Code of Ethics and the Ethics Channel

You can access the Ethics Channel in various ways:

1. Via this link to the external platform, a secure and confidential means to file reports. These will be duly registered, at all times guaranteeing their confidentiality and integrity. The Ethics Channel is available 24 hours a day and allows Esade community members and third parties to report any irregularities or wrongdoing in writing and orally (voice recording). The Ethics Channel is hosted on an external platform, guaranteeing greater security and confidentiality to those filing reports.
2. In addition, you can also use other means to report any irregularity or wrongdoing:
    
   a. Contact Diego Pol, the Independent Expert, via e-mail or phone (+34) 648 870 897). The Independent Expert is an experienced consultant who will receive reports regarding potential irregularities and analyze their plausibility and whether or not they are well-founded. All the information processed by the Independent Expert is considered confidential. Similarly, the Independent Expert will maintain the anonymity of those filing reports if they prefer to remain anonymous.

   If the Independent Expert is unavailable by phone, we recommend sending an e-mail with your phone number if you so wish. You can also try calling back a few hours later or leave a voice message for the Independent Expert to return your call.

   b. Contact the Internal Information System Director, Isabel Sáez, via e-mail. The Fundació Esade Board of Trustees has named Isabel Sáez, Esade’s Internal Auditor, to serve as the Internal Information System Director. This position is completely independent from the Board of Trustees. The Internal Information System Director will ensure that the internal information system and the different communications channels it includes work correctly so that Esade community members and third parties can access them and file reports identifying themselves or anonymously without fearing retaliation. The Internal Information System Director will also resolve any questions or doubts regarding the system and ensure that the corresponding internal investigations are processed properly.

As a general norm, the Internal Information Systems Director will receive reports and analyze their plausibility. The  Ethics Committee will then manage these reports and name an investigator to duly investigate the reports. The Ethics Committee will be in charge of supervising and diligently and quickly resolving all the reported irregularities.

Yes, though we encourage you to identify yourself. This helps us investigate the alleged irregularities more efficiently. Please bear in mind that Esade will always ensure the confidentiality of reports received through the Ethics Channel and the other internal channels available for this purpose.

Behaving ethically and complying with norms are fundamental at Esade. The Whistleblowing Policy approved by the Fundació Esade Board of Trustees declares that all Esade community members are required to report any irregularities or wrongdoing to Esade via the channel that best meets their needs, regardless of how they learned about the events in question. This underscores the importance of detecting and addressing any improper behavior and irregularities. We are all responsible for safeguarding Esade and its community members and instilling a truly ethical culture at our institution.

To determine the plausibility of the reports filed, these should include the following:

1. Data identifying the person reporting the possible irregularities (unless opting to file an anonymous report);
2. If available, data identifying those allegedly committing the irregularities;
3. A description of the supposed irregularities, whenever possible specifying the norm being violated, the date, the people involved and witnesses; and
4. If available, proof or evidence supporting your report.

The Ethics Channel incorporates the proper technical and organizational measures to mitigate the risk of disclosure, unavailability and loss or destruction of data.

All Ethics Committee members and any other person made aware of these reports (when strictly required to process them) are obligated to maintain absolute confidentiality regarding the reports from their reception to the final determination. This is especially true regarding the identity of all those affected by the reports, in particular, the identify of those filing them as of the person denounced.

In addition, those using the Ethics Channel can file anonymous reports.

Esade will protect all those using the Ethics Channel from any type of retaliation when filing reports in good faith. At the same time, presenting false reports may imply being subject to the corresponding disciplinary measures.

After receiving reports of any possible irregularities, those filing reports will receive an acknowledgment of receipt no later than 7 working days as of the date their reports are received. The Internal Information Systems Director or Independent Expert, if applicable, will carry out an initial analysis of the reports’ plausibility and forward the latter to the Ethics Committee. This committee will be responsible for deciding if the reports are well-founded and potentially true. It may also reject them due to not meeting the minimum requirements or if the alleged irregularities have already been reported to the competent external legal or administrative authorities. If the Ethics Committee decides to move forward with the report, it will name an investigator to examine the case, carrying out an objective, exhaustive and professional investigation.

Upon completing its investigation, the Ethics Committee will duly notify the investigated individuals of its decisions and, whenever possible, inform those filing the corresponding reports about the end of the proceedings and the general results of the latter.