Introduction

In compliance with Law 2/2023, of February 20, regulating the protection of individuals who report regulatory violations and the fight against corruption (Whistleblower Protection Law), ANECOOP provides this means of communication for the submission of communications regarding alleged actions or omissions constituting violations of European Union law and/or serious or very serious criminal or administrative offenses.

By way of example, through this channel, the following irregular or non-compliant situations or behaviors, or violations can be reported:

Sexual harassment
Discrimination
Money laundering
Disclosure of confidential information
Conflict of interest
Corruption
Irregularities with Social Security and the Tax Agency
Fraud
Consumer protection
Environmental crimes
Public health
Food safety
Data protection

Who can report?

All individuals who have knowledge of infringements in a work or professional context can report through this channel, specifically:

Individuals who are employees of ANECOOP or have had an employment relationship with ANECOOP.
Self-employed individuals who have a relationship with ANECOOP.
Partners and members of the management, executive, or supervisory bodies of ANECOOP.
Individuals who work for or under the supervision and direction of ANECOOP contractors, subcontractors, and suppliers.
Interns or trainees, regardless of whether or not they receive remuneration.
Individuals whose employment relationship with ANECOOP has not yet begun, in cases where information about infringements is obtained during the selection process or pre-contractual negotiations.

Whistleblowing Channel Operation

ANECOOP’s Whistleblowing Channel channel allows for written communications, either through a form or verbally via a voice file. It is also possible to use both forms of communication.

If requested by the reporting person and using the herein mean to do so, the communication can be presented through an in-person meeting within a maximum period of seven days.

The reporting person has the choice to submit a communication anonymously or not. In both cases, the reporting person will be able to follow up on their case.

Regarding the reported facts, the reporting person is requested to provide a detailed description of them (the nature of the illicit or irregular action or omission, individuals or areas involved, approximate date of occurrence, and, if possible, provide documents or evidence).

The reporting person will NOT be subjected to retaliation for the actions or omissions reported here, even if the result of the investigations is the absence of an offense, unless the reporting person acted in bad faith or reported facts that should not be reported through this means.

Individuals who report or disclose the aforementioned offenses will be entitled to protection provided the following circumstances are present:

They had reasonable grounds to believe that the information on breaches reported was true at the time of reporting, even if conclusive evidence is not provided, and that such information fell within the scope of Law 2/2023.
The communication or disclosure has been made in accordance with the requirements set forth in this law.

The aforementioned protection shall expressly exclude individuals who report or disclose:

Information contained in communications that have been dismissed through any internal information channel or for any of the following reasons:

When the reported facts lack credibility.
When the reported facts do not constitute a violation of the legal framework included within the scope of Law 2/2023.
When the communication manifestly lacks foundation or there are rational indications that it has been obtained through the commission of a crime.
When the communication does not contain new and significant information regarding violations compared to a previous communication for which the corresponding procedures have concluded, unless new factual or legal circumstances justify a different follow-up.

Information related to claims about interpersonal conflicts or that only affect the whistleblower and the individuals referred to in the communication or disclosure.
Information that is already fully available to the public or that consists of mere rumors.
Information that refers to actions or omissions not covered by Law 2/2023.

External Reporting Channels

Although ANECOOP’s Whistleblowing Channel is the preferred means to report any actions or omissions covered by Law 2/2023 (in order to ensure that ANECOOP is the first to be informed of the facts and can take appropriate measures), the reporting person can choose other external reporting channels authorized by the competent authorities to report actions or omissions that may constitute offenses. Among these channels are:

Independent administrative body: Independent Authority for Whistleblower Protection o A.A.I. (pending creation).
Autonomous Community: Valencian Antifraud Agency (AVAF).
National: National Anti-Fraud Coordination Service (SNCA); Anti-corruption and Organized Crime Prosecution Office; National Police; Court of Auditors; Ombudsman.
EU: European Anti-Fraud Office (OLAF); European Court of Auditors.

What happens after the submission of the report?

A person designated by ANECOOP, called the Whistleblowing Channel Manager, will be responsible for receiving and processing the report.

The ANECOOP’s Whistleblowing Channel Manager will maintain contact with the reporting person to provide updates on the status of the report and, if necessary, request additional information about the reported facts.

Upon receipt of the information, all necessary actions will be taken to verify the credibility of the reported facts.

Within a maximum period of three months from the submission of the report, the ANECOOP’s Whistleblowing Channel Manager will conclude the proceedings and provide a response to the reporting person regarding the submitted report, unless the reporting person has withdrawn the report or notification is not possible (for example, if contact details of the reporting person are not available).

General principles

In compliance with Article 5(2)(h) of Law 2/2023, of February 20, regulating the protection of individuals who report regulatory infringements and the fight against corruption, the reporting person can find the general principles of ANECOOP’s Whistleblowing Channel in the General Principles tab, located at the top of this page.

Data protection

For information on data protection regarding the processing of your personal data, click on the Data Protectionplease click on the Data Protection tab at the top of this page.