who has been hired to support the company in evaluating the notification, in investigating the matter, or to advise the organisation on points related to such matters.
The police and/or other regulatory or law enforcement bodies.

All parties concerned are encouraged to submit information regarding possible infringements of our Code of Ethics, as well as to request guidance regarding the policies available below. We thank you in advance for your valuable collaboration.

Please do not forget to read our Ethical Channel Privacy Policy. You also have information available on data protection in the actual Ethics Channel Operating Policy.