GHESA Ingeniería y Tecnología SA, hereinafter GHESA, through the email address compliance@empre.es   establishes its unique internal information channel, also known as the whistleblowing channel or ethics channel, and makes it available to its employees and third parties, so that they reveal any potential conduct that they consider could entail a breach of the principles contained in their Code of Ethics, in the internal or external regulations to which GHESA is subject, or in the legislation that is applicable to it.

Therefore, through this internal information channel, GHESA makes it possible to report and document any possible irregularity or behavior contrary to current legislation, in order to promote an investigation by its Compliance Committee of the reported facts, thus complying to Directive (EU) 2019/1937 of the European Parliament and of the Council, of October 23, 2019, to Law 2/2023, of February 20 and Organic Law 10/2022, of September 6. Along the same lines, through this internal information channel, GHESA also complies with Article 40 of its Code of Ethics, and point 8 of its Crime Prevention Manual,

GHESA guarantees that at all times both the confidentiality of the information communicated and the identity of the complainant will be protected and, therefore, it will not be communicated to the accused without their prior consent, guaranteeing the confidentiality of the complainant's identity and avoiding any type of response to him by the accused as a result of the complaint.

The information received through the address compliance@empre.es  it will be received by the secretary of the GHESA Compliance Committee to review and assess in the first instance whether the communication/complaint meets the minimum requirements of credibility, and good faith of the reporting person. Subsequently, based on the result of this assessment, the final investigation process would be settled within the GHESA Compliance Committee. 

In any case, communications must always comply with the criteria of veracity and proportionality, and this mechanism cannot be used for purposes other than those that pursue compliance with the standards contained in the GHESA Code of Ethics, and other internal or external regulations to to which GHESA is subject, including applicable law.  

Within a maximum period of seven calendar days, from the date of receipt of the communication, GHESA will send the reporting person an acknowledgment of receipt of the communication received. Subsequently, within a maximum period of three months, from the receipt of the communication, GHESA will respond on the actions of its investigation and, only exceptionally, when the complexity of the investigation justifies it, this period may be up to six months.

The communication that you make to GHESA through the email address compliance@empre.es IT MAY BE ANONYMOUS, and unless in your communication you indicate a different way to contact you, by default, the communications that we will send you from GHESA in relation to your complaint/communication will be made to the same email address, to through which you have contacted us.