Club de Madrid has in place a number of formal policies aimed at establishing rules and procedures to define appropriate professional conduct and prevent and deal with situations that go against the organisation’s values or the law. Further developing this compliance policy and system, and in order to demonstrate its commitment to transparency and corporate ethics, Club de Madrid, with the support of Audidat 3.0 S.L., a Spanish consultancy specialized in Compliance and Data Protection, has put in place a tool for reporting incidents through which any allegedly irregular activity or behaviour occurring within the organization, of which there is knowledge or reasonable suspicion, can be reported anonymously. This “Ethical Channel”, is available to anyone who has a relationship with our organization (employees, partners, directors, suppliers, customers, associates, etc.) and aims at encouraging compliance with our organization’s regulations, in order to generate a climate of trust both within and outside the organization.
The activities and behaviours that could be reported may include, among others:
- actions that could imply a breach of the Code of Professional Conduct or other Club de Madrid’s policies;
- behaviour that is considered to be illegal, or has the potential to endanger others or breach Club de Madrid’s values;
- incidents of fraud, bribery, theft;
- a potential failure to comply with legal obligations
The Ethical Channel is accessed through the link below, which directs the user to the digital platform for filing new reports or complaints, as well as for tracking previously filed reports or complaints. Non-retaliation is guaranteed, as a result of which any type of reprisal against the informant is completely forbidden. Likewise, the presumption of innocence of the accused party is guaranteed until proven otherwise. The use of the Ethical Channel does not in any way preclude the possibility to resort to external channels established by the competent bodies or authorities to report any act that may be considered a crime. For further details on when and how to use the Ethical Channel please access here.
The Ethical Channel is managed by a third party external to our organization (Audidat) in order to comply with the necessary impartiality and objectivity required for this type of procedure. The manager will receive the complaint and will carry out the appropriate inquiry and investigation, in coordination with the member of the staff designated as Head of the Internal Information System and with full support from the rest of Club de Madrid management and staff.