Complaint Channel

Welcome to the ALUDEC Whistleblowing Channel.
This space is specially designed for you to report to us, with maximum security, any incidents related to your environment or work activities that you consider or suspect to be irregular, punishable, or illegal.

Before submitting a complaint, please carefully read the following information.

Admisible complaints

These are the complaints for which this channel has jurisdiction:

  • Tax fraud
  • Embezzlement
  • Money laundering
  • Acts that could amount to an environmental offence
  • Swindling
  • Bribery
  • Against public health

Inadmissible complaints

The channel does not have jurisdiction for the following complaints:

  • Complaints that are manifestly false
  • Unfounded or
  • Does not relate to potential misconduct, illegal activity or infringement of the Group's Code of Ethics.

Guarantees and Consequences

The ALUDEC GROUP shall ensure that no acts of retaliation are carried out against whistleblowers who have reported any misconduct or breaches of regulations or the Group's internal policies in accordance with Law 2/2023 of 20 February regulating the protection of persons who report regulatory infringements and the fight against corruption
In particular, any kind of unfavourable treatment that puts the individuals concerned at a particular disadvantage compared to someone else in the workplace or other working environment, solely because of their status as whistleblowers, or because they have made a public disclosure, is strictly prohibited.

Anyone found to have knowingly submitted a false report may be subject to criminal or civil procedures in accordance with current legislation, as well as any corresponding disciplinary measures where appropriate.
Where an investigation concludes that an act of misconduct in breach of the law or the ALUDEC GROUP Code of Ethics has taken place that could constitute a criminal act, the provisions of the Disciplinary Procedure, Collective Agreement and any applicable employment legislation shall apply.


1 - Submission of the complaint

The report should contain, wherever possible, the following details:

  1. Description of the alleged misconduct, illegal activity or breach of the Code of Ethics.
  2. Names of the people who are potentially involved.
  3. Approximate dates that the events took place.
  4. Means by which the conduct was carried out.
  5. Business areas affected.
  6. Relevant processes affected (e.g., procurement, accounting, treasury, etc.).
  7. Potential financial impact.
  8. Documentation or evidence of the facts.

2 - Communication

Once the Compliance Team has received the report, it shall send an acknowledgement of receipt to the whistleblower within 7 calendar days, unless the whistleblower has opted to remain anonymous or such acknowledgement could jeopardise the report’s confidentiality.

Then, once the contents of the report have been assessed, the Compliance Team will determine whether or not to open an investigation. The Compliance Team will not process any submission that is manifestly false, unfounded or does not relate to potential misconduct, illegal activity or infringement of the Group's Code of Ethics.

In order to decide whether or not to accept the submitted report, the whistleblower may be asked to clarify certain details or provide additional information, documentation or data to prove that the alleged misconduct took place.

The reported party must be informed, as soon as possible, of the facts of which he/she is accused.

The individual subject to the report shall be informed of the facts of which they are accused as early as possible.

Once the report has been assessed, one of the following steps shall be taken:

  • Where the report of concern does not fall under the remit of the Compliance Team, the whistleblower shall be informed that their report has been archived, without prejudice to its potential transfer to the corresponding management team.
  • The whistleblower shall be informed that an investigation has been opened.
  • The Compliance Team shall issue a response to the enquiry that it received.