Internal whistleblowing channel

Additional information Welcome to Pacadar's internal whistleblowing channel. Please fill-in the following form, stating any relevant allegations. The complaint and all information you include on this form will be treated on a strictly confidential.

Details of the complainant
Relationship with the company

Do you work for Pacadar?

If you do, please state the department you work in and your position:

If you do not work directly for Pacadar , are you employed or engaged by another Pacadar Company or by a Group subcontractor or supplier?

If so, please state which:

Complaint details

Do you wish to be updated on the complaint process? If so, please state how you wish to be notified:

Can you identify any person or persons as the perpetrators of or as the people responsible for the events being reported?

*Please explain the facts alleged clearly and concisely (What happened, who you think is responsible, where it happened, how and when you found out, is an isolated fact or recurrent, etc.):

Have the events you are reporting already happened or are they going to happen in the future?

Where did or will the event reported occur?

Is the event reported an isolated incident or is it a recurring event?

When, how and why did you become aware of the event reported?

Evidence of the allegation

Do you have any evidence regarding the allegations?

If so, please explain what evidence you have:

Click the "Add Files" button to select files you want to attach a file to the complaint. Once you have added all the files click the "Attach" button.

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Extensions allowed: .pdf, .doc, .docx, .rtf, .jpg, .jpeg, .png
Maximum 10 files, maximum size per file: 2Mb.

Do more people know about the events being reported?

If so, please enter their details:

Additional information

Regarding the act reported, have you contacted anyone in the company from Pacadar or anyone from Pacadar?

If so, please state who you have contacted about this matter:

Have you reported the incident to the police or the courts?

If so, please state who you reported the events to and the date, as well as any other reference data you may have (report number, court proceeding number...):

Are you experiencing any type of reprisal or have you been threaten or coerced by any person as a result of the complaint?

If so, please provide a detailed description of said reprisals, threats or coercion and the names of the person or people involved:

Send complaint

* Required fields

*Select the company affected by the events you plan to report:

INFORMATION: Welcome to Pacadar's internal complaint channel. To file a complaint you must first select the group company to which the complaint refers.

Filing complaints via the Complaint Channel will be performed in accordance with the provisions of Pacadar 's Code of Conduct and, in any case, subject to the provisions of the Complaint Channel Rules and Privacy Policy which you must read and accept. It is also advisable to read the FAQs section, which provides answers to some of the issues that most frequently arise.

If, after reading the provisions of the Code of Conduct, the Complaint Channel Rules and the Frequently Asked Questions (FAQs) section, you still have queries regarding the operation of the Complaint Channel or specific facts about which you are hesitating to file a complaint, you can contact PACADAR Ombudsman, Christian Mesia Martínez (outsourced legal consulting firm for Pacadar), by calling +34.91.447.92.90 or +34.629.133.082 or by sending an e-mail message to or a letter addressed to Montalban street, numer 7, Madrid (28014).

Edificio Torre Espacio Paseo de la Castellana 259D 28046 Madrid Spain

Performance standards of the complaint channel

ONE.- Basic business principles for the formulation of internal complaints
People who decide to file an internal complaint must do so in good faith, with scrupulous respect for truth, with the conviction that they are acting properly and only benefit of Pacadar, the State and / or society in general. Making false complaints, be contrary to the law and the principles and values ​​of Pacadar is expressly prohibited.

TWO.- Reportable acts
Through the internal reporting channel only the commission of acts contrary to law within any of the company of Pacadar or to the detriment of these and violations of its code of ethics (hereinafter Acts Reportable plural, or Reportable Made in singular) may be reported.

THREE.- Reportable People
Administrators, managers, employees, consultants, subcontractors, distributors as well as the suppliers or dealers working for Pacadar, as well, as any other person or entity with which the company's belonging the group have a conttractual relation or precontractual bussiness, labour or administrative relation are persons susceptibles of being claimed against through the internal reporting channel.

FOUR.- Persons who may report
All bounded person by Pacadar 's the code of ethics or Individual subject, as defined in Item 2 of the Code, has the inexcusable obligation and legal duty to report internally any Reportable Made of having knowledge. Without limiting the foregoing, you may also make an internal complaint any person having knowledge of the commission of a Reportable Made without holding the necessary condition of Individual Subject.

FIVE.- Procedure for handling complaints

5.1. Complaint
Any internal complaint shall contain, at a minimum, (i) the name of the company Pacadar Group to which it relates; (ii) information identifying the denounced person; and (iii) the allegations, specifying, to the extent possible, the suspected infringement. Complaints may be made only in Spanish or English, and in writing. No internal complaints may be made by phone or by email, or by any other channel other than those set forth in these Rules.

5.2. Prima facie evidence capable
Any person making a complaint shall be prima facie evidence to substantiate the same, so their complaint must be accompanied by a principle of proof of the facts, at least circumstantially. It will be considered a prima facie valid any possible probative evidence in law, preferably in documentary support, but will also be admissible evidence, including witnesses' testimony of the complainant-own instruments and play of words, images and sounds. In any case, any evidence must have been obtained by the complainant in a lawful manner, ie, with respect to the law and constitutional rights and principles.

5.3. Admissibility
Complaints will only be admissible in the case of complying with the provisions of these Rules.

5.4. Correction of defects
If you committed a rectifiable defect in formulating the report you will be granted a period of ten (10) working days of the complainant to remedy the defect, warning in this case you may proceed to file the complaint on the assumption that the defect is not adequately remedied within the time allowed.

5.5. Filing
If the complaint does not comply with the provisions of these Rules, for whatever reason, or if he had not made the correction of the defects in the complaint, we will proceed to file the same.

5.6. Opening of file
If the complaint proves to be admissible, the Compliance Officer shall open a file which may be carried out such actions appear appropriate and use the tests as may be necessary for the proper elucidation and determination of the facts. The deadline for application processing shall not exceed two (2) months from the date of opening.

5.7. Conclusion of the record
Application processing will conclude with a report of the Compliance Officer where it will be noticed the actions carried out, the evidence taken and the facts that may be considered accredited, noting the recommendations as they need to perform.

5.8. Submission of the report
The report of the Compliance Officer will be submitted to the General Director which may take any legal action they consider appropriate.

5.9. Notification to the person or persons reported
The person or persons alleged to acquaint that have been reported and should be notified of the existence of the complaint and a summary of the allegations as soon as possible and in any case within a maximum period of three (3) months after the complaint was received. The notice to the person or persons accused is directed not include details of the complainant, in accordance with the provisions below in sixth standard.

SIX.- Confidentiality
Rules, the processing of the same will be held in confidence, ie, keeping strict secrecy and confidentiality of the identity of the complainant. The data may be disclosed only complainant, if any, to the competent public authorities in the investigation of the facts. Notwithstanding the foregoing, if as a result of the investigation of a complaint becomes evident that this is false or if the complainant had acted in bad faith or flagrant breach of these Rules, regardless of the legal measures the company could adopt regarding details of the complainant may be revealed to the person accused, if it so wishes, in return, initiate appropriate legal actions.

SEVEN.- Anonymous complaints
Anonymous complaints will be accepted for processing.

EIGHTS.- No Retaliation
Retaliation, threats and coercion against persons who make good faith complaints internal categorically prohibited. To ensure this, a complainant has the right to go to the Compliance Officer in order to obtain guidance and protection from reprisals that might be suffering for the sake of have made an internal complaint.

NINE.- Acceptance of Rules and Privacy Policy
The formulation of an internal complaint implies full and unreserved acceptance of any kind of these Performance Standards and acceptance of the internal reporting channel as well as the corresponding Privacy Policy.

Frequently Asked Questions (FAQs)

What is the internal channel complaint?
A whistleblowing channel is an internal complaint mechanism of the company that serves anyone to bring this to the attention of the commission of acts contrary to the law or to their detriment and possible violations of its ethical code of ethics.

May you file a complaint anonimously?
Yes. To be able to make a complaint through this internal mechanism it is not necessary for the complainant to identify with your name and your number of National Identity, Foreign Identification Number or Passport number and nationality.

What guarantees does the person making an internal complaint has?
The company guarantees, first, that the handling of complaints will be held confidential, ie, keeping secret the identity of the complainant, whose data may only be disclosed, as appropriate, to the competent public authority for research of facts. Secondly, the company will pay the complainant not be retaliated against for the sake of making a complaint, quite the contrary. The report made in good faith and to reveal any irregularities that may be committed in the company is always welcome. The complainant also has the right to go the Compliance Officer and / or Director of the Legal Department to give it protection and for guidance and advice regarding how to act to defend against possible retaliation. Third, the complainant is guaranteed to treat your complaint will be performed independently of the company and absolutely professional manner by a specialized law firm.

May an act be filed without any evidence?
The only accepted complaints are founded on the existence of reasonable suspicion of the commission of an illegal act and / or contrary to the ethical code of ethics and, therefore, it is essential that they are supported by evidence, preferably documentaries. Although they are also admissible testimonial evidence-including testimony from complainant-own instruments and play of words, images and sounds. In any case, it is important to note that it is essential that the evidence was obtained by the complainant in a lawful manner.

What if an allegation is false?
Complaints must be true, must be in good faith and comply with the provisions of the operating rules of the complaint channel. It should be noted that making false allegations could constitute libel and slander. The company may take legal action as appropriate against the person who makes a false or bad faith allegation and, in the case of false allegations, the accused may even reveal the details of the person who has made a false report that one can if deemed appropriate, take legal action against it.

Will the reported person or persons be informed about the claim against him/her or them?
A claim against and, therefore, as soon as all the verifications and enquiries have been done within three (3) following months to the receival of the claim, the company will inform the offender the existance of a claim against him/her or them accompanied by a summary of the facts ha has been accused of. Except the false claims cases, the offender will not receive the personal data of the person who claimed against him/her or them.

Is there any time for completion of an internal complaint?
According to the rules of proceeding of the internal reporting channel, the deadline for completion of such file/record may not exceed two (2) months counting from the day of its reception.

Which consequences may the internal report have in case it is confirmed by the Commission, the existance of solid evidence which prooves the commission of an ilegal act?
In case there is solid evidence of the commission of an illicit act within the company or in its detriment of an act or several acts which contravene the law or the comany's code of ethics, the company will, first, immediately adopt all the necessary measures to bring to an end suchs acts or to avoid them from happening. Afterwards, depending on the seriousness of the actions, the company may decide as well to initiate any legal actions against the persons or persons allegedly responsible filing a complaint or lawsuit in the courts, the prosecution or the Forces of State Security.

Privacy Policy

For the purposes of the provisions of Law 15/1999 of December 13, related to the Protection of Personal Data, Pacadar informs its users of the Internal Reporting Channel (hereinafter "Users") about the existence of a file of personal data duly registered in the General data Protection Registry, created with information provided to it through this internal reporting channel, by and for the company, and under its responsibility, in order to handle complaints which are formulated internally by allegedly committing against the law within the Group or prejudice and breaches of this code of ethics of Pacadar.

Users who make an internal complaint expressly accept the inclusion of data provided through the internal reporting channel in the automated file of personal data referred to in the preceding paragraph.

Also, users give their consent their personal data can be transferred or communicated to the Security Forces of State Security, other Public Administration bodies with powers to investigate the allegations and the Courts as well as other jurisdictional organs.

Pacadar is committed to respecting the confidentiality of the data included in the file and use it in accordance with its purpose, and to comply with its obligation to keep it and adopt all necessary measures to prevent alteration, loss, treatment or non authorized acces in accordance with the provisions of the regulations.Pacadar will maintain the confidentiality regarding the data of users who formulate internal complaints, preventing access to them by those who have been reported.

Notwithstanding the foregoing, in the event that a complaint is found to be false, Users are informed that their data may be communicated to the person or persons reported so that they can, if they deem it appropriate, initiate legal action assist them by reason of the false report.

Holders of personal data included in the file referred may exercise with respect to, the rights recognized in Law of Protection of Personal Data, and in particular the rights of access, rectification and cancellation; and the right of objection, whenever it deems to be relevant.

The rights referred to in the preceding paragraph may be exercised by each holder by sending an e-mail to

Users and other holders of personal data included in the file classified as "Internal Reporting Channel" are informed that Christian Mesia is an external legal consultancy working for which is held responsible for processing the data of such mentioned file which has been mandated to attend, on behalf of Pacadar , all the requests of those individuals whose rights of access, rectification, cancellation or opposition have been damaged.

In any case, as provided in Article 25 of Royal Decree 1720/2007 of 21 December, approving the Regulations implementing the Organic Law 15/1999 of 13 December on the protection of character data is passed staff, to holders of personal data included in the file that the exercise of such rights shall indicate at least the following information:

  • a. Name and surname, photocopy of your national identity card or passport or other valid form of ID and, where appropriate, the person representing him, and the document evidencing such representation.
  • b. Petition in which the request is specified.
  • c. Address for correspondence, date and signature.
  • d. Documents of the request being made, where appropriate.

For more information on the protection of personal data it is highly recommended visiting the Spanish Data Protection Agency website or get in contact with it through its citizen service is recommended, dialing 901 100 099.

Thanks for sending your complaint

Your complaint will be handled according to the procedure laid down in the Code of Conduct.