Whistleblowing Channel Policy 

We share our "Policy on Whistleblowing Channel Management" document. Our commitment to transparency, integrity, and ethical conduct forms the foundation of this policy. It sets out our approach to whistleblowing and ensures we address concerns from our stakeholders promptly and appropriately.


The document delineates the objectives, scope, and general provisions of the policy. It emphasises the protection of personal data and the safeguarding of whistleblowers. Furthermore, it provides clarity on the operation of the whistleblowing channel. Including the classification and resolution of complaints, and the preservation of pertinent information. We believe that by fostering an environment where concerns can be voiced without fear of reprisal, we are reinforcing our dedication to upholding the highest standards of corporate governance. Here’s a summary of the sections from the document.

Introduction and objective

The policy is based on the Sustainable Business Principles (Telefónica Ethics Code). Those principles mandate that every individual associated with the Telefónica Group must adhere to both the law and internal regulations. It is the duty of all employees, officers, and directors to report any perceived irregularities. Or also actions that contravene the law or internal guidelines. This proactive approach ensures that any suspicions or doubts about irregularities are addressed. In this way, the professional, social, and ethical environment of the Telefónica Group is enhanced. The policy also aligns with the Sarbanes-Oxley Act, which necessitates the establishment of a specific channel for addressing complaints related to accounting and auditing issues.

Whistleblowing channel

The Whistleblowing Channel is a unified platform through which employees, executives, board members, and other stakeholders can report potential irregularities, including but not limited to accounting discrepancies, audit-related issues, and other internal control matters. This channel is in compliance with the Sarbanes-Oxley Act of the United States and other relevant regulations. Employees can also report any potentially irregular behaviour to their hierarchical superior executive, who shall then inform the head of the Internal Audit area.

The whistleblower has the option to remain anonymous, and we will penalise any attempts to prevent an employee from using the Whistleblowing Channel.

Registration and classification of complaints

The Internal Audit team analyses each complaint upon receipt, ensuring the confidentiality of both the whistleblower and the accused. We assign each complaint a sequential identification code. Also, we incorporate it into a database that tracks the classification and processing status of the complaint. We rank the complaints based on their importance, with 1 being the most critical and 5 being the least. Factors that determine the importance include potential criminal liabilities, risks of violating current legislation, potential damage to the group’s image, business continuity risks, the monetary value associated with the complaint, and the number of people or areas affected.

Protection of the whistleblower

The policy underscores the importance of protecting whistleblowers. Any employee who uses the Whistleblowing Channel in good faith to report irregularities, especially those related to accounting, auditing, or financial reporting, receives protection as section 806 of the Sarbanes-Oxley Act stipulates. We designed the channel to allow whistleblowers the choice to remain anonymous. If a whistleblower’s identity becomes public for any reason, measures are in place to ensure their protection.

In essence, this policy highlights Telefónica’s dedication to maintaining an ethical and transparent working environment and ensures the prompt addressing and rectification of any irregularities. The Whistleblowing Channel acts as a crucial tool in this effort, offering stakeholders a platform to express their concerns and guaranteeing appropriate responses to these concerns. Read more in the link below:


Contact our communication department or requests additional material.