General Policy Of the Ethical Channel



EDNON, S.L. (hereinafter the COMPANY) is committed to regulatory compliance, ethics, transparency and integrity and, to this end, has created an Internal Information System (hereinafter the “Ethical Channel”) in accordance with Law 2/2023, of 20 February, regulating the protection of persons reporting normative and anti-corruption offences (hereinafter “Law 2/2023”).


This Policy develops the general principles of the Ethical Channel and the guarantees that assist persons who make use of the Ethical Channel.




2.1 Personal scope: The Policy includes within its scope all the personnel of the COMPANY, as well as third parties that relate to the Organization, including in any case (hereinafter the “Interested”):



(i) Employees of the COMPANY.


(ii) The self-employed.


(iii) Shareholders, participants and persons belonging to the administrative, management or supervisory body of the Organization, including non-executive members.


(iv) Any person who works for or under the supervision and direction of contractors, subcontractors and suppliers with whom the COMPANY relates.


(v) Those workers whose employment relationship has already ended, volunteers, interns, workers in training, as well as those whose relationship has not yet begun, where information on infringements has been obtained during the pre-contractual selection or negotiation process.


In this sense, Data Subjects who make communications of violations will be referred to as the “Informants” in this Policy.


2.2 Material scope of application:

Under this Policy, the COMPANY makes available to all interested parties the Ethical Channel, as a confidential and/or anonymous channel to communicate information regarding possible violations committed within the Organization (hereinafter “Communications”):


(i) Falling within the scope of the European Union acts listed in the Annex to Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, on the protection of persons reporting infringements of Union law, irrespective of the classification of such infringements by national law;


(ii) Affecting the financial interests of the European Union as referred to in Article 325 of the Treaty on the Functioning of the European Union (TFEU);


(iii) Having an impact on the internal market, as referred to in Article 26.2 TFEU, including infringements of EU competition rules and state aid;


(iv) Affecting the internal market in relation to acts which infringe corporate tax rules or practices whose purpose is to obtain a tax advantage which distorts the object or purpose of the legislation applicable to corporation tax;


(v) may constitute a serious or very serious criminal or administrative offence. In any case, all serious or very serious criminal or administrative offences involving economic damage to public finances and social security shall be understood;


(vi) To deal with labour law in the field of occupational safety and health, without prejudice to its specific rules;


(vii) They involve the materialization of a criminal risk for the Organization, as well as breaches or weaknesses of the Criminal Compliance Management System, in accordance with the provisions of UNE 19601:2017.




The COMPANY offers the following means of communication:

  • Online. Through the web platform ETHICAL CHANNEL, accessible on the website of the COMPANY or by entering as User and Password the word CANALDENUNCIASEDNON
    • In writing.
    • Through a voice recording.
  • By post.
    • Sending the communication to the management of the company, addressed to
      A/A: President
  • In person. At the request of the Informant may also be presented through a face-to-face meeting within a maximum of seven days.
  • By depositing communication in a mailbox enabled for this purpose on the premises of the company, in a safe place and without security cameras.


The Ethical Channel is the preferred channel for reporting risks or irregularities identified. However, it is possible to submit the communication to the Independent Informant Protection Authority (“IAA”) or to the competent authorities or bodies of the autonomous communities

Regardless of the route used, the COMPANY will ensure compliance with the general principles and guarantees provided in this Policy and the Ethical Channel Procedure


Instructions for use of the platform


To access you must enter the User and Password credentials indicated above.


Once you have accessed the ETHICAL CHANNEL web platform, the Informant can choose to fill in the form or attach a voice file. Likewise, the Informant may choose to provide their contact details or remain anonymous.


In any case, it shall include a clear and detailed description of the facts. In addition, you will have the possibility to attach files that support the communication.


Once the communication has been made, you will see a tracking number that you must save. With this number, in the follow-up section, the Informant can know the status of the investigation.


Also, in the follow-up section, the Informant and the Ethics Committee may maintain a subsequent communication, even if they decide to remain anonymous. For this reason, the Informant is recommended to consult frequently in the follow-up section if he has received any communication from the Ethical Channel.





The Ethical Channel is an internal and collegiate body, which is governed by its own rules of procedure and acts with complete independence, autonomy and impartiality, and has the function of responsible for the Ethics Channel, in accordance with article 8 of Law 2/2023, is responsible for its management, as well as the diligent processing of investigation files and the proposal of measures, if any, applicable. In particular, there is an external company responsible for the management of the Ethics Channel and the processing of investigation files.



The general principles applicable to the COMPANY’s Ethics Channel are:


1. Confidentiality. The Ethical Channel guarantees the maximum confidentiality of the identity of the Informant and of the persons affected by the Communication (the “Denounced”), of the information communicated and of the actions that are developed in the management and processing of the same, preventing access to unauthorized personnel.


2. Anonymity. The Ethical Channel, at the choice of the Informant, allows the presentation and processing of anonymous communications and the possibility of communicating with the Informant during the investigation of the facts while maintaining his anonymity.


3. Right of the Accused to information. The Accused has the right to be informed of the acts or omissions attributed to them, to be heard at any time and to provide any evidence they deem appropriate, respecting the presumption of innocence and the right to honour. Without prejudice to the foregoing, this hearing shall take place in such time and in such manner as may be deemed appropriate to ensure the successful completion of the investigation. In no case shall the Accused be informed of the identity of the Informant.


4. Respect for the rights of the accused. The COMPANY guarantees that through the Ethical Channel the right to information, the right to defense, the right to a contradiction, the right to the presumption of innocence and the right to honor of all persons involved in the investigation is respected. They also have the right to be heard at any time, in the manner deemed appropriate, to ensure that the investigation is completed.


5.Prohibition of reprisals. The COMPANY guarantees the protection against reprisals of all persons who report violations that fall within the scope of the Ethical Channel, provided they have reasonable grounds to believe that the information referred to is true at the time of communication, even if they do not provide conclusive evidence. The protection also includes those other persons who may assist the Informant during the investigation, third parties related to it, as well as against companies owned by the Informant or with which he has any other relationship in a work or professional context.


6. Good faith and truthfulness of information. Communications made by the Informant through the Ethical Channel must be made in good faith and the information communicated must be complete and truthful.


7. Effective processing. Communications received through the Ethics Channel will be treated effectively. The Ethics Committee ensures that the investigation and resolution of the alleged facts are handled without undue delay and with due professionalism and diligence, so that the procedure can be completed in the shortest possible time and with due process.


8. Independence, autonomy, impartiality and regulatory compliance. The Ethics Committee acts at all times with independence, autonomy and impartiality and with the maximum respect for the legislation and internal regulations of the COMPANY.


9. Secret of communications: The Ethics Committee and any person involved in the investigation of the Communications must keep secret and act with the utmost discretion on the facts known to them during the investigation.


10. Support Measures. The COMPANY provides information and advice on the procedures and remedies available, the protection of the Informant from reprisals and the rights of the Denounced.


11. Transparency and accessibility. The COMPANY ensures at all times that all information on the Ethical Channel is transmitted in a clear and understandable way and is accessible to all interested parties.


12. Preferred Channel. The Ethical Channel is the preferred channel for making communications related to violations or breaches. If a Communication on violations is received through a channel not included in the Ethics Channel, the Communication must be sent immediately to the Ethics Committee, refraining from sharing this information with third parties.


13. Protection of personal data. The Ethical Channel is configured with full respect for the provisions on Data Protection, in order to duly protect the privacy and privacy of the persons involved and to guarantee the confidentiality of whoever formulates a Communication.


Santiago de Compostela, 29th November 2023.