ETHICS CHANNEL

1. Purpose and Objective of the Ethics Channel

The UpSocial Ethics Channel is a confidential and secure mechanism that allows employees, collaborators, clients, suppliers, and third parties to report potential irregular conduct that may constitute legal violations, regulatory non-compliance, or breaches of the principles and values set forth in the organization’s Code of Ethics.

This channel has been established in compliance with Law 2/2023 of February 20, regulating the protection of persons reporting regulatory infringements and anti-corruption measures, as well as Directive (EU) 2019/1937 of the European Parliament and of the Council, ensuring the confidentiality and protection of the whistleblower against possible retaliation.

2. Scope of Application

The Ethics Channel should be used to report irregularities in the following areas:

  • Fraudulent conduct, corruption, or bribery.
  • Breach of legal or regulatory requirements.
  • Violations of the UpSocial Code of Ethics.
  • Workplace harassment or discrimination.
  • Misuse of the organization’s resources.
  • Business practices contrary to ethics or integrity.

Any report must be made in good faith and contain sufficient information to allow for proper analysis and investigation.

3. Confidentiality and Whistleblower Protection

The reporting system guarantees:

  • Absolute confidentiality: The identity of the whistleblower and the information provided will be protected at all times.
  • Prohibition of retaliation: UpSocial ensures that anyone making a good-faith report will not face retaliation, including dismissal, demotion, or discrimination.
  • Option for anonymity: The whistleblower may choose to submit their report anonymously if desired.

4. Communication Channels

To submit a report, UpSocial provides the following means:

5. Complaint Management Procedure

  1. Receipt of the report: An acknowledgment of receipt will be provided within a maximum of 7 days.
  2. Preliminary analysis: The veracity of the information and the need to initiate an internal investigation will be assessed.
  3. Internal investigation: If appropriate, an independent team will be assigned to analyze the situation impartially.
  4. Resolution and corrective measures: If the report is confirmed, appropriate sanctions or corrective actions will be implemented.
  5. Communication of the decision: If the whistleblower has provided contact information, they will be informed of the outcome within a maximum of 3 months.

6. Data Retention and Protection

Reports and associated data will be retained for as long as necessary for the investigation and legal compliance. Subsequently, they will be deleted in accordance with the General Data Protection Regulation (GDPR) and Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).

7. Ethics Channel Policy

The UpSocial Ethics Channel Policy governs the operation of this mechanism, ensuring security, impartiality, and efficiency in the management of reports. The full document is available for consultation on our website.

8. Code of Ethics

The UpSocial Code of Ethics establishes the organization’s fundamental principles and values, promoting a work environment based on transparency, respect, and responsibility. It is available for consultation on the official website.

9. Updates and Modifications

UpSocial reserves the right to modify the operation of the Ethics Channel to comply with new regulatory requirements or organizational improvements. Any significant changes will be communicated through our official channels.

10. Contact and Inquiries

For any questions regarding the Ethics Channel, its operation, or data protection, you may contact UpSocial at info@upsocial.org.

Last updated: July 9, 2025