The Whistleblowing Channel is a means of communication of the CaixaBank Group to facilitate the confidential and agile communication of irregularities that they may assume infractions. Communications may be submitted anonymously.
CaixaBank Group makes this Channel available as part of the internal information System and it is an essential part for the fulfillment of the Code Ethics as well as CaixaBank’s internal regulation, so, takes an active part in our continuous improvement process as a Group.
The communications through the Channel must deal with acts or conducts, present or past, referring to the areas of application of the Code Ethics which implies the general regulations and especially the following Rules of Conduct:
The Channel is available to directors, employees, interns, temporary staff, agents, brokers, collaborators, prescribers, suppliers and people working under their supervision and direction, shareholders, former employees, job candidates.
The system is accessible 24 hours a day, 365 days a year from any device and in several languages through the following channels:
At the request of the interested party, disclosures can also be presented through a face-to-face meeting, for which the request must be directed through one of the communication channels mentioned above.
Notwithstanding the detailed the interested party may contact the Independent Authority for the Protection of Informants (Autoridad Independiente de Protección del Informante).
The action principles and main guarantees offered by the Whistleblower Channel include the following:
The management of the Group’s Whistleblowing Channel is the responsibility of CaixaBank’s Regulatory Compliance function, which reports to the Compliance Department.
As stated in our Corporate Regulatory Compliance Policy, the mission of the Regulatory Compliance function is to identify and monitor the risks of sanctions or financial losses to which the entity is exposed as a result of non-compliance with laws and other regulations, as well as to advise and assist senior management and governing bodies on regulatory compliance matters.
Its mission is carried out through the supervision of Compliance Risk arising from the processes and activities undertaken; the encouragement, promotion and dissemination of corporate values and principles; and the promotion of a culture of control and compliance with applicable laws and regulations (both external and internal), enabling and fostering their integration into the management of the entire organisation.
To strengthen independence, objectivity, and respect for the guarantees offered by the Whistleblowing Channel, the complaint management process is partially outsourced to an external expert, which reinforces objectivity and ensures proper handling of all reports.
Complaints are resolved using a rigorous, transparent, and objective procedure, safeguarding the confidentiality of all parties involved at all times.
The duty of confidentiality is established as a guiding principle that directs the actions of CaixaBank’s Regulatory Compliance function in managing reports.
Access to information is restricted to individuals with management authority according to their assigned responsibilities, and the disclosure of any information related to reports is expressly prohibited.
Reports may be either nominative, meaning the whistleblower is identified, or anonymous.
At CaixaBank, we maintain a strong commitment to respecting anonymity when this is the option chosen by the whistleblower.
Tracking and tracing anonymous reports is strictly prohibited. Any breach of this rule will result in the adoption of the corresponding disciplinary measures. To ensure compliance, appropriate IT systems have been implemented to guarantee the automatic deletion of access logs to the Whistleblowing Channel.
In the case of nominative reports, the whistleblower’s identity is never disclosed to the subject of the report and is only shared with other areas involved in the management process when this information is strictly necessary to conduct the investigation of the facts or behaviours. Disclosure of the whistleblower’s identity always requires prior consent from the whistleblower.
Any disclosure of the whistleblower’s identity outside the permitted circumstances, or any attempt to obtain information about submitted reports—regardless of position or role—will result in the imposition of appropriate disciplinary measures, where applicable.
At the CaixaBank Group, we reject and do not tolerate any form of retaliation against individuals who submit a report, as well as against those who participate in or assist with its investigation, provided they have acted in good faith and have not been involved in the reported act.
To ensure compliance with this principle, all necessary measures will be taken to guarantee the protection of the whistleblower. Should circumstances so require, mitigating measures will be adopted to isolate and/or relocate the whistleblower from their workplace.
The person reported and any individuals who may be affected by an internal investigation have the right to be informed of the complaint filed against them as soon as the necessary checks have been carried out and the case has been formally admitted for processing.