1. Commitment to current and applicable legislation

No relationship or commercial activity will be established with whoever has a link and/or promotes illicit commercial activities.

2. Good faith and honesty

Business relations must be carried out with clarity, objectivity, seriousness and honesty, avoiding illegal, unethical or fraudulent conduct.

3. Respect and commitment to the confidentiality of personal data

The confidentiality of the personal data accessed by reason of our professional activity must be maintained at all times, even after it has ended. It is essential to implement the appropriate security measures to protect your own and third parties' confidential or personal data.

4. Respect for people

Harassment, abuse, intimidation, disrespect and disregard at work is unacceptable and will not be tolerated.
Relationships based on respect, participation, equity and collaboration will be promoted, fostering a respectful work environment in order to achieve a positive work climate.

5. Anti-corruption and bribery policy

No type of corruption, bribery or influence peddling will be accepted to carry out a professional activity, either with the public administration or in the private sphere.

6. Occupational risk prevention

The provisions of current and applicable legislation regarding occupational risk prevention must be complied with.

7. Compliance with tax and Social Security matters

Any illicit practice involving the illicit evasion of payment of taxes to the detriment of the Public Treasury and the competent Social Security will be avoided.

8. Transparency in financial and accounting data

The economic-financial information must faithfully reflect the economic, financial and equity reality, in accordance with generally accepted accounting principles and applicable international financial reporting standards.

9. Commitment and respect for the environment

A responsible attitude towards the environment will be ensured, as well as the commitment to comply with environmental legislation and the rational use of resources. For this reason, it is necessary to avoid committing any illegal act that degrades the environment.

10. Supervision

To ensure full compliance with this Code of Ethics, it must be shared and known by the entire organization, as well as verifiable compliance when required.


Communication channels are created in order to promote compliance with the law and the rules of conduct established in the Code of Ethics and Conduct.

These communication channels can be called the "Ethical Channel" which will coincide with the same channel established for the complaint or notification of any type of illegal incident or suspicion. The characteristics and operation of said Ethical Channel are integrated in the PRP Program itself and in the respective Codes of Ethics. PALLETCAT SL has established, based on the available resources and the analysis carried out in "Annex A - Graphic table of the status of PALLETCAT SL", as well as the study carried out based on the section "Map of Criminal Risks", a specific Ethical Channel which is described below.Likewise, PALLETCAT SL will publish this Annex G as a guide for the interested party in order to make it available to all those involved in the business relationship with the organization of the procedure that has been established.


PALLETCAT SL has established as a communication channel for the referral of complaints:

1. Email: ……………………………………………………….
PALLETCAT SL has enabled the previously transcribed email which will be included in all those documents and/or communication spaces enabled in the organization.
This communication channel is established for any type of complaint, so it is also used for any relevant communication that may imply an irregularity or risk for the organization.

2. By means of a model of communication of evidence or suspicion of criminal conduct that may be obtained in physical or digital format by requesting it from the Coordinator or, where appropriate, from the Governing Body.

3. By filling in a form on the PALLETCAT SL website: WWW.PALLTECAT.CAT

The Government Body will study the communication regardless of the channel used and if it does not affect the criminal sphere, it will be redirected to the corresponding department or area. Along the same lines, as established in the “Code of Conduct” section, in the case of complaints related to non-compliance with said Code, they will be sent to the Governing Body for its management.


The Coordinator of the PRP Program or, as the case may be, the RCN will record and store the communication, assigning it a registration number for its identification. It will classify the communication by analyzing the information that has been obtained, proceeding, if necessary, in expanding it in the event that the caller has not provided all the information necessary to be able to initiate the following steps described below:

1. If the communication does not reveal a possible irregularity in criminal matters according to the advisers of the Coordinator of the PRP Program or, where appropriate, the RCN, the pertinent actions will be filed.

2. If the communication reveals a possible irregularity in criminal matters, the Coordinator of the PRP Program or, where appropriate, the RCN will contact the complainant informing them of the acknowledgment of receipt of the communication and complying with current and applicable Protection regulations. Data, informing you of your rights.

In relation to the accused, as long as it does not imply a high risk for the achievement of the investigation and resolution, you will be informed about the facts and evidence of the corresponding case, as well as the possibility of exercising your rights of access and rectification.


The Coordinator of the PRP Program or, as the case may be, the RCN will be in charge of carrying out the Instruction and Resolution procedures.

In the investigation phase, the information collected through the established communication channels will be analyzed, as well as the other actions that are considered pertinent to carry out for the correct resolution of the matter.

Once analyzed, the Coordinator of the PRP Program or, as the case may be, the RCN will present a resolution proposal to the Governing Body for the decision-making that they deem necessary to carry out and the resolution will be notified to the complainant, and/or the appropriate measures will be taken. . The resolution model used is called “Resolution model before the communication of evidence or suspicion of criminal conduct”. This model is modifiable and non-binding, the Coordinator of the PRP Program or, where appropriate, the RCN may modify or expand the notification according to the needs of the case.

All the information that is kept in this matter will be kept for 10 years due to the possible legal repercussions that may arise in the future.


PALLETCAT SL in its organization and management model has enabled an Ethics Channel with preventive effectiveness that enables the detection of acts or behaviors that could be contrary to the general or sectoral regulations that may be applicable in accordance with the Penal Code when it imposes "the obligation to report possible risks and non-compliance to the body in charge of monitoring the operation and observance of the prevention model”.

The Ethics Channel is enabled for all members who are part of our entity and/or third parties who may inform the organization of the existence of any procedural and organizational weakness that may lead to criminal risk or the commission or omission of an act. criminal.

PALLETCAT SL guarantees confidentiality, anonymity and the absence of retaliation of any kind towards the person who has brought the facts to light. The data will be kept in the system only for the time necessary to investigate the reported facts. In any case, after three months from the introduction of your personal data, our organization will proceed to delete it from the system. If its conservation is necessary to continue the investigation, our organization may continue to process your data in a different environment that corresponds legally.

Complaints may be communicated through any of the following channels enabled in the organization:

1. Email to the following address: ………………………………………….

2. Model of communication of evidence or suspicion of criminal conduct that may be obtained in physical or digital format by requesting it at the organization's offices.

3. Completion of the Ethical Channel Web Form on the entity's website: WWW.PALLTECAT.CAT


Name and surname Optional field
DAYS / NO Optional field
CP Optional field
Population Optional field
Email Optional field
Your relationship with the organization* Superior/Employee/Collaborator/Other*
Act or conduct reported and place* Detailed description of the suspicious or irregular conduct*
Attach Documentation Browse... No file selected
Note : All fields marked with an asterisk (*) are required

If you identify yourself, in accordance with current and applicable regulations on Personal Data Protection, we inform you that your data will be incorporated into the treatment system owned by PALLETCAT SL, with NIF B25358367 registered office at PG INDUSTRIAL RIAMBAUTRAMONTANA 55 25300TARREGA

LLEIDA ESP 25300, TARREGA (LLEIDA) in order to manage your communication, adopt the corresponding corrective measures and, if necessary, inform you about the result of the procedure.

The legitimizing basis of this treatment is the consent granted by the complainant.

PALLETCAT SL informs that the data will be kept for the period strictly necessary to clarify the reported facts. In any case, after three (3) months, the data provided will be destroyed unless they are investigated in a different legal environment.

Likewise, it is reported that the data will be processed in a lawful, loyal, transparent, adequate, pertinent, limited, exact and updated manner and undertakes to adopt all reasonable measures so that these are deleted or rectified without delay when they are inaccurate.

You may exercise the rights of access, rectification, limitation of treatment, deletion, portability and opposition to the processing of your personal data as well as the consent given for the treatment of the same, directing your request to the postal address indicated above or to the email: ……………………………………………………….

You can also contact the Control Authority, in this case the Spanish Agency for Data Protection, to submit the claim you deem appropriate.

Lastly, the complainant grants explicit consent for the processing of the data mentioned above.

  • I have read and accept the data protection policy so that my data is managed for the Ethical Channel.

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