The BME Group's Internal Information System (hereinafter "BME´s Information System") is the channel for reporting irregular or potentially inappropriate conduct, actions or omissions that could constitute breaches or from which there may be indications of non-compliance with applicable legislation and the internal regulations established by the SIX-BME Group, as well as any form of discrimination or harassment in the workplace (hereinafter "conduct and non-compliance").
BME's Information System shall be applicable to employees, as well as to clients, suppliers and other interested parties who have a relationship with BME or any of its Group companies, who detect conduct and non-compliance in an employment or professional context and report them through the channels provided in BME's Information System (hereinafter "reporting persons").
Internal reporting channels and means of communication
The internal communication channels will be, in accordance with the regulations in force, the preferred means of information. BME´s Information System integrates the following reporting channels:
Whistleblowing channel for reporting irregular or potentially inappropriate conduct, actions or omissions that could constitute breaches or from which there may be indications of non-compliance with applicable legislation and the internal regulations established by the SIX-BME Group
Channel enabled to report conduct that may constitute any form of discrimination or labor or sexual harassment, in the workplace.
The reporting/complaining through the above channels could be done:
In writing through the following means:
E-mail to Compliance Spain: canaldedenuncias@grupobme.es
Communication through BME Integrity Line tool available at: Integrity Platform - SIX, to which only Compliance Spain personnel have access.
The tool provides the option of communicating and processing information anonymously.
By means of a physical meeting with Compliance Spain at the request of the reporting person, within a maximum period of seven (7) calendar days from the communication.
Essential principles of the management procedures:
Internal procedures for managing the information received through the reporting channels integrated in the BME´s Information System are based on the following principles:
Confidenciality
BME ´s Information System is designed and managed in such a way as to guarantee the confidentiality of the information reported, the identity of the reporting person, of any third party mentioned in the communication, as well as of the actions carried out in the management and processing of the same.
Information on personal data protection
The protection of personal data will be guaranteed, preventing access to them by unauthorized personnel.
Information on personal data protection can be found at the following link.
Prohibition of retaliation
Persons reporting or disclosing information within the scope of the BME Information System, through any of the channels made available to them, shall be entitled to protection provided that they act in good faith and have reasonable grounds to believe that the information is true at the time of communication, even if they do not provide conclusive evidence.
Acts constituting retaliation, including threats of retaliation and attempted retaliation against persons who report information under the BME Information System are expressly prohibited.
Protection of persons concerned
The persons concerned by the communication shall have the right to the presumption of innocence, the right of defense and the right of access to the file. They shall be equally entitled to the same protection established for reporting persons, preserving their identity and guaranteeing the confidentiality of the facts and data of the procedure.
External reporting channels
The commission of any actions or omissions that may constitute a violation of the above may be reported through the external information channel of the competent authority: Autoridad Independiente de Protección del Informante (A.A.I.) or through the corresponding regional competent authorities:
Breaches of European Union law provided that they fall within the scope of the acts listed in the Annex to Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, when they affect the financial interests of the EU and have an impact on the internal market, as referred to in Article 325 and 26.2 of the Treaty on the Functioning of the European Union.
Serious or very serious criminal or administrative breaches of the Spanish legal system.
Breaches falling within the scope of Directive (EU) 2019/1937 of 23 October 2019 may also be reported to the relevant institutions, bodies, offices or agencies of the European Union when they affect the interests of the European Union.