Why have a whistleblower channel?

At Impact Hub, we commit to upholding high standards of integrity and respect in all our interactions and activities. Our Code of Ethics reflects this commitment, establishing principles and values that guide our responsible behavior and compliance with the law in each of our relationships: from our shareholders and volunteers to our employees, clients, suppliers, public and private institutions, and society as a whole.

If you detect any behavior that you believe contradicts our Code of Ethics or that may be irregular, illegal, or criminal, we offer you a secure and confidential tool to report it: our Reporting Channel." This channel has been established in accordance with Law 2/2023, dated February 20,, which protects whistleblowers and combats corruption. .

Your opinion matters

To safeguard your rights as a whistleblower, you have the option to submit your report anonymously. The Sentinel Channel ensures the confidentiality of both your identity and the content of your report, which will be managed by our Ethics Committee at Impact Hub..

If you know of an incident that you believe should be reported:


What is a reporting channel?

It is a mechanism available to any natural or legal person who has any kind of relationship with Impact Hub and through which an irregularity, illegality, or crime that may negatively affect the organization in the provision of its services can be reported.

How are the facts investigated and what are the consequences?

Once the report is received, it is assigned a reference code and included in the register of reports. After analyzing the facts of the report, they are classified according to their main content and the level of severity, ranging from mild, severe, to very severe. Subsequently, excluding the personal data of the whistleblower, the Register is sent to the Ethics Committee of Impact Hub, which will be the body that decides on the report. In this case, an investigation may be initiated regarding the reported facts, or the report may be archived if it is considered to be completely unfounded, with the reasons for each decision recorded in the file.

How are the facts investigated and what are the consequences?

The deadline for processing the file and making a decision regarding it shall not exceed three (3) months from the date of its opening. If the investigated facts are confirmed, Impact Hub will first take all necessary measures to stop such acts or to prevent them from occurring. Afterward, depending on the severity of the facts, legal actions may be initiated against the person or persons allegedly responsible for them.

What guarantees does a whistleblower have?

Firstly, the report may be made anonymously, i.e., maintaining the whistleblower's identity secret, whose data may only be disclosed with the whistleblower's authorization or, if applicable, to the competent public authority for the investigation of the facts. Secondly, the Ethics Committee guarantees to the good faith whistleblower that no reprisals will be taken against them simply for making a report..

What happens if a report is false?

Reports must be truthful and made in good faith. It should be noted that making false reports could constitute the crimes of slander and libel as defined in Articles 205 and following the Penal Code. Impact Hub may take legal action against anyone who makes a false or malicious report.

Can a report be made without evidence?

Reports must be made in good faith and based on reasonable indications of the commission of an illegal, criminal, and/or unethical act, and therefore it would be advisable for them to be supported by documentary evidence. Although testimonial evidence, including the testimony of the whistleblower, and instruments for reproducing words, images, and sounds are also admissible. In any case, it is important to note that it is essential that the evidence has been obtained by the whistleblower lawfully.

How are personal data treated within the framework of the Reporting Channel?

All personal data provided for the purpose of the report will be processed in accordance with Organic Law 3/2018 of December 5 on the Protection of Personal Data and Guarantee of Digital Rights, for legitimate and specific purposes related to the investigation that may arise as a result of the report, they will not be used for incompatible purposes and will be adequate and not excessive about the aforementioned purposes.