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Ethics channel

Last update: 15 May 2026.

1. What is the ethics channel?

The ethics channel of Impulso Tecnológico S.L. is the internal information system foreseen in Spanish Law 2/2023 of 20 February, regulating the protection of people who report regulatory infringements and anti-corruption (transposition of Directive (EU) 2019/1937).

It is the channel to communicate, in good faith and confidentially, any conduct or fact that may constitute:

  • Infringements of European Union law.
  • Actions or omissions that may constitute serious or very serious criminal or administrative infringements.
  • Violations of the internal Code of Ethics or of Impulso Tecnológico S.L.'s compliance policies.
  • Cases of labour, sexual, discriminatory harassment or any conduct contrary to the company's principles.

2. Who can use the channel?

  • Current or former employees, interns and volunteers.
  • People in selection processes or pre-contractual negotiations.
  • Self-employed contractors providing services to the organisation.
  • Shareholders and members of administrative bodies.
  • Contractors, subcontractors and suppliers.

3. How to submit a report

The following channels are available:

  • Email: ethics@impulsotecnologico.com.
  • Postal mail: Impulso Tecnológico S.L. — Officer of the Internal Information System, Calle Delmira Agustini 5, local 4, 28021 Madrid – España, in a sealed envelope marked "CONFIDENTIAL — ETHICS CHANNEL".
  • In-person meeting: at the whistleblower's request, within 7 business days of the request.

Reports may be filed identified or anonymously. Where identification is provided, the whistleblower's confidentiality is guaranteed by law.

4. Whistleblower guarantees

  • Confidentiality. The whistleblower's identity will not be disclosed to unauthorised persons, except for legal obligation as part of a judicial investigation.
  • Prohibition of retaliation. Anyone reporting in good faith is protected against any labour or professional retaliation (dismissal, suspension, substantial change in conditions, negative evaluations, etc.).
  • Assistance. Possibility of receiving legal advice and, where appropriate, reinforced protection measures under article 36 of Law 2/2023.
  • Data processing. Personal data is processed in accordance with the privacy policy and retained only for the time necessary to decide on the merit of the report, with a maximum of 3 months from receipt unless formal proceedings are opened.

5. Procedure

  1. Acknowledgement of receipt within a maximum of 7 calendar days from receipt of the report.
  2. Preliminary analysis of admissibility. If admitted, a file is opened.
  3. Internal investigation with all guarantees of impartiality, hearing and defence.
  4. Conclusion and response to the whistleblower within a maximum of 3 months (extendable to 6 in complex cases), under article 9 of Law 2/2023.

6. Officer of the Internal Information System

The System Officer, appointed by the administrative body, is responsible for the diligent, independent and confidential management of the channel. Their identity has been declared to the Independent Whistleblower Protection Authority (A.A.I.).

7. External channel and authorities

Additionally, every whistleblower may directly contact the external channels provided by law:

  • Independent Whistleblower Protection Authority (A.A.I.) at the Spanish state level.
  • Competent regional authority, where applicable.
  • European Union institutions, bodies or organisations.