1. Irregularity Reporting Channel

Centro Canalejas Madrid, S.L.U. (hereinafter, the “CCM”), in compliance with Law 2/2023, of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption, derived from the Transposition of Directive EU 2019/1937 of the European Parliament and of the Council of 23 October 2019, makes available to its employees and its stakeholders a Channel for Reporting Irregularities (hereinafter, the “Channel”).

The Channel has been set up so that, if there is certainty or well-founded suspicion that unlawful conduct is being committed within CCM, related to actions with criminal relevance or in breach of the Code of Ethics, breaches of European Union law, criminal, labour or serious or very serious administrative offences, it is confidentially transferred for investigation, constituting an effective means of preventing and combating such conduct and anticipating or mitigating its consequences.

The Channel incorporates mechanisms that guarantee the confidentiality of all information and offers a secure communication space to maintain contact with CCM’s compliance bodies and allows interaction between CCM and whistle blowers anonymously, without suffering reprisals of any kind.

Thus, it reaffirms CCM’s commitment that any illicit activity reported, and which may have been committed by CCM, any of its employees, executives, or members of the Board of Directors, will be treated confidentially and will be rigorously investigated, and the appropriate measures will be adopted in accordance with internal and external regulations.

Communications submitted through this Channel should be about:

• Infringements in criminal compliance
• Violations of the Values and Code of Ethics and Conduct, and CCM’s internal policies and procedures.
• Harassment (harassment at work, bullying, sexual harassment, harassment on grounds of sex, discrimination at work)
• Protection of personal data
• Prevention of money laundering
• Labour
• Other infringements

The Channel is available to employees and former employees, managers, interns, trainees, workers undergoing training, regardless of whether they receive remuneration, as well as to those whose employment relationship has not yet begun, suppliers, collaborators, or business partners of CCM.

This Channel is not the appropriate space for customer or third-party complaints.

The system is available 24 hours a day, 365 days a year, from any device through the following link

At the request of the interested party, communications may also be submitted by means of a face-to-face meeting with the CCM Channel Manager by sending the request to the following email address: cumplimiento@centrocanalejas.es

Without prejudice to the avenues of access detailed above, the interested party may contact the Independent Authority for the Protection of Informants.

2. Code of Ethics

The professionals at Centro Canalejas Madrid, S.L.U. carry out their work in compliance with the Law and the highest ethical standards.

This Code of Ethics responds to CCM’s desire to comply with current regulations and international quality standards, as well as with professional ethics.

It includes the principles and values, as well as the catalogue of rules of conduct and general guidelines for action applicable to all employees and persons directly or indirectly related to CCM. It constitutes a guide for action to ensure appropriate behaviour in the professional performance of employees.

The Code of Ethics reflects CCM’s principle of due diligence, in line with the measures adopted in relation to regulatory compliance and the desire to reinforce the commitment of CCM’s governing bodies and senior management to promote, encourage and disseminate their full commitment to compliance with current regulations and legislation.