Ethics Channel

The Ethics Channel is ISEG’s Internal Reporting System. It allows anyone connected with the company to report conduct that may constitute a breach, in full confidence and also anonymously.

It is governed by Spanish Law 2/2023 of 20 February, on the protection of persons who report regulatory breaches and on the fight against corruption, and by the internal procedure approved by ISEG’s management.

Submit a report

Open the Ethics Channel form

The form opens in Microsoft Forms. You can submit it without identifying yourself: ISEG does not receive or store your IP address.

Who can use it

  • ISEG employees, current or former.
  • Candidates in, or who have taken part in, a recruitment process.
  • Self-employed workers, contractors, suppliers and subcontractors.
  • Shareholders and persons with administrative or management duties.
  • Anyone working under the supervision of ISEG’s contractors or suppliers.

What can be reported

  • Breaches of European Union law.
  • Criminal offences.
  • Serious or very serious administrative offences.
  • Breaches of ISEG’s internal rules and Code of Conduct.

If you are not entirely sure about what you have seen, report it anyway. You do not need to provide evidence: it is enough that the information is true to the best of your knowledge.

How to report

You may use any of these three routes. All of them are handled in the same way and within the same deadlines.

Online form

The recommended route. Available 24 hours a day and in three languages. You may report identifying yourself, confidentially or anonymously.

Postal mail

Addressed to the Officer in charge of the Internal Reporting System, in a sealed envelope marked “Canal Ético — Confidencial”.

Iberian Sustainable Energies Group, S.L.
Responsable del Sistema Interno de Información
Polígono Industrial Empresarium, C/ Albardín, nº 9, Nave B-01
50720 La Cartuja Baja — Zaragoza — España

In-person meeting

You are entitled to request an in-person meeting with the Officer in charge of the System. It will be held within seven (7) calendar days of your request. You can ask for it in the last question of the form.

Identified, confidential or anonymous

When you submit your report you choose how you want to do it:

  • Identified. You give your name and contact details. Your identity remains confidential towards the persons concerned and towards the rest of the organisation.
  • Confidential. You give contact details but ask that your identity not be disclosed. Only the Officer in charge of the System will know it.
  • Anonymous. You provide no personal details at all. The report is handled in exactly the same way.

If you choose to remain anonymous and leave no contact details, we will not be able to send you the acknowledgement of receipt or tell you the outcome, because there will be no way to reach you. Your report will still be investigated, within the same deadlines.

What happens next

  1. Acknowledgement of receipt. You will receive confirmation that your report has arrived, within a maximum of seven (7) calendar days, unless doing so could jeopardise confidentiality or you have not provided contact details.
  2. Admission. We assess whether the facts fall within the scope of the channel and whether there are reasonable grounds. A decision not to admit a report is always reasoned.
  3. Investigation. The necessary enquiries are carried out, respecting the presumption of innocence of the persons concerned.
  4. Reply. The maximum time is three (3) months from receipt, extendable to six (6) months in duly justified, particularly complex cases.

Your safeguards

Confidentiality

Your identity will not be disclosed to the persons concerned or to the rest of the organisation. Only the persons set out in the procedure may access the file: the Officer in charge of the System and, where strictly necessary, human resources or legal services.

No retaliation

Any act of retaliation, threat or attempted retaliation against a person who reports in good faith, or against anyone who assists the investigation, is expressly prohibited. At ISEG this is treated as a very serious offence.

Presumption of innocence

Persons affected by a report retain their right to a defence, to their reputation and to the presumption of innocence.

Good faith

The law protects those who report with reasonable grounds to believe the information is true. Knowingly reporting false information falls outside that protection and may have consequences.

External channel

You are not required to use ISEG’s channel first. You may go directly, or subsequently, to the Spanish Independent Whistleblower Protection Authority (A.A.I.) or, where applicable, to the competent regional authority. Using the external channel does not cost you any protection.

Data protection information

Controller. Iberian Sustainable Energies Group, S.L. — Polígono Industrial Empresarium, C/ Albardín, nº 9, Nave B-01, 50720 La Cartuja Baja (Zaragoza), Spain.

Purpose. Receipt, recording, handling and investigation of reports submitted through the Internal Reporting System.

Legal basis. Compliance with a legal obligation (Article 6(1)(c) of Regulation (EU) 2016/679) arising from Law 2/2023.

Recipients. No data is shared with third parties, except with the judicial authorities, the Public Prosecutor or the competent administrative authorities where legally required. The form is hosted on Microsoft Forms, acting as processor.

Retention. Data is kept only for as long as strictly necessary. If three months pass from receipt without an investigation being opened, the data is deleted and the report is kept in anonymised form only. Investigated files are kept for as long as liabilities or actions arising from them remain unbarred, and never for more than ten years.

Your rights. You may exercise your rights of access, rectification, erasure, restriction, objection and portability by writing to lopd@iseg.es. You may also lodge a complaint with the Spanish Data Protection Agency.

Note. The identity of the reporting person is not disclosed to the persons concerned when they exercise their data protection rights.

Procedure for the Internal Reporting System and management of the Ethics Channel (Manual SGI MSG 06), approved by ISEG’s management.