DEM Whistleblowing Channel

Frequently asked questions

Here you can check the frequently questions in the anonymous reporting channel of DESARROLLO MULTILATERAL, S.L. (DEM)

When will I receive a response to my report or enquiry? What is the timeframe for resolution?

The Ethics Committee will confirm receipt and acceptance of the report or enquiry within a maximum of 7 days. The resolution period for enquiries is a maximum of 90 days, unless the complexity of the case justifies a longer period.

Who handles the reports?

The ISRM (Internal Reporting System Manager – Law 2/2023): Receives and registers all communications submitted through the internal channel, ensures confidentiality, deadlines, and custody of the file, and decides on admissibility. Leads the internal reporting procedure, activates recusals when conflicts of interest arise, and documents closure. May obtain internal or external support without losing responsibility.The ABC Function (Anti-Bribery Compliance Function – ISO 37001): Oversees the design, implementation, and effectiveness of the Anti-Bribery Management System, advises on controls, and reports performance to senior management. Handles bribery-related cases from a technical standpoint: risk analysis, due diligence, investigations, corrective actions, and audit/certification evidence.Both functions are external to DEM.

Can I check the status of my report even if it is submitted anonymously?

Yes. At the end of the process, you will automatically be provided with a code that allows you to view the status of your report.

Can I report a workplace situation if I do not belong to the company?

Yes. The channel is available so that different actors within the business ecosystem can help detect unlawful activities. In any case, if the matter concerns complaints about the service provided, other channels exist for lodging those claims.

How can I increase anonymity when submitting a report?

Some recommendations to maximise anonymity, in addition to indicating that the report is anonymous:• Ensure that the description of the facts does not include information that could easily identify you. The same applies to any documents you upload as evidence.• Do not submit a report from a computer connected to the company network, including mobile devices connected to the corporate Wi-Fi. Ithikios does not record information, but before reaching their systems, the traffic passes through your organisation’s own controls such as proxies or firewalls, which could reveal the services you connect to.• You may use the open-source TOR browser, which anonymises the IP address.

I have lost the access key to check the status of my report. What can I do?

Unfortunately, for security reasons, only the whistleblower knows their access code and password. If you lose either of them, you will not be able to follow up the report. This does not mean the report will not be processed; it simply means you will not be able to see its progress or provide further information if required by the company.

If there is an emergency, should I use this channel?

No. This channel is not intended for managing urgent matters or emergencies. In such cases, contact the authorities or emergency services.

Is anonymity guaranteed when submitting a report?

During the reporting process, you may choose whether or not to provide your personal data. If you decide not to, you will need to follow up your case through the whistleblowing channel to track progress and resolution. The channel will provide you with a username and password to access the status of your report. The channel is independent from the company and does not record IP information.

Is there an Ethical Code where I can check which behaviours are reportable?

Yes. You can review the Ethical Code here.

What happens if it is later found that the content of a report is false?

The key requirement is acting in good faith and having grounds to believe the facts reported are true. DEM does not expect the whistleblower to investigate the events. This responsibility lies with the Ethics Committee. If the investigation determines that no breach has occurred but the whistleblower acted in good faith, they should not fear any form of retaliation.

What is DEM’s Whistleblowing Channel?

It is a communication mechanism made available by DEM to all groups authorised to access the channel. Through this mechanism, communications related to the scope of the Ethical Code or any other internal policy or standard applicable to DEM may be submitted.A set of categories has been defined to classify communications according to their nature, facilitating their management and the completion of data-collection forms.

What type of offences can I report?

Any criminal offences established in the Spanish Criminal Code or in the regulations of other countries in which DEM operates, committed by a legal representative or employee, for the direct or indirect benefit of DEM.

Where is the platform that manages the channel?

The whistleblowing channel operates on an external platform, https://ithikios.com . This company receives the reports and automatically forwards them to DEM for assessment. Ithikios’ servers are located in data centres within the European Union. Your data is encrypted to minimise the risk of intrusion.

Who manages the whistleblowing channel?

The channel is operated by compliance specialists from external entities with access to the system, and, when necessary, in collaboration with independent experts.

Why should I report what I know?

Integrity, responsibility, and transparency are fundamental values for DEM. We are all required to understand and comply with our Ethical Code. Likewise, we are responsible for reporting any potential breach of our Code.