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COMPLAINT CHANNEL POLICY

Complaint Management Procedure

OBJECTIVE

The main objective of the Complaint Channel is to prevent breaches and irregularities related to the principles and values recognized in the Foundation’s Code of Conduct and developed in the regulations that derive from it. Additionally, it aims to correct already identified breaches and irregularities, enabling the imposition of sanctions on the authors of the infringing conduct, without prejudice to the subsequent civil, administrative, or criminal liabilities that may arise. Therefore, it is guaranteed that all natural or legal persons connected to Arrels Fundació will be able to communicate to the Foundation, confidentially and without risk of retaliation, any breach or irregularity of which they are aware, as long as it is done in good faith.  This also includes any other illicit act or risk of committing one that could negatively affect Arrels Fundació in the provision of all its services.

 

FUNCTIONING

Who manages it?

The Channel is managed by a Monitoring Committee made up of the regulatory compliance officer, the director of the entity and its president, with the support of external professionals. Together, they are responsible for the processing and resolution of complaints.

 

How can complaints be submitted?

  • To submit a complaint, you can send an email to denuncia@arrelsfundacio.org, in which, in addition to the detailed account of the events you want to report, all relevant supporting documentation can be attached.
  • Complaints can also be reported in person to the head of department, the director of the entity or the regulatory compliance officer. The latter will then proceed to draw up a report of the events, which may be signed by the complainant and, if applicable, include a list of the provided documentation.

 

How should these complaints be?

Complaints cannot be made anonymously. The identification of the complainant with full names and at least one contact method is necessary. Arrels Fundació guarantees that no disciplinary measures or legal actions will be taken against the person making a good-faith complaint.

In addition, the identity of the person making the complaint will be considered confidential information and may not be disclosed without their consent, except in the unique exceptions provided by law and when essential for investigating the reported events.

 

Will the accused person be informed that there is a complaint against them?

Yes. The accused person will be notified of the existence of a complaint against them and its content. In all cases, the right to privacy, defense, and the presumption of innocence of the individuals subject to the allegations will be guaranteed.

The investigation and verification of the reported facts will be carried out with objectivity, impartiality and with the greatest discretion and confidentiality possible.

In the event of a conflict of interest with the regulatory compliance officer or any member of the Monitoring Committee, it must be immediately disclosed to the rest of the Committee, which, if deemed appropriate, will appoint another person in order to carry out the corresponding investigation.

 

What is the procedure once the complaint is received?

Once the complaint is received, the regulatory compliance officer will assign it a code and a report will gather the date of receipt, the information it contains and the resolution date, along with all the actions that have taken place to reach a conclusion.

The regulatory compliance officer will be responsible for processing all the received complaints. . After reviewing the complaint and, if applicable, the accompanying documentation, the complaint will only be archived without further investigation when the attributed facts are clearly unfounded or when they are not constitutive of any violation, irregularity, or offense affecting Arrels. In all other cases, the complaint will be investigated, and for this purpose, the compliance officer will:

  • Interview the person who filed the complaint
  • Interview possible witnesses
  • Interview the accused person
  • Receive evidence that the accused or the complainant consider appropriate to submit
  • Obtain other evidence through any reasonable and legally permissible means

The investigation will be carried out as soon as possible and, in any case, within 30 natural days.

Finally, the regulatory compliance officer will issue an investigation report that includes the facts, statements from the interviews, conclusions, and a proposed resolution, which will be communicated to the management of the entity, the accused person reported, and of the person who made the complaint.

The proposed resolution will be reasoned and justified and will include, if applicable, a proposal for disciplinary measures or sanctions, which will always be appropriate and proportionate to the breach or irregularity detected. If a criminal offense is suspected, it will be reported to the authorities.

 

What happens if a false complaint is reported?

When there are reasons or indications to suspect that a complaint has been submitted in bad faith, Arrels reserves the right to adopt the appropriate disciplinary and legal measures regarding the person who made the complaint.

Retaliation against any employee who has made a complaint is strictly prohibited. The prohibition of retaliation will not prevent the adoption of disciplinary measures when it is detected that the complaint is false and has been filed in bad faith.