COMPLIANCE

SIPAY PLUS promotes a culture of compliance among its partners, staff, clients, suppliers, collaborators and other stakeholders.

SIPAY has a Criminal Risk Management and Corporate Compliance System, making it essential to communicate to its partners, staff, collaborators, clients, suppliers and other interested parties, the objective of ensuring professional and commercial performance in accordance with the mission, vision, values and commitments of the company, regulatory compliance and risk prevention.

A compliance system in accordance with SIPAY’s responsible ethical model

As part of the implementation of the Criminal Risk Management System and corporate compliance, the sole Administrator of SIPAY has approved, as top-level internal compliance regulations, the Criminal Risk Prevention Policy and the Code of Conduct, which establish the core compliance guidelines that we wish to implement in our relationships with all our partners, staff, collaborators, clients, suppliers, and other stakeholders.

Compliance Committee.

In order to provide SIPAY with the necessary mechanisms to ensure compliance with regulations, self-regulation systems, respect for acquired commitments, and the supervision and improvement of the criminal risk management and corporate compliance system, the sole Administrator of SIPAY has appointed and empowered a Compliance Committee made up of internal and external experts advising on regulatory requirements and their suitability, compliance risk management, and the design of controls, action plans, self-assessments, and verifications, in order to ensure the effective fulfillment of business obligations and the prevention of risks.

Whistleblowing channel.

At SIPAY we have zero tolerance for non-compliance with regulations, our ethical principles and malpractice.

SIPAY makes available to its members, collaborators, clients, suppliers and any interested party its Whistleblowing Channel , to communicate confidentially and even anonymously, any suspicion or knowledge of conduct, actions or omissions that may constitute an infringement of European Union Law; a criminal or administrative offense, or any breach of the values, guidelines for action or rules of conduct contained in the Code of Conduct, in the Criminal Risk Prevention Policy and in the rest of SIPAY’s internal regulations, committed by a SIPAY member in the exercise of their functions in the company.

See our Prevention Policy HERE .

Please see our Code of Conduct HERE .

Access our Complaints Channel management procedure HERE .

COMPLAINTS CHANNEL

SIPAY is fully committed to the highest ethical and regulatory compliance standards in its relationships with all its partners, staff, collaborators, clients, suppliers and other stakeholders in all the activities it carries out.

To ensure the maintenance of the Criminal Risk Management System and regulatory compliance, the sole Administrator of SIPAY has appointed and empowered a Compliance Committee made up of internal experts constantly advised by specialists in corporate risk management, among whose functions is the management of the Whistleblowing Channel.

SIPAY makes its reporting 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 a SIPAY member in the performance of their duties that constitute:

• infringement of European Union law (legal infringement);
• serious or very serious criminal or administrative offense:
• any breach of the values, guidelines for action or rules of conduct contained in the Code of Conduct; in the Criminal Risk Prevention Policy and in the rest of SIPAY’s internal regulations.

The complainant may also request, through this form, an in-person meeting with the Compliance Committee to submit a communication or complaint as previously indicated. In such case, the Compliance Committee will schedule the meeting within a maximum of seven (7) business days. If an in-person meeting is held, 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.
• A complete and accurate transcript of the conversation. In this case, the complainant will be given the opportunity to verify, correct, and accept the transcript of the conversation by signing it.

While not the preferred method for submitting complaints and as an alternative to this SIPAY Complaints Channel, complaints may be submitted through external complaint channels to the Independent Authority for the Protection of Informants, to the competent administrative authorities, where applicable, or to the institutions, bodies and agencies of the European Union.

All complaints received will be entered into a complaints register, assigning each one a unique reference number to identify it throughout its processing.

All complaints may be anonymous; that is, identifying the person making the complaint is not mandatory but optional.

It is reported that only if the informant or complainant provides an address, email or safe place for receiving notifications, will they be notified of the acknowledgment of receipt with a reference number of the complaint; SIPAY may request additional information if necessary and keep them informed of the admission or not to processing and of the corresponding resolution.

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

SIPAY states that the Whistleblowing Channel complies with the following principles and offers the following guarantees, the specific development of which can be consulted in the Whistleblowing Channel Management Procedure:

• Maximum confidentiality.
• Guarantee of the right to defense, presumption of innocence and right to honor.
• Guarantee of the principle of evidence and contradiction.
• Conflict of interest management.
• Prohibition of retaliation, including threats and attempted retaliation.
• Protection of personal data.

File a complaint:

Providing personal information is not mandatory. You can file an anonymous complaint.