Compliance Channel

The communication will be inadmissible in the following cases:

• The content of the report does not fall within the Channel's remit. If the matter falls within the scope of another internal channel or area of ​​the Mutual, the data will be deleted from the Channel after anonymizing it and, where appropriate, forwarding the information to the relevant area, also informing the reporting person.
• 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 must 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 communication 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. Communications that have not been acted upon may only be kept in anonymized form, without the blocking obligation provided for in Article 32 of Organic Law 3/2018, of December 5, being applicable.”

In this regard, if your communication 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 communication, after which your communication will be deleted from the Channel and will remain only anonymized. Consequently, you will no longer be able to access your case through the Channel Portal (in the computer button “Tracking existing communication”). If you have read the inadmissibility notification, the communication will be removed from the Channel within the following 7 days.

If you have provided your email address, you will receive an email from “Whistleblower Software” indicating that you have a new update to your communication, with a link to enter your access password. If you have not provided an email address when submitting your communication to the Channel, you must periodically access the Channel Portal (using the "Tracking existing communication" button) to check whether your communication 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 communication through the platform, unless you choose to include your contact details. 

FREMAP will guarantee the confidentiality of your identity in accordance with the provisions of Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption. As a protective measure. FREMAP expressly states that its identifying data is not included within the scope of the right of access that can be exercised by the person affected by the communication.

Under no circumstances will the identity of the informant be revealed to the person affected by the communication or to third parties, without prejudice to the fact that, where appropriate, it may be necessary to know it to the person who has to carry out the investigation or the disciplinary or judicial procedure that may be initiated as a result of the investigation. Furthermore, their 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 their identity to the requesting authority, they will be informed of this circumstance unless such information could compromise the investigation or the judicial procedure.

All communications will be initially analyzed by the Regulatory Compliance Committee, as the entity responsible for managing the Compliance Channel, and if admitted, will be immediately investigated by the competent body. In case of inadmissibility, you will be informed of the reason for it..

The essential principles of the communications management procedure are published on FREMAP's corporate website at (https://www.fremap.es/Conocenos/Paginas/Cumplimiento-Normativo-y-Prevencion-Penal.aspx), and can access the guarantees and rights that assist him, in the FREMAP Internal Information System Policy Integrity.

We remind you that communications 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 communication through the "Existing communication tracking" information 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 data or even if you prefer to be contacted at the email or phone number you provide, your confidentiality will also be preserved). If a communication 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 jeopardize the confidentiality of the information - and subsequently, depending on whether it is an admitted communication that 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 Internal Information System Policy Integrity and on the corporate website.

Absolutely not. You can find more information by accessing the FREMAP Internal Information System Integrity 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 of making the communication, you believe and have well-founded reasons to believe that the content of it is true and you do not intend to defame or harm a third party in any way. He is not expected to seek evidence or investigate the incident, but he is 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 communication submission process, you will receive an automatically generated incident number and will be able to set a password. Using these access details, you can log in to your private area of ​​the Portal at any time by clicking on "Existing communication tracking" and following the instructions. This private area allows you to engage in direct dialogue with the System Manager (Regulatory Compliance Committee) or provide additional information while protecting your anonymity if that has been your choice. 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.