The Whistleblower Channel is a means of PUERTAS BAMAR to facilitate the agile and confidential communication of irregularities that may involve non-compliance with regulations. Communications can be made anonymously.

PUERTAS BAMAR makes this Channel available as part of the Internal Reporting System and is essential for compliance with the Code of Ethics and Conduct in general and internal regulations in particular and, therefore, is an active part of our continuous improvement as a company.

PUERTAS BAMAR’s Internal Information System has been designed in accordance with the requirements of Organic Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption, which protects all those natural persons who, through the Channel available here or any other referred to in the aforementioned law, report the commission of serious or very serious administrative infringements, as well as criminal conduct, as can be seen in Article 2 of the aforementioned law.

Communications submitted through the Channel must deal with acts or conduct, present or past, relating to the areas of application of the Code of Ethics.

In particular, the Channel offered by PUERTAS BAMAR is available to counselors, employees, trainees, personnel of Temporary Employment Companies (ETT), agents, mediators, collaborators, prescribers, suppliers and persons working for or under their supervision, shareholders, former employees (employment relationship ended), and job candidates.

This channel is not the appropriate channel for customer complaints.

The system is available 24 hours a day, 365 days a year, from any device and in several languages, through the following access routes:

• E-mail: canaldedenuncias@bamarpuertas.com
• Postal address: Carretera Cuéllar Olmedo km. 16,5 – C.P. 47420 Íscar (Valladolid)

At the request of the interested party, complaints may also be submitted by means of a face-to-face meeting, and the request must be addressed through one of the aforementioned communication channels.

Without prejudice to the avenues of access detailed above, the interested party may contact the Independent Whistleblower Protection Authority.

Principles of action and guarantees

PUERTAS BAMAR’s Whistleblower Channel has a series of principles and guarantees:

Authority and Independence

The company’s Whistleblower Channel is managed by the Compliance Committee.

Partial outsourcing of management

In order to reinforce the independence, objectivity and respect for the guarantees offered by the Whistleblower Channel, the whistleblower management process is partially outsourced to an external expert, which reinforces the objectivity and due treatment of all complaints.

Complaints are resolved using a rigorous, transparent and objective procedure, safeguarding in all cases the confidentiality of the interested parties.

Confidentiality

The duty of confidentiality is configured as a guiding principle that guides the actions of PUERTAS BAMAR in the management of complaints.

Access to the information is restricted to persons with management powers according to their assigned functions, and it is expressly forbidden to disclose any type of information about the complaints.

Anonymity and non-traceability

Complaints can be either nominative, i.e., with identification of the complainant, or anonymous.

At PUERTAS BAMAR we maintain a firm commitment to respect anonymity when this is the option chosen by the complainant.

The tracking and tracing of anonymous complaints is prohibited. Violation of this will result in appropriate disciplinary action.

Confidentiality of the complainant’s identity

In the case of nominative complaints, the identity of the complainant is not disclosed, in any case, to the complainant, and is only disclosed to the other areas involved in the management when this information is essential to carry out the investigation of the facts/behavior. The disclosure of the whistleblower’s identity requires, in any case, prior consent of the whistleblower.

The disclosure of the identity of the complainant outside the permitted assumption or the carrying out of inquiries aimed at finding out data of complaints filed, regardless of the position and functions, will entail the imposition of the appropriate disciplinary measures, if applicable.

Prohibition of retaliation and whistleblower protection

At PUERTAS BAMAR we reject and do not tolerate any type of retaliation, in any form, against persons who file a complaint, as well as against those who participate or assist in the investigation of the complaint, as long as they have acted in good faith and have not participated in the reported act.

In order to ensure compliance with this principle, the necessary measures shall be taken to guarantee the protection of the whistleblower. In the event of circumstances that make this advisable, mitigating measures shall be taken to isolate and/or transfer the complainant from his or her workplace.

Rights of the defendant and of the affected persons

The accused and persons who may be affected by an internal investigation have the right to be informed of the complaint made against them as soon as the appropriate verifications have been carried out and the case has been admitted for processing.

For more information on the PUERTAS BAMAR Complaints Channel, please consult the Information Management Procedure.