Ethics and Compliance

At Torre de Collserola, we firmly believe in the importance of fostering a safe, ethical, equal, and trustworthy environment for everyone who is part of or interacts with our organization: employees, clients, suppliers, business partners, and other stakeholders.

With this commitment, Torre de Collserola has implemented a Compliance Program focused on crime prevention, the promotion of Corporate Social Responsibility, and the strengthening of a solid ethical culture throughout the organization. As a core element of this program, an Ethics Committee has been established as a specialized and independent body responsible for ensuring compliance with our internal regulations and safeguarding the integrity of the ethical values that guide our actions.

To ensure compliance with the legal framework and our internal rules, Torre de Collserola has created and implemented an Ethics Channel that allows any person to confidentially and securely report —with the option to remain anonymous— any potential irregular conduct, legal infringements, or ethical violations detected within our organization. The system guarantees protection against retaliation for individuals who report in good faith.

This channel is conceived as a key tool within our Compliance Program and is aligned with the provisions of Law 2/2023 of February 20, on the protection of persons who report regulatory infringements and fight against corruption, as well as with Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law.

All reports will be handled with the utmost confidentiality and without risk of retaliation for the reporting person, provided that the report is made in good faith and based on reasonable indications or truthful facts.

The use of the Ethics Channel to submit complaints or knowingly false statements with clear disregard for the truth or without any basis is strictly prohibited.

Through the Ethics Channel, you may report any fact that you believe could constitute a violation of the legal framework, the Code of Ethics, or any internal regulation currently in force at Torre de Collserola. In particular, the channel is available for reporting:

• Fraud and corruption-related conduct.
• Discrimination, workplace harassment, or violations of fundamental rights in the work environment.
• Breaches in workplace safety, health, and hygiene regulations.
• Violations related to personal data protection or information security.
• Anticompetitive practices or those contrary to free competition.
• Conduct contrary to human rights or harmful to the environment.
• Infringements related to public procurement, money laundering, financial services, or state aid.
• Other potentially serious or very serious criminal or administrative offenses.

Confidentiality:
We understand that confidentiality is essential for individuals to feel secure when reporting facts through the Ethics Channel. We guarantee absolute confidentiality throughout the process and protect the identity of the reporting person to the extent permitted by law. Anonymous reporting is also possible.

Impartial investigation process:

Once a report is received, a process of analysis and investigation will begin, conducted objectively, impartially, and diligently by the body responsible for the Ethics Channel, in accordance with internal regulations and applicable legislation. The rights of all involved parties will be respected throughout the process, including the right to be heard, to present relevant evidence, the presumption of innocence, and the right to honor.

Protection against retaliation:

Torre de Collserola expressly prohibits any form of direct or indirect retaliation against individuals who report concerns protected by law, provided they act in good faith and based on reasonable indications of veracity.

Diligent handling and deadlines:

All reports will be managed with the utmost diligence and professionalism. An acknowledgment of receipt will be issued within a maximum of seven days, and a response will be provided within a period not exceeding three months, which may be extended by an additional three months in particularly complex cases.

Resolution and follow-up:

Once the facts have been analyzed, necessary actions will be taken to correct and prevent irregularities, including potential disciplinary, corrective, or organizational improvement measures. Whenever feasible and without compromising confidentiality, the reporting person will be informed of the outcome and status of their report.

There are two options. 

• Through the co-resol app:

1. Download the co-resol app, accepting notifications. It is free and available on the App Store and Google Play.
2. Press the "Just Click" button and then enter the Collserola code.
3. Select the channel button.
4. Write your message or leave a voice note being as specific as possible. You can attach images and documentation.
5. Identify yourself or select the option of anonymity. In either case, you must accept the Privacy Policy.
6. Once you have completed these steps, a message will appear on the screen as acknowledgment of receipt of your click.
7. Communication for tracking the click will be made through a secure chat (you can access it from the chat button on the app's home screen) until it closes.

• Through a web page:

You can access it through this link:

https://canalco-resol.com

1. Press the "Just Click" button and enter the Collserola
2. Select the channel button.
3. Write your message or leave a voice note being as specific as possible. You can attach images and documentation.
4. Identify yourself or select the option of anonymity. In either case, you must accept the Privacy Policy.
5. In this case, along with the acknowledgment of receipt, a unique Identifier and PIN will appear on the screen for the click sent, which you must save separately for security, to later maintain communication, through a secure chat, about the status of your click.
6. Every time you want to know if you have a new message in the chat, or you want to provide more information, you must go to the home link https://canalco-resol.com and press the “Access a previous click” button and enter the Collserola code, as well as the Identifier and PIN that you had saved.

Important:

This Ethical Channel is not an emergency service. This channel should not be used to report on situations that involve an immediate threat. If you need assistance in such a situation, please contact your local authorities and use the channels defined for this purpose.