Ethical Channel of Complaints, Information and Communications

Ethics Channel for Reports, Information and Communications

Baker Tilly has an Ethics Channel for Reports, Information and Communications that enables anyone to report any potential irregularity, breach, or conduct that is contrary to ethics, the law, and the rules governing the organisation.

Employees may submit reports in writing or verbally, or both. However, the Internal Information System is the preferred channel for reporting acts or omissions that may constitute infringements of European Union law, or that may amount to a serious or very serious criminal or administrative offence, and in any event those involving financial loss to the Public Treasury and Social Security.

The channel is based on the principles of confidentiality and non-retaliation. Anonymous reports can be submitted, although we encourage you to identify yourself so that we can contact you if additional information is needed.

The Ethics Channel for Reports, Information and Communications complements, and does not replace, the organisation’s usual communication channels with employees, collaborators, and other third parties with whom it maintains a direct employment, commercial, or professional relationship. In this regard, interested parties should seek to use those channels for the effective resolution of each case before using this channel.

This channel is not intended for queries and/or questions regarding the interpretation of the organisation’s legal requirements and rules. For that purpose, you may send an email to: compliance@bakertilly.es.

Thanks to this platform, and with your responsible cooperation, we can detect conduct that may be contrary to our principles.

Who can act as a reporting person?

In accordance with Law 2/2023 of 20 February, regulating the protection of persons who report regulatory infringements and anti-corruption measures, the following persons may use this tool:

Any employee, member of the governing bodies, or manager of the Baker Tilly group, as well as anyone working under the supervision and direction of manufacturers, suppliers, contractors and subcontractors of the organisation who, in an employment context (whether the employment relationship has not yet begun or has already ended), commercial or professional context, has become aware of infringements, irregularities or breaches.
External personnel such as consultants, suppliers, self-employed professionals and interns.
Legal entities with which the organisation has established or plans to establish a business relationship, including clients, consumers, contractors, consultants, subcontractors, suppliers, vendors, advisers, agents, distributors, representatives, intermediaries, investors, joint venture partners, consortium partners, outsourcing providers or business alliances.
Trade union representatives.
Any other person who has held or will hold any of the positions set out in this section.

How can I access the Channel?

You can access the Ethics Channel for Reports, Information and Communications via the link on this page, which connects to an external, secure and confidential platform where your communications will be recorded, guaranteeing confidentiality and integrity at all times. The Ethics Channel is available 24 hours a day and allows incidents to be reported in writing. The Ethics Channel is hosted on a platform contracted from an external provider, providing reporting persons with greater security and confidentiality safeguards.

Once you have submitted your report, you will be able to track it using the access password generated automatically.

To access the form available in the Ethics Channel for Reports, Information and Communications, you must first accept the Privacy Policy.

Can I report anonymously?

Yes. However, we encourage you to identify yourself, as this enables us to conduct a more efficient investigation of the reported facts. Please note that the organisation will always guarantee the confidentiality of communications received through the Ethics Channel or other internal channels enabled for this purpose, as well as the non-adoption of retaliatory measures.

What information should I provide when submitting a report?

In order to assess a report, it must include:

Identifying details of the person submitting the report (unless anonymity is chosen);
If known, identifying details of the person(s) to whom the incident is attributed;
A description of the reported facts, specifying as far as possible the breach of the applicable regulations, the date, the persons involved and any witnesses;
Where available, evidence supporting the facts reported.

What safeguards apply when using the Ethics Channel for Reports, Information and Communications?

The Ethics Channel for Reports, Information and Communications has appropriate technical and organisational security measures in place to prevent the risk of disclosure, unavailability, loss or destruction of information.

The person responsible for the Internal Information System and any other person who, only where strictly necessary for the proper management of the report, becomes aware of it, will be required to maintain strict confidentiality in all respects, including the data of the parties involved in the process, and especially the identity of both the reporting person and the reported person.

In addition, anyone using the Ethics Channel for Reports, Information and Communications may submit the report anonymously.

The organisation will protect any person who uses the Ethics Channel for Reports, Information and Communications in good faith from any form of retaliation. However, submitting false reports may lead to the imposition of disciplinary measures.

What happens after I submit a report?

Once a report has been submitted regarding a potential incident, the reporting person will receive an acknowledgement of receipt within a period not exceeding 7 working days from receipt. After an initial review, a decision will be made as to whether to proceed with the report if it is considered potentially credible, or to reject it due to a lack of reasonable indications, failure to meet minimum requirements, or because the same facts have already been reported to any judicial or administrative body. If the report is accepted, the person responsible for the Internal Information System will appoint an investigator who will carry out an objective, thorough and professional investigation of the facts.

Once the investigation has concluded, the investigated parties will be informed of the decisions adopted, and the reporting person will be informed, whenever possible, of the conclusion of the procedure and the outcome in general terms.

External reporting channels to the competent authorities

Please note that the Ethics Channel for Reports, Information and Communications is the preferred channel for reporting potential irregularities. However, you may also use external channels enabled by the competent authorities. In Catalonia, for example, the Independent Whistleblower Protection Authority is the Office for Anti-Fraud in Catalonia (https://seuelectronica.antifrau.cat).