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Ethical Channel

At GRUPO EMPRESARIAL ENHOL, we firmly believe in the importance of fostering a safe, ethical, inclusive and trustworthy environment for everyone with whom we maintain a professional or employment relationship.

For this reason, we have implemented a robust Ethics Channel, composed of two subchannels (Ethics/Whistleblowing Channel and Harassment Protocol Channel), which allows any individual to report potential misconduct or ethical breaches identified within our organization.

This channel enables the communication of any possible non-compliance or irregularity within the organization, as established in Law 2/2023 of 20 February, regulating the protection of individuals who report regulatory infringements and combat corruption, as well as breaches of Grupo Enhol’s internal policies.

WHO CAN USE THE CHANNEL?

The channel may be used by anyone who has obtained information in a work-related or professional context linked to the organization, including:

  • Employees
  • Directors or members of governing bodies
  • Suppliers and contractors
  • Self-employed professionals
  • Former employees
  • Candidates in recruitment processes
  • Interns or volunteers

WHAT CAN BE REPORTED?

You may report any facts that you believe may constitute a breach of legal regulations, the Code of Ethics, or any applicable internal policies.

Two subchannels are available for reporting the following types of irregularities:

Ethics & Whistleblowing Channel

  • Law 2/2023-related matters
    • Fraud and corruption-related conduct
    • Workplace health and safety violations
    • Information security and data protection breaches
    • Anti-competitive practices
    • Human rights violations or environmental damage
    • Other serious or very serious criminal or administrative offenses
  • Code of Ethics and Conduct breaches

Harassment Protocol Channel

  • Sexual harassment or harassment based on gender
  • Moral or psychological harassment
  • LGTBI harassment
  • Sexual harassment policy (Peru subsidiaries)

CORE PRINCIPLES OF THE MANAGEMENT PROCEDURE

Confidentiality and anonymity
We understand that confidentiality is essential to encourage reporting. We guarantee full confidentiality throughout the process and protect the identity of the reporting person within the limits permitted by law. Anonymous reporting is also available.

Security
The channel incorporates technical and organizational measures to ensure the confidentiality, integrity and security of the information. Access is restricted to authorized personnel only, preventing unauthorized access or disclosure. Encryption and secure data storage mechanisms are applied.

Omnichannel approach
The channel allows reports to be submitted in writing or verbally, including the option to attach files. All options are integrated into a single system for coordinated and efficient management.

Impartial investigation
Once a report is submitted, our specialized team will investigate it objectively and diligently, in accordance with internal policies and applicable regulations. The rights of all parties involved, including the presumption of innocence, will be respected throughout the process.

Data protection
Personal data will be processed in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on Data Protection (LOPDGDD).

Protection against retaliation
We do not tolerate any form of retaliation against individuals who report in good faith. We are committed to safeguarding their rights and integrity. Disciplinary measures will be taken against anyone engaging in retaliation.

Diligence
Reports will be handled diligently. A resolution will be adopted within a maximum period of 3 months, except in particularly complex cases, where the period may be extended by up to an additional three months.

Resolution and follow-up
Once the investigation is completed, we will take the necessary actions to address the issue and, where possible, implement corrective measures to prevent recurrence. The reporting person will be informed of progress and outcomes whenever possible and legally permitted.

HOW TO SUBMIT A REPORT

There are two options:

Via the co-resol App

  1. Download the co-resol App (free on App Store and Google Play) and enable notifications
  2. Click and enter the code ENHOL
  3. Select the appropriate channel
  4. Write your message or record a voice note (be as specific as possible). You may attach files
  5. Identify yourself or choose anonymity. In both cases, accept the Privacy Policy
  6. You will receive an on-screen acknowledgment of receipt
  7. Follow-up communication will take place via a secure chat within the app 

Via the web platform

Access via:
https://canalco-resol.com

  1. Click “Make a click” and enter the code ENHOL
  2. Select the appropriate channel
  3. Write your message or record a voice note. Attach files if needed
  4. Identify yourself or choose anonymity and accept the Privacy Policy
  5. You will receive a unique ID and PIN, which must be saved securely to access follow-up communication
  6. To check updates or provide additional information, return to the website and select “Access a previous click”, entering the code ENHOL, your ID and PIN

Important

This Ethics Channel is not an emergency service.
It must not be used to report situations involving immediate danger.

If you require urgent assistance, please contact your local authorities and use the appropriate emergency channels.

Our company has received support from the Government of Navarre under the 2022 "Promotion of Digital Business in Navarre" initiative.

We have also been granted funding from the Government of Navarre through the 2021 call for competitiveness improvement aids.

Additionally, our company has received 50% co-financed support from the European Regional Development Fund through Navarre's FEDER 2014-2020 Operational Program.

We are also beneficiaries of 100% co-financed aid with REACT-EU resources, through the FSE 2014-2020 Operational Program of Navarre, as part of the European Union's response to the COVID-19 pandemic.

The presence of the European Union and European Social Fund (ESF) logos on this website and our social media channels reflects our commitment to transparency and adherence to dissemination regulations established in Article 10.1 of the Agreement of December 29, 2021, by the Governing Council of the Community of Madrid. This agreement regulates the direct granting procedure of subsidies from the Youth Employment Stimulus Program. We are proud to have participated in the 2024 call, specifically in Line 1, aimed at promoting stable youth employment in the Community of Madrid.

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