Ethics Channel

IDE is fully committed to the highest ethical and regulatory compliance standards in its relationships with all its partners, staff, collaborators, customers, suppliers and other stakeholders in all its activities.

To ensure the maintenance of the criminal risk management and regulatory compliance system, IDE's Board of Directors has appointed and empowered a Regulatory Compliance Committee made up of internal experts and constantly advised by specialists in corporate risk management, whose functions include the management of the Ethics Channel.

IDE makes its Ethics Channel available to its members and any interested party to confidentially, and even anonymously, report any suspicion or knowledge of conduct, actions or omissions committed by an IDE member in the exercise of their duties that constitute:

• a breach of European Union law (legal infringement);
• a serious or very serious criminal or administrative offence;
• any breach of the values, guidelines or rules of conduct set out in the Code of Conduct, the Criminal Risk Prevention Policy and other internal IDE regulations.

The complainant may also use this form to request a face-to-face meeting with the Regulatory Compliance Committee for the purpose of making a communication or complaint as indicated above. In this case, the Regulatory Compliance Committee will summon the complainant to this meeting within a maximum period of seven (7) working days. In the event of a face-to-face meeting, and after obtaining the complainant's express and informed consent regarding the processing of their personal data, the conversation will be documented in one of the following ways:

• Recording of the conversation in a secure, durable and accessible format.
• Complete and accurate transcription of the conversation. In this case, the reporting person will be given the opportunity to check, rectify and accept the transcription of the conversation by signing it.

Without constituting the preferred method for submitting complaints and as an alternative to this IDE Ethics Channel, complaints may be submitted through external complaint channels to the Independent Whistleblower Protection Authority, to the competent administrative authorities, where appropriate, or to the institutions, bodies and agencies of the European Union.

All complaints received will be entered into a complaints register, with each one being assigned a unique reference number so that it can be identified throughout the entire process.

All complaints may be anonymous, i.e. the identification of the person making the complaint is not mandatory but optional.

Please note that only if the informant or complainant provides an address, email address or secure location for the purpose of receiving notifications will they be notified of receipt with a reference number for the complaint; IDE may request additional information if necessary and will keep them informed of whether or not the complaint has been accepted for processing and of the corresponding decision.

Complaints will be evaluated and investigated with a view to resolving them within a period not exceeding three (3) months from receipt of the complaint.

IDE states that the Ethics Channel complies with the following principles and offers the following guarantees, the specific details of which can be consulted at Complaints Channel Management Procedure :

• Maximum confidentiality.
• Guarantee of the right to defence, presumption of innocence and right to honour.
• Guarantee of the principle of evidence and contradiction.
• Management of conflicts of interest.
• Prohibition of retaliation, including threats and attempts at retaliation.
• Protection of personal data.

This form must not be used for commercial purposes.

Access the Ethical Channel form from here