Whistleblowing Channel

WHISTLEBLOWING CHANNEL POLICY

1. Purpose and aim:

The purpose of this policy is to establish the internal procedure for the communication, processing, and investigation of reports regarding regulatory infringements or behaviors contrary to CHAMOS' values and ethical principles.

With this policy, CHAMOS supports that decisions can be made independently in all aspects of the whistleblowing channel, thus demonstrating its commitment to transparency and the importance of this channel.

2. Scope:

This channel is available for:

• Contracted personnel

• Volunteers

• Collaborators

• Suppliers

• Beneficiaries or other stakeholders

3. Enabled Channel.

The following means are enabled for submitting reports:

• Email: denuncias@chamos.org

• Anonymous web form: www.chamos.org/denuncias

• Physical mailbox: c/ Camino Ancho 41, Alcobendas 28109 Madrid

• Telephone line: +34 660 35 59 04

4. Persons Responsible for the Whistleblowing Channel (hereinafter PRWC):

The trustees will decide on two individuals to fulfill the functions of PRWC. These individuals must have the following characteristics: 

Integrity and professional ethics

• Must act with honesty, impartiality, and commitment to CHAMOS' values.

• Inspire trust from both whistleblowers and those involved in cases.

Confidentiality and discretion

• Ability to handle sensitive information securely and without compromising the identity of the whistleblower or the content of the report.

Analytical and discerning ability

• Ability to assess the plausibility and seriousness of a report.

• Ability to make objective decisions.

Independence and autonomy

• Must not be subject to conflicts of interest or internal pressures that could interfere with their role.

Management and follow-up capability

• Must be able to maintain an orderly record of cases, follow up on procedures, and implement improvement measures if failures are detected.

5. Submission of reports:

Reports can be submitted anonymously through the website or non-anonymously, in writing or verbally. The confidentiality of the whistleblower will always be guaranteed.

The report will be received by the PRWC via:

• Website and email: CHAMOS has an exclusive email address for reports and a visible system on the website. Only the individuals designated by the board of trustees for managing reports will have access to this system, and these individuals commit to treating the received information confidentially.

• Letter or phone call: Any means used will guarantee the confidentiality of the informant.

6. Types of reports:

• Anonymous report: To allow for proper follow-up, information to contact the whistleblower will be requested. It is up to the whistleblower to decide whether to provide it or submit the report anonymously.

The possibility of anonymous reports could facilitate receiving information from individuals who may fear retaliation. However, there is also the possibility of receiving malicious reports. Therefore, in these cases, it is crucial that the PRWC maintain dialogue with the whistleblower to request and receive additional information needed for the investigation process, while always maintaining anonymity. For this reason, in addition to anonymous online platforms, other spaces or meeting points for exchange may also be enabled.

• Non-anonymous report: CHAMOS commits not to take any disciplinary measures or legal action against the sender of a good faith report. The identity of the person making the communication will be considered confidential information and may not be disclosed without their consent.

7. Confidentiality and protection of the informant

The confidentiality of the whistleblower's identity and all related information is guaranteed, and any form of retaliation against individuals who communicate facts in good faith is prohibited.

8. Receipt and acknowledgment: 

The PRWC will issue an acknowledgment of receipt within a maximum of 7 days from the receipt of the report (when not anonymous). All reports will be registered in the Whistleblowing Channel folder (to which only the PRWC will have access), indicating the date of receipt and the report number (for example: 05 05 25 report 1).

CHAMOS reserves the right not to issue a response in the following cases:

• Requests for confidential data:
  Any request that involves accessing data protected by current legislation or linked to private agreements guaranteeing the confidentiality of individuals or institutions involved will be rejected.

• Malicious or bad faith requests:
  Requests whose content or form are disrespectful or contrary to the principle of good faith will not be processed. If there are reasonable indications of malicious intent, the PRWC will dismiss it and notify the sender of the reasons for such decision.

9. Evaluation: 

If the report does not meet the above conditions, the PRWC will work with the president or the secretary of the CHAMOS board of trustees (if not involved in the report) and an investigation file will be opened. This team will conduct interviews with the individuals involved, obtain internal and external information, meaning everything necessary to get to the bottom of the report and recommend the next steps for its resolution. 

This process must always respect both the right to defense, in the event that there is a report against a specific person, and the principle of confidentiality regarding the identity of the informant and the reported or affected party.

Likewise, CHAMOS reserves the right to take legal or disciplinary action against any employee or governing body member who retaliates against a good faith whistleblower.

10. Process resolution:

Once the investigation is concluded, a report with the corresponding conclusions will be prepared. This report will be submitted to the governing body in compliance with the conflict of interest policy. 

11. Measures:

The board of trustees will evaluate the results of the investigation, may request more information and/or deliberate to impose the corresponding sanction or actions to be taken, depending on the report filed. In the event that the reported facts could constitute a crime, their communication to the competent authorities will be recommended.

The data of individuals making the communication may be provided to both administrative and judicial authorities whenever required as a result of any procedure derived from the subject of the report. Such data transfer to administrative or judicial authorities will always be carried out in full compliance with data protection legislation.

12. Record and retention:

CHAMOS will maintain an internal record of reports in compliance with data protection regulations. The entire process will be properly documented, as will the fulfillment of established deadlines and communication with the informant about the handling of their report.

Therefore, the PRWC are responsible for keeping a record of:

• Total number of reports processed.

• Number of investigations completed.

• Number of reports closed with sanctions.

• Classification of reports by topic, e.g., financial, legal, reputational, etc.

Annually, the PRWC will send a report to the board of trustees detailing the number of reports processed, the number of completed investigations, and the number of reports closed with sanctions, as well as classifying all of them by type, always safeguarding pertinent confidentiality.

13. Effective date: 

This policy comes into force on its presentation date and will be reviewed at least every two years or when there are relevant regulatory changes.

May 7, 2025