Compliance Body

The TORRE DE COLLSEROLA Compliance Body is the company’s governing body responsible for the “Compliance Program” in relation to crime prevention in TORRE DE COLLSEROLA. Its areas of responsibility are regulatory compliance and the prevention, monitoring, and control of behaviors inconsistent with the Code of Ethics, the internal regulations included in the Manual for the Prevention of Crimes, and/or current legislation.

The “Compliance Program” is based on the implementation of organizational and management models that include adequate monitoring and control measures to guarantee internal and external regulatory compliance of the Company's activities in the broadest sense.

Ethics and Compliance

The TORRE DE COLLSEROLA Code of Ethics is an integral part and fundamental standard of the TORRE DE COLLSEROLA Crime Prevention Manual, and is a tool that aims to ensure the effectiveness of the implementation of procedures, channels, and circuits aimed at all TORRE DE COLLSEROLA collaborators, in order to provide a conduct guide that is consistent and aligned with the company’s ethical and business principles, in order to avoid any conduct that could result in liability and/or a breach of the standards established in the TORRE DE COLLSEROLA Code of Ethics, in the policies and regulations that develop said code, and in applicable law.

Ethics and Compliance

TORRE DE COLLSEROLA provides its collaborators, customers, suppliers, and third parties with an information channel, called the “Whistleblowing Channel”, which makes it possible to confidentially report breaches of the company's Code of Ethics or breaches of current legislation, along with any potentially relevant irregularities, bad practices and/or incidents, of any nature (ethical, criminal, financial, accounting, tax, commercial, administrative, etc.) that could have any implications for TORRE DE COLLSEROLA.

The Whistleblowing Channel makes it possible to:

Clarify the doubts related to the Code of Ethics or Crime Prevention Manual
Clarify issues of interpretation of the Code of Ethics, Standards of Conduct, Protocols
Propose improvements on ethical and regulatory compliance
Communicate any incident, irregularity, breach and/or non-compliance detected within the company.

Communications can be made through the form or by sending an email to the corporate address at canal.etico@torredecollserola.com

Reports will be handled by the TORRE DE COLLSEROLA Ethics Compliance and Regulatory Control Body (“Compliance Body”).

TORRE DE COLLSEROLA guarantees the confidentiality of the communications received in compliance with the provisions of the Code of Ethics and Organic Law 15/1999, of December 13, on the Protection of Personal Data.

Form to be completed for reporting incidents

Name and surname*
Phone*
E-mail*
Date of report*
Approximate date of the events reported*
Description of the complaint*Make a detailed description of your complaint, identifying the people involved and the relevant data that you consider
Attached documents List and identify the files that you provide and that you consider evidence of the complaint lodged
Document 1
Document 2
Document 3
**Indicate if the complainant authorizes to inform the defendant of their identity:
I accept terms and conditions
**
The data provided by the complainant who initiates the procedure, as well as those data collected throughout the investigation thereof, will be included in a file created by Torre de Collserola S.A. for the exclusive purpose of fulfilling the objectives of the Whistleblowing Channel, for those cases when situations or behaviors that may involve a breach of the Torre de Collserola Code of Ethics are reported.

The data will be shared with the Torre de Collserola “Compliance Body”, the people who are required to know said data in order to investigate the facts reported and, when appropriate and depending on the issue at hand, when the data is required by the competent authorities. In any event, the data will be treated with the utmost confidentiality and in compliance with current legislation on the protection of personal data.

The complainant will be informed of the facts reported and their data protection rights as early as the investigation allows, however, the complainant's identification will not be reported, unless the complainant has given his or her express consent or has acted in bad faith.

The personal data communicated will be deleted within a period of two months following the completion of the investigation of the reported facts or, when applicable, within two months after the completion of the judicial proceedings resulting from the investigation.

To exercise the rights of access, rectification, cancellation, and opposition provided by Organic Law 15/1999, of December 13, on the Protection of Personal Data (“LOPD”), please send a signed written request, along with a copy of a document that proves your identity, to the “Compliance Body” via e-mail to canal.etico@torredecollserola.com or to the postal address: Compliance Body - Ctra. Vallvidrera to Tibidabo, s / n. - 08017 Barcelona (Data Protection).