Applus+ Ethics & Compliance Communication Channel is a means available to all Applus+ Professionals, our clients, suppliers and business partners, as well as other third parties, so that they can ask us questions about the correct interpretation and application of our Code of Ethics, as well as other internal regulations.
Likewise, through the E&C Communications Channel, they can send us any indication or reasonable suspicion of non-compliance with the Code of Ethics, the Anti-Corruption Policy and other internal regulations or laws.
All enquiries and complaints raised in good faith are welcome and will always be treated with the utmost speed and confidentiality.
Notwithstanding the foregoing, Applus+ informs of the existence of external communication channels with the competent authorities, depending on the type of infringement reported, although the company reiterates that the Ethics & Compliance Communication Channel, established for this purpose, is the preferred channel for the communication of such suspicions.
In order to be accepted and taken into consideration, all queries and complaints must contain, at least: certain details of the Reporting Party; the query raised, or a description of the alleged facts; and, if applicable, proof or supporting evidence of the reported facts.
Required information is marked with an asterisk in the applicable form available in our website.
At the request of the Reporting Party, a complaint may also be submitted by means of a face-to-face meeting.
It is essential that when you have any suspicion, knowledge or hint of an irregular conduct against Applus+’ internal regulations or other applicable regulation or laws, you raise your concern, since we can only address these situations if we are aware of them.
Applus+ commits to maintaining the confidentiality of a Reporting Party who is acting in good faith at all times. The Reporting Party’s identity will not be divulged to third parties, the reported party or their management without the express consent of the Reporting Party. Nevertheless, if the investigation of the facts requires such an action, a minimum of information will be shared with the fewest number of individuals.
Likewise, Applus+ commits to preventing, investigating and taking action against any kind of harassment or retaliation, direct or indirect, against a Reporting Party for the simple fact of having introduced a complaint according to the Applus+’ whistleblowing procedure.
Our Chief Compliance Officer is the person expressly appointed by the Group for all the process of managing, processing and resolution of complaints.
On receipt of a complaint, the CCO will register it, analyse and conduct an initial review of the facts and evidence as outlined in the complaint, and then decide if it is deemed to be admissible or it is dismissed for not presenting any clear evidence, not meeting the minimum requirements or being the allegations already reported to a judicial body or administrative authority.
Whatever the scenario, the CCO will inform the Reporting Party of his decision (to deem the complaint admissible or to dismiss it) within seven working days of receipt of the complaint.
For complaints that are deemed admissible, internal investigations will be performed to determine the veracity of the alleged facts, if said alleged facts constitute a breach of internal rules and/or the law and the identity/ies of those responsible for the misconduct.
Once the internal investigation in concluded, the CCO will produce a formal written decision and will communicate the outcome of the concluded investigation to the reporting and reported party, except where it is advisable to maintain the confidentiality of the conclusions reached.
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