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FREMAP Compliance Channel

Welcome to the FREMAP Compliance Channel. In accordance with our Compliance Culture, we place this Channel at your disposal. It is integrated into the FREMAP Integrity internal Information System and offers you a way to communicate your concerns about irregular conduct or conduct contrary to current regulations and/or our principles and values.

This Channel should not be used to:

  1. Falsely or deliberately accuse other people. Only reports made in good faith will be accepted.
  2. Report complaints or claims regarding FREMAP's benefits management or the treatment you receive from our staff. Instead, please use the dedicated complaints channel accessible under Complaints and Claims, atencionclientes@fremap.es or through the FREMAP website, in the section About Us >Contact FREMAP >Complaints and Claims.
  3. Send questions relating to the management of data protection rights. These should be sent to the address derechos_arco@fremap.es , as well as requests for intervention by the data protection officer prior to the filing of a complaint with the AEPD against the Controller or Processor, which should be sent to the address dpd@fremap.es.

 

This is a confidential Channel, so you can choose to identify yourself, but if you prefer, you can report anonymously. In any case, you can check the status of your report by pressing the button "Track existing report" from this same page, to make it easier and safer for us to communicate. When submitting the report, you may indicate an address, e-mail address or safe place to receive notifications. You can find more information about this Channel in the sections "FREMAP Integrity Internal Information System Policy" and on the corporate website.

We recommend that you consult the FAQs to learn what type of breaches or irregularities you can report through this channel and what information falls outside the scope, and therefore, what causes a report to be rejected, as well as other issues of interest.

Regarding the processing of personal data, you can find more information in "Basic Data Protection Information.

If you wish to make an INQUIRY, click here.

FAQs

You can report any type of information related to illegal activities or irregularities applicable to FREMAP, including our Catalogue of Prohibited Conduct. If you are a FREMAP employee and you detect or suspect irregular conduct, you should submit a report so that the Regulatory Compliance Committee or the relevant area can handle it as soon as possible. In any case, you must take into account the FREMAP Integrity Internal Information System Policy as well as the Data Protection and Privacy Policy and submit reports in good faith. Your cooperation is essential to prevent irregularities or behaviours contrary to our principles and values, or to current regulations. What's more, you can submit your report by accessing the form via the "Create a new report" button, either in writing or through a secure voice recording system, or by requesting a face-to-face meeting (for which you will need to provide your contact information).

The Compliance Channel may not be used to report interpersonal or work-related issues or conflicts that do not constitute a breach or illegal act. 

Knowingly reporting false facts or events is strictly forbidden, and FREMAP reserves the right to exercise its disciplinary power in accordance with current labour regulations or to terminate a contract/link with the third party acting in bad faith.

Likewise, mere rumours or information that has been obtained illegally, as well as information that has been previously investigated, is being investigated, or is the subject of a judicial proceeding, should not be submitted.

Communicating data revealing ethnic or racial origin, political opinions, religious or philosophical beliefs, trade union membership, as well as biometric data, data relating to health or sex life or sexual orientation of the person concerned or any other persons, must be avoided in all cases.

If you report any information that does not fall within the scope of the Compliance Channel but is of interest to a particular department within the Mutual Society, the details will be deleted from the Channel once the information has been forwarded to the relevant department, and the person who made the report will be informed accordingly.

The report will be rejected in the following cases:

  • The content of the report does not fall within the Channel's remit. If it falls within the remit of another internal channel or area of the Mutual Society, data pertaining to the Channel will be deleted after it has been made anonymous and, if applicable, after the information reported has been referred to the relevant area, and the reporter will be kept informed.
  • The reported events are clearly unfounded or there is a reasonable indication that an offence has been committed in obtaining them.
  • The reported events lack plausibility.
  • The reported events have already been the subject of a previous internal investigation that has already been completed, or if the events are being or have already been investigated by the authorities.
  • The information provided is generic and does not refer to specific events that can be verified. In this case, prior to the report being rejected, the Regulatory Compliance Committee will ask the reporter to provide additional information, granting a period of seven (7) calendar days to do so, after which, if there has been no response to the request, the report will be rejected.

FREMAP is obligated to comply with the provisions of Article 32.4 of Law 2/2023, which states that “4. In any case, if three months have elapsed since the receipt of the report without any investigative actions having been initiated, it must be deleted, unless the purpose of its retention is to leave evidence of the functioning of the system. Reports that have not been acted upon may only be kept in anonymised form, without the blocking obligation provided for in Article 32 of Organic Law 3/2018, of 5 December, being applicable.”

In this regard, if your report is rejected, the information about said rejection will be kept on the Channel portal for up to a maximum of 3 months from the receipt of the report, after which your report will be deleted from the Channel and will remain only in an anonymised form. Consequently, you will no longer be able to access your case through the Channel Portal (in the computer button “Track existing report”). If you have read the rejection notification, the report will be removed from the Channel within the following 7 days.

If you have provided your e-mail address, you will receive an e-mail from “Whistleblower Software” indicating that you have a new update to your report, with a link where you can enter your access password. If you have not provided an e-mail address when submitting your report to the Channel, you must periodically access the Channel Portal (using the "Track existing report" button) to check whether your report has been accepted or rejected.

To guarantee anonymity, the data is encrypted and transmitted through the secure and independent server of the external company providing the service. FREMAP will not access your identity when you send a report through the platform, unless you choose to include your contact details. 

FREMAP will ensure that your identity remains confidential pursuant to Law 2/2023 of 20 February on the protection of persons who report regulatory infringements and the fight against corruption. As a protective measure. FREMAP expressly states that your identifying data is not included within the scope of the right of access that can be exercised by the person affected by the report.

Under no circumstances will the identity of the informant be revealed to the person affected by the report or to third parties, without prejudice to the fact that, where appropriate, it may be necessary for the person responsible for conducting the investigation or any disciplinary or judicial proceedings that may be initiated as a result of the investigation to be made aware of that identity. Furthermore, your identity may be communicated to the judicial authority, the Public Prosecutor's Office or the competent administrative authority within the framework of a criminal, disciplinary or sanctioning investigation, as FREMAP has the duty to cooperate with the competent authorities. In this case, and prior to communicating your identity to the requesting authority, you will be informed of this circumstance unless such information could compromise the investigation or the judicial procedure.

All reports will be initially analysed by the Regulatory Compliance Committee, as the entity responsible for managing the Compliance Channel, and if accepted, will be immediately investigated by the competent body. If your report is rejected, you will be informed of the reason(s) why.

The key principles of the reports management procedure are published on FREMAP's corporate website at (https://www.fremap.es/Conocenos/Paginas/Cumplimiento-Normativo-y-Prevencion-Penal.aspx), and you can find out about your rights and the safeguards in place in the FREMAP Integrity Internal Information System Policy.

We remind you that reports concerning potential conflicts of interest that do not involve any illegal or irregular activity will be handled in accordance with FREMAP's Conflict of Interest Management Manual and the principles of conflict of interest management published on the website.

In any case, you can access the report through the "Track existing report" button to check if any message has been sent to you (for example, to request information). All of this while always protecting your anonymity or confidentiality (if you choose to provide your name or even if you prefer to be contacted at the e-mail address or phone number you provide, your confidentiality will also be preserved). If a report is accepted, FREMAP may involve external specialists and initiate an investigation. In this case, you will be informed through the platform or the contact method provided, when the investigation has been completed.

Within a maximum of 7 calendar days you will receive an acknowledgment of receipt (unless this could jeopardise the confidentiality of the information) and subsequently, depending on whether the report is accepted and must be investigated, there is a period of up to 3 months, extendable by a further 3 months in cases of complexity at the discretion of the investigating body, as set out in the FREMAP Integrity Internal Information System Policy and on the corporate website.

Absolutely not. Further information is available in the FREMAP Integrity Internal Information System Policy. Even if the investigation rules out any wrongdoing, FREMAP will ensure that no one suffers any retaliation. In this sense, the important thing is that, at the time the report is made, you believe and have well-founded reasons to believe that its content is true and you do not intend to defame or harm a third party in any way. You are not expected to seek evidence or investigate the incident, but you are expected to act in good faith, be cooperative, and provide all possible information.

If you believe you may face retaliation or that your information will not be handled properly, you can contact the external channel of the Independent Authority for the Protection of Informants (AIPI).

At the end of the report submission process, you will receive an automatically generated incident number and will be able to set a password. Using these credentials, you can log in to your private area of ​​the Portal at any time by clicking on "Track existing report" and following the instructions. This private area allows you to start a dialogue with the System Manager (Regulatory Compliance Committee) directly or provide additional information while protecting your anonymity if that is your preference. It is important that you do not lose the automatically generated reference number or your password in order to access your private area and check for messages.

FREMAP will treat your personal data confidentially. This means that if you have identified yourself, appropriate measures will be taken to ensure the protection of your personal data, that of third parties, and all actions carried out in the management and processing of the investigation, employing appropriate technical and organizational measures to guarantee and preserve the identity of individuals and the confidentiality of their data.