Q: Will CUPA GROUP know my details as a complainant?
A: CUPA GROUP will not know your details as complaints can be submitted anonymously without any identifying information.
In those cases in which the complainant decides to identify him/herself confidentiality, the CUPA GROUP professionals who have access to your data are obliged to sign a confidentiality agreement that obliges them to keep the strictest reserve, secrecy and confidentiality of the information to which they have access. This obligation will remain in force even after the end of their professional services with CUPA GROUP.
Q: CUPA GROUP dismiss me because of a complaint made or take any kind of retaliation against me for this reason?
A: No, under no circumstances. CUPA GROUP may not, either during or after the investigation, take any action that would be detrimental to your professional career or that would lead to the termination of your employment or professional relationship with the company. Furthermore, CUPA GROUP will never know your details as they remain anonymous to the companyif the complainant want it that way.
In any case, the protection of the whistleblower will not exempt him/her from any liability that he/she may have incurred for acts other than those that are the subject of the complaint.
Q: What can I report through the whistleblowing channel?
A: In general, you can report any behaviour or conduct that is contrary to the code of ethics or internal regulations of the organisation, as well as any criminal or unlawful behaviour in accordance with the regulations in force at any given time. For example:
Actions related to suppliers: non-compliance with market procedures related to the selection of suppliers.
Harassment: abusive, hostile or offensive conduct.
Discrimination: discriminatory practices based on culture, political ideas, religious beliefs, race, gender or any other circumstance that may be considered a source of discrimination.
Restriction of freedom of expression, association, trade union or collective bargaining. Misappropriation and diversion of resources.
Accounting issues: recording commercial and financial transactions in a manner contrary to generally accepted accounting practices.
Conflict of interest: putting one´s own interests ahead of those of the company through improper actions in the exercise of professional duties.
Unethical conduct: dishonest or unethical conduct by any employee or professional acting on behalf of the organisation.
Commitments to third parties (customers/suppliers): non-compliance with agreements signed with third parties.
Falsification of documents: altering contracts, reports or documents for one´s own benefit or with the aim of causing detriment to the organisation.
Information security: unauthorised use of company, customer or supplier information.
Q: What happens to complaints once they have been made?
A: CUPA GROUP , through its professional experts in this area, will proceed to review and analyse all complaints. Once they have been catalogued and analysed, a report will be sent to the Compliance Committee in order to assess the appropriateness of an internal investigation and to decide on the measures to be adopted in the event that the facts reported constitute a criminal offence or any other type of offence or are contrary to the values and principles contained in the organisation´s code of ethics.