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INTERNAL WHISTLEBLOWING CHANNEL MANAGEMENT PROCEDURE
RMB SPAIN INMOBILIARIA
Owner: ANA MARÍN BUCHANAN (self-employed professional)
DATE: 22-12-2025
Reports may be submitted confidentially by email to: asesoria@rodriguezparis.es
Reports may be submitted anonymously.
INDEX
1. INTRODUCTION
RMB SPAIN INMOBILIARIA, operated by ANA MARÍN BUCHANAN as a self-employed professional, has implemented a Code of Ethics and Whistleblowing Policy which sets out the ethical principles and standards of conduct governing its professional and business activity.
With the aim of providing an appropriate response to any doubt, discrepancy or irregularity related to compliance with said Code, and in order to contribute to monitoring compliance with all regulations applicable to the activity, this Whistleblowing Channel is established as a communication and reporting mechanism, regulated by this Procedure.
The Whistleblowing Channel is a confidential and transparent means through which collaborators, suppliers, clients and other interested parties may report conduct that could constitute an irregularity, an unlawful act or a breach of the Code of Ethics or other applicable regulations.
Its purpose is to establish the necessary mechanisms to report and manage, at an early stage, any issue related to the scope, interpretation or compliance with applicable regulations, as well as conduct that may give rise to legal liability.
2. DEFINITIONS
For the purposes of this Procedure, the following definitions shall apply:
3. SCOPE OF APPLICATION
This Whistleblowing Channel is available to any person who maintains or has maintained a professional or commercial relationship with RMB SPAIN INMOBILIARIA and wishes to report doubts, suggestions, irregular conduct or regulatory breaches.
The Channel is confidential and may be used anonymously.
Access to the Whistleblowing Channel shall be visible and accessible via the professional website or, where applicable, through direct communication.
4. MANAGEMENT OF THE WHISTLEBLOWING CHANNEL
The Whistleblowing Channel may be hosted on an external platform that guarantees the confidentiality, integrity and security of the information, including the possibility of submitting anonymous communications.
Management of the Whistleblowing Channel lies with the owner of the activity, who may rely on specialised external collaborators where necessary, ensuring confidentiality at all times.
5. GOVERNING PRINCIPLES OF THE WHISTLEBLOWING CHANNEL
6. RECEIPT OF COMMUNICATIONS
For the attention of: ANA MARÍN BUCHANAN
Communications may be submitted through the following means:
7. WHISTLEBLOWING MANAGEMENT SYSTEM
The management system shall include the registration, filing and secure storage of received communications, implementing the necessary technical and organisational measures to ensure confidentiality and compliance with data protection regulations.
8. PROCESSING PROCEDURE FOR COMMUNICATIONS
The procedure shall consist of the following stages:
The maximum resolution period shall be three months, extendable in particularly complex cases by a further maximum of three additional months.
9. PERSONAL DATA PROTECTION
Personal data processed through the Whistleblowing Channel shall be handled in accordance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018.
The purpose of the processing shall be the management and investigation of the communications received.
Data shall be retained only for the period necessary to fulfil said purpose and the applicable legal obligations.
Data subjects may exercise their rights of access, rectification, erasure, objection, restriction and portability by submitting a written request.
10. COMPLIANCE FUNCTION COMMITMENTS
The Internal Information System Manager shall act with diligence, objectivity, independence and confidentiality, and shall refrain from intervening in the event of a conflict of interest.
11. RELATIONSHIP WITH OTHER APPLICABLE PROCEDURES
This Whistleblowing Channel does not interfere with other legal or contractual procedures that may be applicable.
12. STATEMENT OF COMPLIANCE
Compliance with this Procedure is mandatory for all persons within its scope of application.
RMB SPAIN INMOBILIARIA shall adopt the necessary measures in response to any detected breach.
13. APPROVAL, ENTRY INTO FORCE AND UPDATES
This Procedure was approved by ANA MARÍN BUCHANAN, as owner of the activity of RMB SPAIN INMOBILIARIA, on 22-12-2025, and enters into force on that same date.
It shall be reviewed periodically, at least on an annual basis, or whenever relevant regulatory changes occur.