Complaints channel


ALCONZA has approved an Internal Reporting System that complies with the requirements established in Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption (hereinafter, “Law 2/2023”).

This System is a set of tools and procedures that are intended to facilitate the detection and management of possible violations (with the exceptions that will be exposed) within ALCONZA.



The Management of ALCONZA, as the person most responsible for the supervision of regulatory compliance, has designated Enrique Avendaño Amorebieta as the person responsible for the management of the System (hereinafter, the person “Person Responsible for the System”).



An internal information channel has been set up so that information can be communicated regarding certain violations or non-compliances (as defined in the following section).



Alleged Infringements may be reported in several ways:


In writing:

By means of the e-mail address or by sending a letter to the postal address Arana bidea,13-48640 Berango – Bizkaia to the attention, to the attention of the System Manager.


Verbal communication:

By calling the telephone number 946 680 000 and asking for the System Manager. In addition, the reporting person may request a meeting (face-to-face or telematic) to provide information (the meeting must be held within a maximum of 7 days from the request). These meetings shall be documented by secure, confidential, durable and accessible recording of the conversation, or (a detailed transcript of the conversation that is validated by the reporting person.


If the alleged Infringement refers to facts or circumstances in which the person in charge of the System was involved, the information may be sent to the person in charge of Administration Management, who shall then assume, provisionally and for the sole purpose of managing this information, the functions of the person in charge of the System.



Any information lawfully obtained within the framework of an employment or professional activity in or with ALCONZA that refers to any or some of the following actions or omissions (hereinafter, the “Violations”) may be reported:


  • Immoral or illegal conduct or actions in the performance of work. The commission of conduct that may violate the regulations on occupational hazards, compromising health and safety at work, or that constitute a violation of the labor provisions, procedures or codes of ethics of ALCONZA.
  • Inadequate or lucrative management of material resources. Conflicts of interest, the use of ALCONZA. assets for own purposes or inadequate management or handling of resources.
  • Theft: Any type of theft, robbery or theft of personal property.
  • Labor or sexual harassment. Any type of abuse of power and harassment (labor, sexual or otherwise) through intimidation, oral, written or physical threats.
  • Discriminatory treatment or influence peddling. Mobbing (difference in treatment of an employee with respect to his or her colleagues for reasons unrelated to work performance), influence peddling or improper use of information.
  • Misuse of classified information.
  • 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.



Any member of ALCONZA BERANGO, understood as such all persons professionally related to the company, whether as employees (whatever their status, including trainees), whether as shareholders, managers or members of the Board of Directors, as well as applicants in selection processes, trainees, interns, retirees, etc. may transmit information on alleged Infringements, directly or represented.


External third parties such as freelancers, suppliers, contractors and subcontractors (and their employees) may also do so, and may therefore report the Infractions indicated, subject to their requirements and procedures.



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


The informant will have the right to know the status of the processing of his/her communication and the results of the investigation (with an obligation of confidentiality), except in cases where he/she has expressly waived the right to receive communications or where the confidentiality or the success of the investigation could be compromised. To this end, you must provide an e-mail address or other means of communication and undertake to preserve the confidentiality of the content of the notifications received.



In order to analyze the provisional plausibility of the information, the reporting person should provide as much information as possible about the alleged Infringement, including:


  • A basic description of the facts What alleged infringement may have been committed and how?
  • The (approximate) dates on which it was committed. When?
  • The persons suspected of having committed the infraction, participants in the infraction and other possible insiders. Who?
  • The documents, audios, videos, data or any other sources of information (whether on paper or computer) that can be used to corroborate or clarify the alleged infringement. What evidence or clues are available?



Acknowledgement of receipt and request for further information: The informant who has communicated information in writing will receive an acknowledgement of receipt within 7 calendar days of receipt of the information by the System Manager (unless the informant has declined to receive information or has made an anonymous communication without indicating any means of contact).


When the Responsible for the System considers that the information received is totally or partially confusing or insufficient, it may request the informant who has identified himself/herself (or provided a means of communication) the corresponding amplifications or clarifications.


Preliminary analysis of the information: The person responsible for the System will perform a preliminary analysis of the information and make one of the following decisions:

Inadmit the communication:
When the facts reported lack any verisimilitude.

When the facts reported do not constitute an Infringement or, even if they could be, no evidence or evidence has been provided that could minimally corroborate them.
When the communication is manifestly unfounded or when, in the opinion of the person in charge of the System, there are reasonable indications that the information or evidence or evidence provided has been obtained unlawfully.
When the communication does not present significant new information on an already reported and closed Infringement, which is already public knowledge or in respect of which the System Manager already had prior knowledge and had not considered that there was an infringement (unless there are new circumstances and relevant evidence or principles of proof that justify it).
Initiate the investigation:
Investigation: the proceedings deemed appropriate for the clarification of the facts and for the investigation of the persons allegedly responsible shall be carried out.


If the success of the investigation so permits, the person or persons concerned shall be informed of the facts and given the opportunity to make representations. In any case, the identity of the informant shall be kept secret and may not be disclosed to the person or persons concerned.


Once all the investigative steps have been completed, the System Manager will prepare a final report specifying the conclusions drawn and her assessment of the facts reported. He/she may propose two possible actions:

The procedure will be closed, if it is considered that the fact does not constitute an infraction, that its perpetration is not sufficiently justified or that the known perpetrator has not been accredited.
Proposal for continuation of the procedure, if it considers that from the proceedings carried out there are reasonable indications that an Infringement may have been committed by the person or persons concerned.
In this case, it may propose, depending on the case: the filing of a criminal complaint before the Provincial Prosecutor’s Office or the corresponding Court; the filing of an administrative complaint before the corresponding authority; and/or the adoption of corrective measures.


Final decision: The System Manager will send the final report to the administrative body or to the Management Board, so that they may decide whether to file the file or whether to agree to any or all of the proposals made by the System Manager.


As a general rule, this decision must be taken within a maximum period of 3 months from the acknowledgement of receipt of the communication (if no acknowledgement of receipt has been sent – because it is an anonymous communication, for example – the period will start from the expiry of 7 calendar days after receipt of the communication). However, the period may be extended by another 3 months if the investigation is complex.



ALCONZA will guarantee the protection of the person reporting in good faith against possible retaliation by the organization or third parties. Retaliation is understood to mean not only disciplinary retaliation, but also restrictions on internal promotion, access to training, work-life balance measures, etc.

However, there are certain requirements for such protection to be granted:

That the information provided be truthful or that the informant has a reasonable and objective justification to believe in its truthfulness at the time of communication. In addition, the information must not have been obtained unlawfully, nor may it be already public knowledge or based on mere hearsay or supposition.
Law 2/2023 establishes that intentionally reporting false information is considered a very serious misconduct, which may carry financial penalties of between 30,001 and 300,000 euros. In addition, this conduct of providing false information may be subject to disciplinary sanctions by Alconza.

If the System Manager believes that a communication may be false or based on bad faith, she will inform the administrative body or the Management Board so that the corresponding measures can be taken or initiated.

It must be an alleged Infringement, as that term has been defined above.
The reporting person must have followed the established procedure for the communication of the information.


Berango, March 2024

General Management of Alconza Berango SL