Compliance Portal

The communication must contain factual elements from which at least a well-founded suspicion of infringement can reasonably be derived. To do so, it must include, among others, a detailed description of the possible non-compliance, the identity of the people or entities involved in the possible illicit conduct, as well as the dates on which the alleged infractions took place.

Generic or indeterminate questions will not be admitted.

The channels enabled for the communication of possible violations are the following:

• Postal mail, expressly indicating on the outside of the envelope “ To the attention of the Compliance Body ” at the following address: Plaza de Cánovas del Castillo, 3, 28014 Madrid.
• By email:Click here to show mail address
• Through the form below.

You can freely decide whether you want to reveal your identity or not. In the case of email and the form, an email will be requested from you in order to acknowledge receipt of your communication (unless you expressly request otherwise) and to obtain additional information from you if necessary.

Once the communication is received through any of the enabled channels, an acknowledgment of receipt will be sent to you within five business days of receipt unless you have expressly waived receiving communications related to the investigation.

Next, a preliminary analysis will be carried out to verify whether the facts or conduct set out in the communication constitute an infringement, which may result in:

• The inadmissibility of the communication (because the facts lack plausibility, do not constitute an infringement, etc.).
• Admission for processing.

In both cases, you will be notified of the decision taken within the following five business days (unless the communication was anonymous or you have opted out of receiving notifications).

Furthermore, in the event that the facts could indirectly constitute a crime, they will be immediately sent to the Public Prosecutor's Office.

Within a period of no more than three months from receipt of the communication, with the exception of those cases of special complexity that require an extension of the period up to a maximum of another three months, you will be informed of the actions undertaken.

During this period, the communication will be investigated, informing the affected person, when applicable, of the actions or omissions attributed to them, who will have the right to be heard at any time.

The resolution of the communication will adopt the archiving of the communication, the referral to the Public Prosecutor's Office, the transfer to the competent authority or the initiation of a sanctioning procedure.

Fraternidad-Muprespa will treat both your identity and that of the possible infringer with confidentiality.

In any case, when you decide to submit a communication you can choose whether you want to preserve your anonymity or reveal your identity.

If you decide to maintain your anonymity, you can submit your communication through:

• Electronic format. It is recommended to access the Compliance Portal website from a device not linked to your work and free of viruses; In addition, it is recommended to access the website using anonymous browsing software and if documents are attached to the web form, you must ensure that it does not have metadata (properties with information about the author, company, etc.).
• Postal mail. In these cases you must ensure that data that could reveal your identity is not displayed, such as name and address, for example. Otherwise, your anonymity would not be guaranteed.

The use of the channels mentioned in this web portal, as well as the information and documentation you send, may mean that you provide personal data that will be processed by Fraternidad-Muprespa , who is responsible for the processing of said data.

Fraternidad-Muprespa has appointed a Data Protection Officer who you can contact if you have any questions about the processing of your personal data. His email is as follows:Click here to show mail address.

The purpose of data processing is that corresponding to each of the procedures detailed here.

The basis of legitimization of this treatment is compliance with a legal obligation derived from Law 2/2023, of February 20, on the protection of people who report regulatory infractions and the fight against corruption.

When there is a legal obligation, the information and documentation sent, and consequently, the personal data they contain, may be the subject of communications to third parties (among others, administrative or judicial authorities and the Public Prosecutor's Office).

The personal data provided will be kept for the time necessary to fulfill the purpose for which it is collected, and to determine the possible responsibilities that may arise from the purpose, as well as during the periods established in the archives and documentation regulations.

Current data protection regulations recognize the data owner with different rights, including the right to access, rectify and request the deletion of their data. For more information about them and the way in which you can exercise them, you should consult our Privacy Policy available on our website https://fraternidad.com/rgpd .

The communication of a possible infraction:

It will not constitute an infringement of any kind in the field of labor regulations by the communicating person, nor may it result in unfair or discriminatory treatment by the employer. If they are considered a victim of retaliation, the reporting person will send new communication through this same compliance portal.