Whistleblower Channel

The Whistleblower Channel is a tool that the Grupo Cooperativo Cajamar (hereinafter, the Group or the Cajamar Group) has set up to prevent, detect and facilitate the communication of any breach of the internal or external rules, guarantee the confidentiality of notifications and the rights of the whistleblower and the person concerned, as well as to enable reports to be filed anonymously.

Who may file a report?

The Whistleblower Channel is available to employees, directors, board members, interns, students on placement, former employees, prospective employees, agents, suppliers, members and customers of the Cajamar Group’s companies.

What can be reported?

The Whistleblower Channel can be used to report the following situations:

  • Potentially material financial and accounting irregularities
  • Any conduct that constitutes a breach of the following internal rules of the Cajamar Group:
    • Code of Conduct.
    • Criminal and Anti-bribery Risk Prevention Plan.
    • Anti-corruption Policy.
    • Money Laundering and Terrorist Financing Prevention Manual.
    • Conflict of Interests General Policy.
    • Regulations on the detection and reporting of suspicious transactions involving market abuse.
  • Any other irregular act, behaviour, action or fact that may constitute a breach of the Group’s other internal rules or the external laws and regulations applicable to its activities.

The Whistleblower Channel is not a form of communication for investors nor is it a Customer Service channel to deal with complaints or claims.

How to file a report

Reports can be filed 24 hours a day, 365 days a year via this application, which is accessible via the BCC website or any of the entities that form part of the Cajamar Group, guaranteeing confidentiality and anonymity. Acknowledgement of receipt of the report shall be sent to the whistleblower within seven calendar days of its receipt, unless this could jeopardise its confidentiality.

Notwithstanding the above, if the whistleblower so wishes, reporting may be via a face-to-face meeting, which shall take place within 7 days of the whistleblower’s request.

If the whistleblower has opted for the latter channel, the report will be documented via a full and exact transcript of the conversation and he/she will be informed of the processing of his/her data in accordance with data protection regulations, whereby hew/she will be offered the possibility of reviewing the transcript to check, rectify and accept the content by signing it.

Once the report has been made (via the platform or via a face-to-face meeting), communication may be maintained with the whistleblower and additional information may be requested, if deemed necessary.

Notwithstanding the aforementioned channels of communication, the whistleblower may contact the competent authorities (BdE, CNMV, DGSFP and BCE, among others), the EU institutions, bodies or organisations and the Independent Whistleblower Protection Authority.