Integrity and conduct

Principios Éticos: Profesionalidad y Conducta .Grupo Clece

INTEGRITY AND BEHAVIOUR

The Code of Ethics that we adhere to sets out our principles, values, general standards of behaviour and directives on required courses of action for everyone in the company.

.In order to ensure that everyone adapts to these guidelines, an Ethics Channel (Internal Reporting System) is set up, through which the various stakeholders with whom we interact (members of staff, clients, suppliers, etc.) can report any incidents relating to behaviours that may constitute a breach or a failure to comply with the regulations in effect, pursuant to the provisions of Law 2/2023, of 20 February, on the protection of persons who report regulatory breaches and anti-corruption measures (“Whistleblower Protection Law”).

ETHICS CHANNEL (INTERNAL REPORTING SYSTEM)

At CLECE, we have effectively implemented a Compliance Management System that guarantees we act in accordance with current legislation within the framework of ethically impeccable conduct. Our Ethics Channel (Internal Reporting System) constitutes one of the main tools of this compliance system.

The purpose of this internal channel is to effectively receive and process notifications regarding behaviours that breach the principles outlined in our Code of Ethics and other essential documents that make up our Compliance Management System, as well as applicable legislation, as established by the Whistleblower Protection Law.

To facilitate its understanding and use, our Ethics Channel Operating Policy is available to anyone who wishes to report in good faith a possible infringement in a professional context with CLECE.

The information you provide us will be handled with complete confidentiality and anonymity—if you so wish—and we are committed to ensuring that your comments will be taken into consideration.

CLECE guarantees protection against retaliation, which is defined as any action or omission that may harm a person who reports, in good faith, possible violations through the Ethics Channel, as detailed in the following section.

What may be reported through the Ethics Channel?

Information on infringements or breaches in a broad sense, that is, reasonable suspicions, real or potential infringements that have occurred or are likely to occur. Reports must always be made in good faith and with the greatest level of detail and evidence possible.

By way of illustration, and without prejudice to what is contained in the Ethics Channel Operating Policy, the following are some of the possible topics subject to communication, in accordance with the provisions of Law 2/2023:

Cases of bribery and corruption.
Conduct against health and safety in the workplace.
Conflicts of interest in any action related to professional development.
Discriminatory conduct.
Sexual harassment, harassment based on sex, sexual identity, and workplace harassment.
Internal fraud.
Cases of unfair competition.
Breaches in matters of defence of competition law.
Conduct contrary to the health and safety of our users.

Complaints and claims related, for instance, to the quality of service must be submitted separately in the "Contact: Complaints/Claims" section of this website.

What channels are available to report potential irregular conduct?

Without prejudice to other channels included in the Ethics Channel Operating Policy, we recommend that you make your report, for greater security and confidentiality, as well as for the possibility of anonymous submission—if you wish—through the digital channel.

You can access this digital channel by clicking HERE, and through the phone line +34 900958058 (company PIN or ID number: 6719).

Telephone	PIN
+34 900958058	6719

Who will process the reported information?

It is important for you to know that the information contained in your report, including personal data, may be processed or shared with the following parties when deemed necessary:

Members of CLECE’s Technical Compliance Unit, as well as the Compliance Committee (Compliance Body) of the company.
Authorized representatives of the company involved in the investigation if the nature or scope of the reported facts require their participation.
Any investigator, advisor, or external consultant hired to support the company in analysing the report, investigating the matter, or advising the organization on issues related to such matters.