Ethics channel

Delibreads has an Internal Reporting System in accordance with Spanish Law 2/2023 of 20 February on the protection of persons who report regulatory breaches and on the fight against corruption (Ley 2/2023, de 20 de febrero, reguladora de la protección de las personas que informen sobre infracciones normativas y de lucha contra la corrupción). The ethics channel is the means for reporting, with full safeguards, any irregularity you become aware of.

Who can use it

Anyone who has become aware of a possible breach in a work-related context connected with Delibreads: current staff, former employees, trainees and job applicants, directors and managers, as well as suppliers, contractors, customers and other third parties we deal with.

What can be reported

• Acts or omissions that may constitute breaches of European Union law.
• Criminal offences or serious or very serious administrative offences.
• Breaches of the Code of Ethics and internal rules, including, among others, in relation to corruption, conflicts of interest, money laundering, harassment or discrimination, health and safety, food safety or the environment.

You can also use the channel to raise questions or queries about the Code of Ethics.

How to report

Through the platform, in writing, either identifying yourself or anonymously. If you prefer to report verbally or at an in-person meeting, you can request this on the same platform; the meeting will be held within a maximum of seven days.

Safeguards

• Confidentiality of the identity of the whistleblower, of the persons concerned and of any third parties mentioned.
• The option of reporting anonymously.
• Prohibition of retaliation against anyone who reports in good faith.
• Processing of data in accordance with data protection legislation.

Time limits

• Acknowledgement of receipt within a maximum of seven calendar days of receipt.
• Response to the investigation within a maximum of three months, which may be extended by a further three months in particularly complex cases.

System Manager

Delibreads' Compliance Officer, appointed with autonomy and independence, oversees the Internal Reporting System and the application of the Code of Ethics.

External channels

You can also report to the Independent Authority for Whistleblower Protection (Autoridad Independiente de Protección del Informante, A.A.I.), to the competent regional authorities or to the institutions, bodies, offices and agencies of the European Union.

Data protection

Data reported through the channel are processed in order to manage the report and, where applicable, investigate it, in compliance with a legal obligation. They are kept only for the time strictly necessary and are erased after three months if no action is taken. Further information is available in the privacy policy.

Documents

• Code of Ethics and Conduct for Stakeholders (PDF in Spanish, version 01, August 2026)
• Corporate Policy