Internal Information System
Grupo Celta makes available to its organisation and to third parties professionally linked to it an Internal Information System to report, in a safe and confidential manner, conduct that may be contrary to the law, to the Code of Ethics, to applicable internal regulations, and to any potentially violent conduct against children and adolescents. This system is integrated within the Group’s Compliance framework and operates in accordance with Law 2/2023 and Directive (EU) 2019/1937.
Its purpose is to provide an effective channel for the diligent receipt, management and investigation of communications regarding possible irregularities, with guarantees of confidentiality, data protection, independence and freedom from retaliation.
What you can report
Through the Internal Information System, you may report breaches of the Code of Ethics or internal regulations, bad financial, accounting or commercial practices, conduct with potential criminal relevance, serious or very serious administrative infringements, and infringements of European Union law within the scope of Directive (EU) 2019/1937 and Law 2/2023. Additionally, any situation related to compliance with the minimum regulatory requirements for the prevention of violence against children, as set out in Organic Law 8/2021 of 4 June on the comprehensive protection of children and adolescents against violence, may also be reported.
This channel is not intended for the management of suggestions, general complaints or queries from fans, users or other third parties outside its scope. For such matters, the Group has the Escoitamos channel available at https://rccelta.es/escoitamos/
Who can use it
The Internal Information System is accessible not only to people who are part of Grupo Celta, but also to third parties with whom a professional relationship exists or has existed, such as suppliers, collaborators, interns or employees.
In matters of child protection, this channel may be used by any person who forms part of Grupo Celta and by families of minors who participate in activities organised by the entity or belonging to the lower youth categories.
How to report
Communications may be submitted through the platform provided by Grupo Celta, accessible from this website, via a secure and confidential environment that allows information to be submitted both in writing and through oral communication.
The platform allows the reporting person to choose between making the communication in an identified, confidential or completely anonymous manner, guaranteeing in all cases the protection of information and compliance with the requirements set out in Law 2/2023.
Oral communications may be made directly through the functionalities enabled on the platform and will be documented securely in accordance with applicable regulations.
Additionally, the reporting person may request an in-person meeting, which will be arranged within the maximum legally permitted timeframe.
Guarantees
The Internal Information System guarantees the confidentiality of the identity of the reporting person, of any third party mentioned, and of all actions taken during the management and processing of the communication. It also guarantees the protection of personal data and limits access to information exclusively to authorised persons and bodies.
The management of communications is governed by the principles of promptness, confidentiality, presumption of innocence, objectivity, impartiality, autonomy, independence, proportionality and subsidiarity. Furthermore, reporting persons acting in good faith are protected against retaliation.
System management
The person responsible for the Internal Information System is the Director of Organisation and Quality, who acts with functional independence and without receiving instructions in the exercise of their functions. The investigation and documentation of communications is the responsibility of the Compliance Committee, except for communications relating to data protection, which will be managed by the DPO, and communications relating to harassment and the protection of children and adolescents, which will be managed by the specific committees established for those categories.
Timeframes
The system provides for the sending of an acknowledgement of receipt within a maximum period of seven calendar days from receipt of the communication, unless this could jeopardise confidentiality. It also provides for the transmission of information on the status of the proceedings within a period of no more than three months from the acknowledgement of receipt. The maximum investigation period is three months from receipt of the communication by the System Manager, extendable by a further three months in cases of special complexity.
Data protection
The processing of personal data collected through the Internal Information System will be carried out in accordance with Regulation (EU) 2016/679, Organic Law 3/2018 and Law 2/2023.
The data controller is Real Club Celta de Vigo, S.A.D., with registered address at C/ Príncipe, 44, 36202 – Vigo.
Personal data will only be retained for as long as necessary to decide whether to initiate an investigation and, in any case, for the legally stipulated periods. Where proceedings are not initiated, the data will be deleted within a maximum period of three months from receipt of the communication, unless it is necessary to retain it duly blocked in order to comply with legal obligations or to verify the functioning of the System.
External channels
Without prejudice to the preferential use of Grupo Celta’s internal channel, reporting persons may also contact public external information channels at regional and national level:
AGPI: The Galician Authority for the Protection of Reporting Persons (AGPI)
It is a collegiate body attached to the Valedora do Pobo (Galician Ombudsman), chaired by its head and composed of representatives from various institutions. Its main function is to protect whistleblowers from irregularities, manage communication channels, and initiate sanctioning proceedings.
https://canalexterno.apigalicia.gal/#/
AIPI: The Independent Authority for the Protection of Reporting Persons, A.A.I. (AIPI)
It is a public body created in Spain in 2023 as a result of Law 2/2023 of 20 February, regulating the protection of persons who report regulatory breaches and the fight against corruption.
Its main function is to protect persons who report irregularities, fraud, crimes or corrupt practices within private companies or public administrations, ensuring they do not suffer retaliation (dismissal, sanctions, harassment, etc.) for reporting.
https://www.proteccioninformante.gob.es/canales-de-presentacion-de-informaciones
Alternatively, you may also contact this authority through the following channels:
- By email: canal.externo@proteccioninformante.es
- By post (Independent Authority for the Protection of Reporting Persons, Calle Luis Cabrera 9, 28002 Madrid)
- By requesting an in-person meeting
