Whistleblowing Channel

The Group Whistleblowing Channel is managed by the Regulatory Compliance function (Group and Regulatory Risk Management), that reports to the Compliance Department and this.

As it is detailed in the our Corporate Policy on Compliance , the mission of the Regulatory Compliance Function is to identify and supervise the risks of sanctions or financial losses to which the Entity is exposed, as a result of the breach of compliance with laws and oyher regulations relating to the scope of action as well as to advise and assist the senior management and the Governing Bodies in relation to regulatory compliance.

Its mission is articulated through the supervision of the Compliance Risk derived from the processes and activities carried out; the encouragement and promotion of corporate values and principles as well as the promotion of a culture of control and compliance with the laws and current regulations (both external and internal) that allows and favors their integration into the management of the entire organization.

In order to strengthen the independence, objectivity and respect for the guarantees offered by the Channel, part of the handling process (the reception and pre-admission) is performed by external experts, reinforcing the objectiveness and due management of all disclosures.

Disclosures are resolved by using a rigorous, transparent and objective procedure, safeguarding in all cases the confidentiality of the interested parties.

The duty of confidentiality is configured as a principle for the guidance the actions of the management of disclosures within the Compliance Department.

It is prohibited on disclosing any information on the content of the disclosures to third parties, whereby only to those persons directly involved in the handling process are aware of the content.

Disclosures can be made on an anonymous basis, without the identification of the whistleblower or otherwise.

Whenever a disclosure is made anonymously, we will maintain a firm commitment with the option taken.

Tracking and traceability of anonymous disclosures is prohibited. Violation of this point will entail the adoption of the corresponding disciplinary measures. To ensure this, we have established the appropriate IT means to guarantee the automatic deletion of access to the Whistleblowing Channel.

In the event of disclosures about a specific person, the protection of the identity of the whistleblower is guaranteed and will not be disclosed to the party being reported under any circumstances. The name of the whistleblower will only be disclosed to the Departments that require it to investigate the case/conducts. In all such cases, the prior consent of the whistleblower will be required.

The disclosure of the identity of the whistleblower outside of the permitted assumption or the carrying out of investigations aimed at finding out the data of the disclosures presented, will imply, in the case it is required, the imposition of the appropriate disciplinary measures regardless of the position and functions.

Any form of retaliation against whistleblowers, as well as against persons participating or assisting in the investigation of a disclosure, is rejected by CaixaBank’s Group and will not be tolerated, provided that they have acted in good faith and have not participated in the act reported.

So as to ensure the fulfillment of this principle, CaixaBank will take any requires measure to ensure the whistleblower’s protection. In that sense, in case the reporting party and the party being reported share the same workplace, measures may be adopted such as whistleblower’s transfer or isolation from its workplace.

The person reported as well as any other person impacted by an eventual internal investigation has the right to be informed of the disclosure made against him/her as soon as the suitable checks have been made and the case file has been opened for processing.