Commitment to Integrity and Compliance

The Compliance and Prevention of Criminal Risks Model is a strategic part of Stackscale, S.L. and Grupo Aire’s business culture. Our company is solidly committed to the principles of integrity and compliance during the performance of all our actions.

Our social responsibility and compliance policy does not only reflect the duty of compliance in accordance with the current regulatory framework. We have also taken a decisive step and we have gone for a compliance policy based on ethical principles in accordance with the best practices, transparency and integrity that must govern all relationships among our company, employees, customers and providers.

As part of this commitment to integrity and compliance, Stackscale, S.L. has enabled a complaints channel via the email so that any of our employees, providers, customers or third parties that are unrelated to Stackscale, S.L. can bring to our attention any ethical query or question, as well as any potentially important irregularity, signs or suspicions of any unlawful behavior or any conduct that might imply the materialization of a criminal risk.

Complaints will be received and processed by the members of Stackscale, S.L.’s Compliance Unit, adopting all necessary measures in order to preserve the identity and guarantee the data privacy belonging to the individuals affected by the provided information, especially those of the person reporting the facts. Notwithstanding the above, complaints presented anonymously can also be processed whenever they include a minimum amount of content and are communicated in good faith.

Complaints must include the data required to be able to perform the analysis of the reported facts. Therefore, the received communications must comply with the following minimum requirements:

  1. Clear and detailed statement of facts.
  2. Identification of the Department and/or Business Unit where these have occurred.
  3. Name and contact details of the complainant and his/her connection to Stackscale S.L.
  4. Identification of the people involved in the reported behavior or its knowledge.
  5. At which moment the facts took place or are taking place.
  6. Quantification, whenever possible, of the reported fact’s impact on financial statements.
  7. Attachment, if considered necessary, of documents, files and other information that is deemed relevant to the assessment and resolution of the complaint.

Stackscale, S.L. will not retaliate against anyone that in good faith (i) issues any ethical query or question, (ii) brings to the company’s attention a potential violation of internal regulations, (iii) informs about a potentially unlawful conduct and/or, if applicable, a behavior that could imply the materialization of a criminal risk, or (iv) contributes to its investigation or resolution. Nevertheless, this guarantee will not include those individuals acting in bad faith with the aim of spreading false information or damaging our customers, providers, employees or company.