Corporate compliance

Whistleblowing

MB92 is committed to compliance with the law and its ethical principles and values in all facets of its business and commercial activity (hereinafter, “regulatory compliance”). Within the framework of the Corporate Compliance system it has implemented, one of the fundamental tools to guarantee regulatory compliance is the Whistleblowing Channel, through which any person may (i) bring to its attention any regulatory non-compliance of which he/she is aware or has reason to suspect, or (ii) report any doubts he/she may have regarding regulatory compliance (all the above, hereinafter, “communication”). Such communication may be made either identified or anonymously and will always be treated confidentially.

MB92’s Whistleblowing Channel is composed of a two-way communication channel:

1. Internal channel: managed by the Head of MB92’s Internal Information System (or Whistleblowing Channel), consisting of the following channels:

  • Secure platform Whistleblower Software.
  • Verbal communication directly addressed to the Head of the Whistleblowing Channel.
  • At the request of the informant, a face-to-face meeting may be held with the person in charge of the Whistleblowing Channel to explain and detail the facts of the communication.

2. External channel: managed by the designated team of the Corporate Compliance area of the Cuatrecasas law firm, and comprising the following channels:

In this regard, Mr. Alex Tagger has been appointed Compliance Officer and Head of the MB92 Whistleblowing Channel.

To regulate the use of the Whistleblowing Channel and the procedure for the investigation and resolution of complaints, MB92 has approved and implemented the Protocol for the management, investigation and response to complaints, and the Whistleblowing Policy.

MB92 has taken the necessary measures to prevent all forms of possible retaliation against whistleblowers, including threats of retaliation and attempted retaliation, and will ensure that all whistleblowers have access, as appropriate, to the necessary support measures to ensure their effective protection.

In Spain, whistleblowers may also address their communications to the regional Independent Whistleblower Protection Authority or to the Independent Whistleblower Protection Authority (state-level authority).

 

Code of Ethics

MB92 encourages the highest professional and ethical standards. Our Code of Ethics has been developed to provide guidance for our clients, associates, suppliers, employees and other individuals working with us.

Download the MB92 Code of Ethics document

Anti-Corruption Policy

MB92 is committed to working ethically and with integrity. As part of this commitment, all forms of bribery and corruption are unacceptable and will not be tolerated. We will not, and we must ensure that any third party acting on our behalf does not act corruptly in any dealings with any other person.

Download the MB92 Anti-Corruption Policy document