Whistle Blowing System

In implementing ECG, Generandi is transparent and fair in receiving and managing violation reports through the Whistleblowing System.

Whistleblowing System (WBS) is a reporting tool for GENERANDI personnel in particular and the public to report any behavior or actions that are indicated to violate the code of ethics, ECG principles and applicable regulations both internal to GENERANDI and applicable legislation carried out by GENERANDI personnel.

WBS Policy

The GENERANDI Whistleblowing System policy has been regulated in GENERANDI by internal Circular Letter which regulates the system, mechanism and procedures for handling reports of indication of violations that are managed confidentially and independently.

Report Filing

Any indication of violation can be filed as a report through the following:

1. Written Letter: Orense, 70, floor 11, 28020, Madrid, Spain To the Attention of WBS Team.
2. Email: teescuchamos@generandi.com
3. Website : generandi.com

WBS Socialization

GENERANDI WBS socialization has been implemented to Internal Parties (GENERANDI Employees) and External Parties, such as:

1. WBS policy information to all employees through GENERANDI internal portal.
2. Poster campaign on WBS information at the Branch Offices.
3. Implement WBS e-learning to all GENERANDI employees.
4. WBS information through the Company website.

Whistleblowers Protection

GENERANDI provides protection to whistleblower for confidentiality of personal data and information reported. Provision of protection is also given to internal reporters from pressure, postponement of promotions, discrimination, dismissal, and physical actions.

WBS Reporting Mechanism

1. The reporter submits a report on indications of violation through a determined procedure.
2. Report on indication of violation are accepted by the Whistleblowing System Team.
3. The Whistleblowing System Team will investigate reports of indication of violation and the result of the investigation is shared with the Managing Board.
4. The Managing Director will report periodically.

Complaint Management

The WBS Team is under the Managing Director and monitored by the Board of Directors.

WBS Report

WBS annual report should be make public to the stakeholders in the Company Webpage.