1. Purpose
The Ethics Channel is the internal information system that WASIM AVIATION, S.L. maintains to receive, register and act upon reports of conduct that may constitute:
- Breaches of European Union law within the material scope of Article 2(1) of Directive (EU) 2019/1937 — in particular, public procurement, financial services, prevention of money laundering and terrorist financing, product safety, transport safety, environmental protection, public health, consumer protection and the protection of privacy and personal data.
- Serious or very serious criminal or administrative infringements of Spanish law, including those involving financial loss to the public treasury or to the Social Security system.
- Conduct contrary to the company's Code of Conduct or to its internal policies on integrity, fraud, bribery, conflicts of interest, harassment or discrimination.
The channel is not intended for general customer-service complaints, technical support requests or human-resources matters without an integrity component — those should be addressed through the corresponding ordinary channels.
2. Who may use it
In accordance with Article 3 of Law 2/2023, the channel is open to any person who has obtained information about a possible breach in the context of a work or professional relationship with the company, including:
- Current, former and future employees of WASIM AVIATION, S.L..
- Self-employed contractors, freelancers, trainees and volunteers.
- Members of the administrative, management and supervisory bodies.
- Suppliers, subcontractors and any worker employed under their direction.
- Persons whose work-based relationship has not yet started, where the information was obtained during the recruitment or pre-contractual stage.
- Persons who assist the reporter, persons connected with them, and legal entities for which they work or with which they have any other type of relationship in a work context.
3. How to report
Reports may be submitted in writing, orally or, on request, in a face-to-face meeting. We accept the following channels:
- Email: TODO_FILL_ETHICS_EMAIL.
- Postal mail: a sealed envelope addressed to "Responsable del Sistema Interno de Información" at our registered office, Calle Camino de Caicena, 33, casa 1, 18008 Granada, Spain. Letters opened by mistake by anyone other than the responsible person will be re-sealed and forwarded.
- Face-to-face meeting: at the reporter's request, within a reasonable period and in a setting that preserves confidentiality.
Reports may be anonymous. Where the reporter chooses to identify themselves, their identity is treated as confidential information and may only be disclosed in the cases foreseen by Law 2/2023.
To facilitate investigation, please include in your report:
- A factual, dated description of the conduct.
- The persons or roles involved, where known.
- Any documentary or material evidence you may have.
- An indication of whether the same facts have been reported through other channels.
4. The process
4.1 Acknowledgement
Receipt of the report is acknowledged within seven calendar days, unless this would compromise its confidentiality. Where the reporter is anonymous, no acknowledgement is sent.
4.2 Admission and investigation
The Responsible Person assesses the admissibility of the report. Reports that are manifestly unfounded, fall outside the scope of Law 2/2023 or duplicate an earlier report without new elements may be archived with reasoned justification. Admitted reports are investigated diligently, in compliance with the principle of adversarial proceedings and with respect for the presumption of innocence and the honour of the persons concerned.
4.3 Outcome
The investigation is concluded and the reporter is notified of the outcome within a maximum of three months from the acknowledgement of receipt — or, where no acknowledgement is sent, three months from the expiry of the seven-day period — extendable by a further three months in cases of particular complexity.
4.4 Decisions
Where the investigation confirms the breach, the company adopts the corrective, disciplinary or contractual measures it considers appropriate, and refers the matter to the competent authority whenever the facts may constitute a criminal offence or a serious administrative infringement.
5. Anti-retaliation
No retaliation, direct or indirect, is permitted against persons who, in good faith, file a report through this channel, against their assistants or against persons connected with them. The following acts in particular are prohibited and will be addressed as serious breaches of the company's policies:
- Suspension, dismissal, demotion or denial of promotion or training.
- Negative changes in working conditions, schedule, location or remuneration.
- Coercion, intimidation, harassment or ostracism.
- Discrimination or unfavourable treatment.
- Harm to the person's reputation, in particular on social media.
- Termination of contracts of supply or services for retaliatory reasons.
Persons protected by Law 2/2023 enjoy the support and protective measures foreseen in Title VII of that Law, including the possibility of seeking advice from the Independent Whistleblower Protection Authority (Autoridad Independiente de Protección del Informante — A.A.I.).
6. Responsible Person and confidentiality
The administrative body of WASIM AVIATION, S.L. has appointed a Responsible Person to operate the Ethics Channel, with autonomous powers and the resources required to fulfil this function. The identity of the Responsible Person is communicated to the A.A.I. as required by Article 5 of Law 2/2023.
Access to the content of reports is restricted to the Responsible Person, to the personnel strictly necessary for the investigation, to the data-protection function, and to those legal advisers engaged for the matter. The reporter's identity, the identity of the persons concerned and the content of the report are kept confidential and are not disclosed to third parties except in the cases foreseen by Law 2/2023.
7. Personal data and record-keeping
Personal data processed within the Ethics Channel is treated under the legal obligation arising from Law 2/2023 (Article 6.1.c GDPR), and, where special-category data is strictly necessary, on the substantial-public-interest basis of Article 9.2.g GDPR. Data is retained only for as long as is necessary to decide whether an investigation is required, and in any event for no longer than ten years. The processing details, recipients, retention periods and rights are described in our Privacy Policy.
8. External reporting
In addition to this internal channel, any reporter may, at their option and without using it first, submit their report directly to the competent external channel:
- The Independent Whistleblower Protection Authority (A.A.I.) at state level, or the corresponding regional authority for matters within the powers of the Autonomous Communities.
- Other competent authorities (judicial, supervisory or administrative) when the facts so require.
- Where applicable, the institutions, bodies, offices or agencies of the European Union.
Public disclosure of the report (for example to the press) is protected by Law 2/2023 only in the limited circumstances foreseen in Article 28 of that Law.