{"id":20627,"date":"2024-04-22T13:36:03","date_gmt":"2024-04-22T11:36:03","guid":{"rendered":"https:\/\/sipay.es\/compliance\/"},"modified":"2026-05-18T11:29:09","modified_gmt":"2026-05-18T09:29:09","slug":"compliance","status":"publish","type":"page","link":"https:\/\/sipay.es\/en\/compliance\/","title":{"rendered":"Compliance"},"content":{"rendered":"\t\t
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COMPLIANCE<\/h1>

SIPAY PLUS fosters a culture of compliance among its partners, staff, clients, suppliers, collaborators, and other stakeholders.<\/h2>

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

A compliance system aligned with SIPAY’s responsible ethical model<\/h2>

As part of the implementation of the Criminal Risk Management and Corporate Compliance System, SIPAY’s sole administrator has approved the Criminal Risk Prevention Policy and the Code of Conduct as top-level internal compliance regulations. These establish the core compliance guidelines we wish to implement in our relationships with all our partners, staff, collaborators, clients, suppliers, and other stakeholders.<\/p>

Compliance Committee.<\/h2>

In order to provide SIPAY with the necessary mechanisms to ensure compliance with regulations, self-regulation systems, respect for commitments made, and the supervision and improvement of the criminal risk management and corporate compliance system, SIPAY’s sole administrator has appointed and empowered a Compliance Committee composed 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, with the aim of ensuring the effective fulfillment of business obligations and the prevention of risks.<\/p>

Whistleblowing Channel.<\/h2>

At SIPAY, we have zero tolerance for non-compliance with regulations, our ethical principles, and malpractice.<\/p>

SIPAY provides its members, collaborators, clients, suppliers, and any interested party with its Whistleblowing Channel<\/strong> to report, confidentially and even anonymously, any suspicion or knowledge of conduct, actions, or omissions that may constitute a violation of European Union law. Any criminal or administrative offense, or any breach of the values, guidelines, or standards of conduct set forth in the Code of Conduct, the Criminal Risk Prevention Policy, and other internal regulations of SIPAY, committed by a SIPAY employee in the performance of their duties within the company.<\/p>

See our Prevention Policy HERE<\/a>.<\/p>

See our Code of Conduct HERE<\/a>.<\/p>

Access the procedure for managing our Whistleblowing Channel HERE<\/a>.<\/p>

WHISTLEBLOWING CHANNEL<\/h1>

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 its activities.<\/p>

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 composed of internal experts, who are constantly advised by specialists in corporate risk management. Among its functions is the management of the Whistleblowing Channel.<\/p>

SIPAY provides its members and any interested party with its Whistleblowing Channel to confidentially and, where technically possible, anonymously report any suspicion or knowledge of conduct, actions, or omissions committed by a SIPAY member in the performance of their duties that constitute:<\/p>

  • a violation of European Union law (legal infringement);<\/li>
  • a serious or very serious criminal or administrative offense;<\/li>
  • or any breach of the values, guidelines, or standards of conduct set forth in the Code of Conduct, the Criminal Risk Prevention Policy, and other SIPAY internal regulations, including violations related to the prevention of money laundering and terrorist financing, where applicable.<\/li><\/ul>

    The whistleblower may also request, through this form, an in-person meeting with the Compliance Committee to submit a report or complaint as described above. In such cases, the Compliance Committee will schedule the meeting within a maximum of seven (7) business days. In the event of an in-person meeting, and after obtaining the express and informed consent of the complainant regarding the processing of their personal data, the conversation will be documented in one of the following ways:<\/p>

    • Recording of the conversation in a secure, durable, and accessible format.<\/li>
    • Complete and accurate transcription of the conversation. In this case, the complainant will be given the opportunity to verify the transcript.<\/li><\/ul>

      To rectify and accept the transcript of the conversation by signing it.
      While not the preferred method for filing complaints, and as an alternative to this SIPAY reporting channel, complaints may be filed through external reporting channels with the Independent Whistleblower Protection Authority, the relevant administrative authorities, or the institutions, bodies, and agencies of the European Union.<\/p>

      All complaints received will be entered into a complaint register, assigning each one a unique reference number for identification throughout its processing.<\/p>

      All complaints may be anonymous; that is, identifying the person making the complaint is optional.<\/p>

      Please note that only if the person making the complaint provides an address, email, or other secure location for receiving notifications will they receive an acknowledgment of receipt with a complaint reference number. SIPAY may request additional information if necessary and will keep you informed of the acceptance or rejection of your complaint and the corresponding resolution.<\/p>

      Complaints will be evaluated and investigated, with the aim of resolving them within a period not exceeding three (3) months from receipt of the complaint, without prejudice to any additional legally applicable timeframes when the complexity of the facts so requires, in accordance with Law 2\/2023.<\/p>

      SIPAY states that the Whistleblowing Channel complies with the following principles and offers the following guarantees, the specific details of which can be found in the Whistleblowing Channel Management Procedure:<\/p>

      • Maximum confidentiality.<\/li>
      • Guarantee of the right to defense, presumption of innocence, and right to honor.<\/li>
      • Guarantee of the principle of evidence and the right to challenge evidence.<\/li>
      • Management of conflicts of interest.<\/li>
      • Prohibition of retaliation, including threats and attempted retaliation.<\/li>
      • Protection of personal data.<\/li><\/ul>

        Filing a complaint:<\/h2>

        Providing personal data is not mandatory. You can file an anonymous complaint.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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