Complaints Channel

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Recommendations for making complaints and inquiries about irregularities:

  1. Report any facts, omissions, and situations within the organization that may violate legal provisions and regulations or its code of ethics, or be detrimental to the interests of employees, collaborators, clients, or other interested third parties, as well as the company's own interests. Your goal is to help correct and improve behavior within the organization; refrain from using it to cause harm.
  2. Use language that is clear but respectful of people and truthful in your statements.
  3. Explain what is appropriate for the situation simply, be spontaneous and sincere, provide as much information as possible, and in a way that the facts can be verified and the situation managed to correct it.
  4. In your communication try to indicate the following contents:
    • - What are the irregular acts or omissions or those that violate the laws or internal rules of the company?
    • - How, where and when it has happened, is happening or will happen.
    • - Who are the witnesses, if any.
    • - How many times has it occurred or if it is an isolated event.
    • - What do you think could be the cause, reason or occasion that leads to it happening?
    • - Whether there were, are or will be economic values involved and their scope.
    • - If evidence can be found, what evidence can be found, and how to locate it.
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    Please attach any documentation you have that may help clarify or confirm the facts. These will generally be files in PDF, text (Word), and image (jpg/png) formats. Our information systems have antivirus and antispam barriers that will reject information and attachments that are infected or interpreted as such. Please ensure that the documentation you send us comes from a reliable source, and that the resource you are using (computer, tablet, mobile phone) is trustworthy.
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    Acceptance of the company's personal data processing policy:

    In accordance with current and applicable regulations on personal data protection, we inform you that your data will be incorporated into the processing system owned by GOSAN, S.A. with CIF: A48059950 and registered office at POL. IND. GRANADA, C-1 48530 ORTUELLA- BIZKAIA – Spain

    • - Purpose: Management and processing of obligations arising from compliance with the regulations and internal procedures and codes of the entity
    • - Retention period: Once the reason for the request has ended, GOSAN, S.A. will retain your personal data for the duration of the legal limitation periods or for the duration of claims. After the legal limitation periods have elapsed, we will destroy your data.
    • - Legal basis: Compliance with a legal obligation. Art. 6.1 c GDPR
    • - Transfers: Data will not be transferred to third parties, except under legal obligation. In accordance with the rights granted to you by current and applicable data protection regulations, you may exercise the rights of access, rectification, restriction of processing, deletion ("right to be forgotten"), portability, and object to the processing of your personal data, as well as the right to revoke the consent given for the processing thereof, by directing your request to the postal address indicated above or to the email address [email protected].

    You may contact the competent Supervisory Authority to file any complaint you deem appropriate.


    Deadlines: The Responsible Body of the Channel will send, within a period of no more than 7 calendar days, acknowledgment of receipt to the complainant, unless the communication is anonymous or the informant has expressly opted out of receiving communications related to the investigation, or the confidentiality of the communication may be jeopardized, to whom the complainant may request, by the most appropriate means considering the content and form of the communication received, the relevant clarifications on the information communicated or request additional information. A response will be given through the decision taken in the file within a period of no more than 3 months from receipt of the communication, except in cases of special complexity that may be extended up to a maximum of another three additional months.

    1. WHAT IS THE INFRINGEMENT CHANNEL (ALSO CALLED INTERNAL INFORMATION SYSTEM)

    The legal obligation established in Law 2/2023 of February 20, regulating the protection of individuals who report regulatory violations and the fight against corruption, aims to ensure that companies have a reporting channel that offers adequate protection against retaliation against those who report any actions or omissions committed by individuals within the company’s legal framework (serious or very serious administrative or labor violations, or potential criminal offenses). This System is a set of tools and procedures intended to facilitate the detection and management of potential violations within the organization.

    2. HOW TO REPORT A SUSPECTED INFRINGEMENT

    GOSAN Group, S.A. has established a reporting channel accessible to all individuals who wish to make inquiries or report irregularities or regulatory violations by email at [email protected] or through the GOSAN Group, S.A. website using a form (Reporting Form) accessible at https://gosan.net/es/canal-de-denuncia.

    Interested parties not organically linked to the organization (clients, suppliers, and subcontractors) may also use the reporting channel publicly posted on the entity’s website. These parties will be treated in the same way and under the same security conditions as if the complaint were filed by a person within the organization.

    In these cases, the reporting channel is not a substitute for, nor can it be confused with, customer service. The dynamics of both resources are different and serve different purposes. The Channel Responsible Body will forward to the person responsible for customer service those communications that it understands are within its jurisdiction, and this person will forward to the Channel Responsible Body those communications or complaints that may present indications of an irregularity that falls within the scope of compliance.

    3. WHAT CAN BE REPORTED THROUGH THE INTERNAL INFORMATION CHANNEL

    Which conduct is subject to reporting, grouped into the following categories:

    1. Immoral or illegal conduct or actions in the performance of work. The commission of conduct that may violate occupational risk regulations, compromising occupational health and safety, or that constitutes a violation of GOSAN, S.A.’s labor provisions, procedures, or codes of ethics.
    2. Improper or profit-making management of company resources. Conflicts of interest, use of company assets for personal purposes, or inadequate management or handling of resources.
    3. Theft: Any type of theft, robbery, or theft of personal property.
    4. Workplace harassment. Any type of abuse of power and harassment (workplace or otherwise) through intimidation, verbal, written, or physical threats.
    5. Sexual harassment at work: any type of sexual harassment, harassment based on sex, harassment based on sexual orientation, sexual identity, and/or gender expression.
    6. Discriminatory treatment or influence peddling. Mobbing (different treatment of an employee compared to their colleagues for reasons unrelated to job performance), influence peddling, or improper use of information.
    7. Misuse of classified information.
    8. Fraud and corruption. Actions or omissions that may constitute a serious or very serious criminal or administrative offense, such as fraud, tax fraud, money laundering, or any other type of corruption.
    4. CONFIDENTIALITY AND POSSIBILITY OF MAKING ANONYMOUS COMMUNICATIONS

    In any of the aforementioned cases, the informant may choose to remain anonymous (not reveal their identity) or identify themselves. In the latter case, their confidentiality will be guaranteed in full compliance with the provisions of Law 2/2023 and personal data protection regulations.

    The informant shall have the right to know the status of the processing of their communication and the results of the investigation (with an obligation of confidentiality), except in cases where they have expressly opted out of receiving communications or the confidentiality or success of the investigation may be compromised. To do so, they must provide an email address or other means of communication and agree to maintain the confidentiality of the content of the notifications received.

    5. WHAT INFORMATION SHOULD BE PROVIDED WHEN MAKING A COMMUNICATION

    To analyze the provisional plausibility of the information, the reporting party should provide as much information as possible about the alleged violation, including:

    • A basic description of the events. What alleged violation may have been committed and how?
    • The dates (approximate) on which it was committed. When?
    • The persons suspected of having committed the violation, participants in it, and other potential knowledgeable individuals. Who?
    • Documents, audio recordings, videos, data, or any other sources of information (whether paper or electronic) that can be used to corroborate or clarify the alleged violation. What evidence or clues are available?
    6. PROCEDURE FOR MANAGING THE INFORMATION RECEIVED

    The reporting person who has communicated information in writing will receive an acknowledgment of receipt within 7 calendar days of receipt of the information from the System Manager (unless the reporting person has declined to receive information or has made an anonymous communication without indicating any means of contact).

    When the System Manager considers that the information received is totally or partially confusing or insufficient, they may request the reporting person who has identified themselves (or provided a means of communication) to provide the corresponding extensions or clarifications.

    Preliminary Analysis of the Information

    The System Manager will conduct a preliminary analysis of the information and take one of the following decisions:

    • Initiate an investigation.

    The appropriate steps will be taken to clarify the facts and identify the persons allegedly responsible.

    If the successful completion of the investigation permits, the person or persons affected will be informed of the facts, giving them the opportunity to make representations. In all cases, the identity of the informant will be kept confidential and may not be revealed to the person or persons affected.

    Once all the investigation procedures have been completed, the person responsible for the System will prepare a final report detailing the conclusions drawn and their assessment of the reported facts. Two possible actions may be proposed:

    • Closing the procedure.

    If the person considers that the incident does not constitute an offense, that its perpetration is not sufficiently justified, or that no known perpetrator has been identified.

    • Proposal to continue the procedure.

    If the person considers that the investigations conducted contain reasonable indications that an offense may have been committed by the person or persons affected.

    In this case, the Court may propose, depending on the circumstances: filing a criminal complaint with the corresponding prosecutor’s office or court; filing an administrative complaint with the appropriate authority; and/or adopting corrective measures.

    Final Decision

    The System Manager will forward the final report to the Administrative Body, so that they can decide whether to close the case or agree to some or all of the proposals made by the System Manager.

    Generally, this decision must be made within a maximum of 3 months from the acknowledgment of receipt of the communication (if no acknowledgment of receipt has been sent—because it is an anonymous communication, for example—the deadline will begin 7 calendar days after receipt of the communication). However, the deadline may be extended by another 3 months if the investigation is complex.

    7. PROTECTION OF THE REPORTER FROM RETALIATION

    GOSAN, S.A. will guarantee the protection of the informant in good faith against possible retaliation by the organization or third parties. Retaliation includes not only disciplinary retaliation, but also restrictions on internal promotion, access to training, conciliation measures, etc.

    However, certain requirements are required for such protection to be granted: The information provided must be truthful or the informant must have reasonable and objective justification for believing its veracity at the time of communication. Furthermore, the information must not have been obtained illegally, nor must it already be public knowledge or be based on mere rumors or assumptions.

    Law 2/2023 establishes that intentionally reporting false information is considered a very serious offense, which may result in financial penalties of between €30,001 and €300,000. Furthermore, this conduct of providing false information may be subject to disciplinary action by GOSAN.